Privacy statement

1. Information we collect

1.1 Information you provide

When you create an account or use the Service, we may collect the following categories of information:

• Identity details: your given name, family name and date of birth.
• Contact details: your email, telephone number and residential address.
• Financial details: Broker API credentials limited to reading and placing orders, along with your investment preferences and risk controls. We do not store full broker passwords or complete payment-card numbers.
• Profile information: your username, strategy settings and alert choices.
• Communications: messages sent through support channels or by email.

1.2 Information gathered automatically

We automatically receive certain technical information when you use the Service:

• IP address, browser type and version, plus operating system.
• Pages and tools viewed, time spent on the platform and clickstream behaviour.
• Device identifiers and, where applicable, mobile advertising identifiers.
• Cookie and tracking information (see our Cookie Policy).

1.3 Information from third parties

We may receive information from identity-verification providers, fraud-prevention services and analytics partners. We can combine it with information already held to strengthen reliability and protect the Service.

2. How we use information

We may use collected information to:

• Create, manage and provide your account and the Service.
• Process trading signals and automated orders through connected brokers.
• Personalise your experience and present relevant market data.
• Send service communications, such as confirmations, trading updates and security warnings.
• Deliver marketing communications where you have consented or applicable law permits it.
• Detect, investigate and stop fraud or unlawful conduct.
• Comply with legal and regulatory duties.
• Develop, test and improve the Service using aggregated and anonymised data.

3. Legal bases for processing (EEA and UK users)

For users in the European Economic Area or the United Kingdom, we process personal data on the following legal bases:

• Performance of a contract: to provide the Service you request when opening an account.
• Legitimate interests: to prevent fraud, protect the platform and develop our product.
• Legal obligation: to meet financial-law and tax requirements.
• Consent: for marketing and optional cookies, which you may withdraw at any time.

4. When information is shared

We do not sell personal information. We may share it with:

• Service providers: cloud-hosting, email, analytics and support suppliers that are contractually bound to protect your information.
• Connected brokers and exchanges: only the API instructions required to execute the strategy you have set up.
• Public authorities: when legislation or a court requires it, or when disclosure is needed to protect our legal rights.
• Corporate transactions: as part of a merger, acquisition or transfer of assets, provided the receiving party remains bound by this policy.

5. International data transfers

Canadian Financial Access Program Inc. provides services to customers across international markets. Your information may be handled or transferred outside your country of residence, including the United States and EU Member States. Where necessary, such transfers use Standard Contractual Clauses adopted by the European Commission.

6. Data retention periods

We retain personal data for as long as your account is active or as necessary to provide the Service. After closure, certain records may be kept for up to seven years to satisfy financial and regulatory obligations. Aggregated and anonymised information may be retained indefinitely.

7. Your personal data rights

Depending on where you live and the applicable law, you may have the right to:

• Obtain a copy of the personal information we hold about you.
• Ask us to correct details that are inaccurate or incomplete.
• Ask for your personal information to be erased, sometimes known as the “right to be forgotten”.
• Challenge certain processing activities or request that they be restricted.
• Receive your information in a structured, machine-readable form.
• Withdraw your consent at any point; this does not affect processing that was lawful before withdrawal.

To exercise a data right, please contact us at [email protected]. We normally reply within 30 days.

8. Protecting your information

Our safeguards include TLS 1.3 for information in transit, AES-256 encryption for stored information, multi-factor authentication, role-based access controls and annual independent penetration testing. No technology can promise complete security. Choose a strong, unique password and enable two-factor authentication.

9. Cookies and similar technologies

We use cookies and related technologies to run and enhance the Service. More details can be found in our Cookie Policy.

10. Children's privacy

The Service is for individuals aged 18 or above. We do not knowingly collect children's personal information. If you believe a child has shared data with us, please let us know so we can remove it without undue delay.

11. Changes to this policy

We may revise this Privacy Policy from time to time. Material updates will appear on the website or be sent by email. Using the Service after a revised policy becomes effective means you accept the updated terms.

12. Contact details

For privacy enquiries or requests relating to your data rights, please contact our Data Protection Officer:

• Email: [email protected]
• Registered address: Canadian Financial Access Program Inc 200 Park Avenue, New York, NY 10166, United States, United States
• Representative in the EU: Canadian Financial Access Program, 200 Park Avenue, New York, NY 10166, United States