DRAFT — This document requires legal review before public launch.
Privacy Policy
Last updated: March 2025
This Privacy Policy describes how The Great Trader ("we," "us," or "our") collects, uses, and shares information about you when you use our website and services. By accessing our platform, you agree to the collection and use of information in accordance with this policy.
1. Information We Collect
Information you provide directly
- Account information: Name, email address, date of birth, nationality, and phone number when you register.
- Payment information: Billing address and payment method details processed securely through our payment provider (Authorize.Net). We do not store raw card numbers.
- Identity verification: Government-issued ID documents and selfies submitted for KYC verification.
- Communications: Messages you send us via email or support channels.
Information collected automatically
- Log data: IP address, browser type, pages visited, time spent, and referring URLs.
- Device information: Hardware model, operating system, and unique device identifiers.
- Cookies and tracking: Session cookies, preference cookies, and analytics identifiers. See our Cookie Policy for details.
- Trading data: Performance metrics, daily P&L, trade history, and evaluation progress within our simulated environment.
2. How We Use Your Information
- To create and manage your account and provide our evaluation services.
- To process payments and issue payouts for funded accounts.
- To verify your identity and comply with regulatory requirements (KYC/AML).
- To communicate with you about your account, evaluations, and support requests.
- To improve our platform through analytics and product development.
- To send marketing communications where you have opted in.
- To detect and prevent fraud, unauthorized access, and abuse.
- To comply with applicable laws and legal obligations.
3. Legal Basis for Processing (EEA/UK)
Where applicable, we process your data on the following legal bases: performance of a contract (providing our services), legitimate interests (security, fraud prevention, improving services), legal obligation (KYC/AML compliance), and consent (marketing emails, non-essential cookies).
4. Sharing Your Information
We do not sell your personal data. We share information only in the following circumstances:
- Service providers: Rithmic (trading infrastructure), Authorize.Net (payments), Plaid/WorkMarket (payouts), identity verification providers, and cloud hosting providers. All bound by data processing agreements.
- Legal requirements: When required by law, court order, or government request.
- Business transfers: In connection with a merger, acquisition, or sale of assets, subject to standard confidentiality obligations.
5. Data Retention
We retain your personal data for as long as your account is active and for a period of up to 7 years thereafter to comply with legal and regulatory obligations (financial records, tax). Trading activity logs are retained for a minimum of 5 years.
6. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your data (subject to legal retention requirements).
- Portability: Request your data in a machine-readable format.
- Objection: Object to processing based on legitimate interests.
- Withdraw consent: Withdraw consent for marketing or non-essential cookies at any time.
To exercise your rights, contact us at privacy@thegreattrader.com.
7. Security
We implement industry-standard security measures including encryption in transit (TLS), encryption at rest for sensitive fields, access controls, and regular security reviews. However, no system is 100% secure and we cannot guarantee absolute security.
8. International Transfers
Our services are operated in the United States. If you access our platform from outside the US, your data may be transferred to and processed in the US, where data protection laws may differ from those in your country.
9. Children
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you become aware that a minor has provided us with personal data, please contact us immediately.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy with a new "Last updated" date and, where appropriate, by email.
11. Contact
For privacy-related inquiries, contact us at privacy@thegreattrader.com or via our contact page.