Privacy notice
Draft for solicitor review. Replace the bracketed details before launch.
This notice explains how [COMPANY LEGAL NAME] (company number [NUMBER], registered office [REGISTERED ADDRESS]) ("we") uses your personal data when you use this app. We are the data controller. Contact: [PRIVACY EMAIL]. ICO registration: [ICO NUMBER].
What we collect
| Data | Why | Lawful basis |
|---|---|---|
| Email, password (stored only as a one-way hash), sign-up date | To create and secure your account | Contract |
| Display name, username, chat messages | To run the members' chat | Contract |
| MT5 login number and server (never your MT5 password) | To link your trading account so you can copy trades and import your journal | Contract |
| Orders the app places, your trade history, journal notes, safety settings | To place and track copied trades and show your journal | Contract |
| Subscription status (card details stay with the payment provider) | To provide the plan you pay for | Contract |
| IP address, device type, log-in times, security events | To keep accounts secure and prevent abuse | Legitimate interests |
| Your confirmation of the risk warning and terms | To show you were told about the risks | Legal obligation / legitimate interests |
Who we share it with
Only the service providers that run the app for us, under contract: our hosting provider ([HOSTING PROVIDER, LOCATION]), the MT5 connection service (MetaApi), our email provider ([EMAIL PROVIDER]) and our payment provider (Stripe). Your trading group's admins can see your name, username, email and account status so they can support you. We don't sell your data and we don't use it for advertising.
International transfers
Where a provider processes data outside the UK, we rely on UK adequacy regulations or the UK International Data Transfer Agreement / Addendum.
How long we keep it
While your account is open. When you delete your account we delete your profile, journal, MT5 link and chat content straight away, and keep a minimal record of orders placed and security logs for up to [6] years where the law requires it.
Your rights
You can access, correct, export or delete your data, object to some uses, and complain. Download your data or delete your account at any time from Your account in the app, or email [PRIVACY EMAIL]. You can also complain to the Information Commissioner's Office (ico.org.uk).
Security
Encrypted connections, hashed passwords, two-step login for staff, strict separation between trading groups, and access logs. No system is perfect; if we ever have a breach that puts you at risk, we'll tell you.