Privacy Policy
Draft — counsel review required
This document is a working draft prepared as a starting point for review by qualified U.S. counsel. It has not been reviewed or approved by an attorney, it is not legal advice, and it is not yet in force. Do not rely on it.
Our approach
We practise data minimisation: we collect what is reasonably necessary to operate the Services and no more. Several categories of data are deliberately not collected at all.
What we collect
- Account information: name, email address, and authentication data handled by our identity provider.
- Application information: for educational programs, your general trading experience, educational goals, availability, format preference, Houston-area eligibility where relevant, expectations, and any relevant educational background you choose to share.
- Billing information: subscription and payment status from our payment processor. We never receive or store your card number.
- Product delivery information: where a product is delivered through a third party platform, the username needed to grant you access.
- Technical information: log and security data such as request metadata, used to operate and secure the Services.
What we do not collect
We do not request, and there is no place in our systems to store:
- brokerage, prop-firm, or exchange passwords, API keys, or secrets
- bank credentials or account numbers
- Social Security numbers or government identification
- your brokerage account balances, open positions, or holdings
- your income, net worth, or detailed personal financial circumstances
If we ever propose to collect sensitive financial information, that will require a fresh legal, security, and privacy review before it is implemented.
How we use information
To provide and improve the Services, review program applications, deliver products you have purchased, process payments, communicate with you about your account, and protect the Services against abuse.
We do not sell personal information. We do not send application answers or financial information into analytics platforms.
Sharing
We share information with service providers who process it on our behalf, such as our identity provider, payment processor, email provider, hosting and database providers, and error-monitoring service. They are permitted to use it only to provide services to us.
We may disclose information where required by law or to protect our rights, users, or the security of the Services.
Retention and deletion
We retain information for as long as needed to provide the Services and to meet legal, accounting, and audit obligations. You may request deletion of your account; some records, such as transaction and acceptance records, may be retained where we are required to keep them.
Your choices
You may request access to, correction of, or deletion of your personal information, and you may export your data. Contact us using the address published on our website.
DRAFT NOTE FOR COUNSEL: state-specific privacy obligations (including California, Texas, and other state privacy statutes), the required rights language, response timelines, and any "Notice at Collection" requirements must be reviewed and completed by counsel.
Security
We use current secure-development practices, encryption in transit, and provider-supported encryption at rest. No system can be guaranteed secure, and we make no such claim.
Children
The Services are not directed to anyone under 18 and we do not knowingly collect information from children.