Privacy Policy

We collect information that you provide directly to us and information that is generated automatically when you use the Service. Information You Provide: - Account registration data: email address, username, and password. - Profile information: display name, avatar, and optional biographical details. - Payment information: processed securely by Stripe. We do NOT store your full credit card number, CVV, or bank account details on our servers. We retain only the last four digits of your card and billing address for record-keeping purposes. - Trade data: all simulated trades you execute within the platform, including entries, exits, stop losses, take profits, position sizes, and timestamps. - AI chat history: conversations with the AI Mentor, including trade analysis requests and coaching interactions. - Community content: clan names, chat messages, tournament participation data, and user-generated content posted through community features. - Support communications: messages you send to us for customer support or feedback. Information Collected Automatically: - Usage data: pages visited, features used, session duration, click patterns, and interaction data. - Device information: browser type, operating system, screen resolution, and device identifiers. - Log data: IP address, access times, referring URLs, and error logs. - Performance data: simulator performance metrics, load times, and technical diagnostics.

We use the information we collect for the following purposes: Providing the Service: - To create and manage your account. - To process subscription payments and manage billing. - To operate the simulator, AI Mentor, clans, tournaments, and all platform features. - To personalize your experience based on your trading history and preferences. Improving the AI Mentor: - Aggregated, anonymized trade data may be used to improve the AI Mentor's coaching capabilities. - Your individual trade data and AI chat history are used to provide personalized coaching within your account. - We do NOT sell your individual trade data or AI conversations to third parties. Analytics and Platform Improvement: - To understand how users interact with the Service and identify areas for improvement. - To monitor and analyze usage trends and platform performance. - To detect, prevent, and address technical issues, fraud, and security concerns. Communications: - To send you service-related notifications, billing confirmations, and account updates. - To respond to your support requests and inquiries. - To send promotional communications (only with your consent, and you may opt out at any time).

Your data is stored in PostgreSQL databases hosted on dedicated servers managed through Hetzner data center infrastructure. We implement industry-standard security measures to protect your information: - Encryption at rest: all stored data is encrypted using AES-256 encryption. - Encryption in transit: all data transmitted between your device and our servers is protected using TLS 1.3. - Access controls: database access is restricted to authorized personnel only, using role-based access controls and multi-factor authentication. - Regular backups: automated daily backups with encrypted off-site storage. - Security monitoring: continuous monitoring for unauthorized access attempts and anomalous activity. While we implement robust security measures, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security of your data, but we commit to notifying affected users within 72 hours where required by law in the event of a data breach, in accordance with applicable regulations including GDPR. Trader-First Privacy Commitment: We understand your trading data is sensitive. Your individual strategies, performance history, and AI coaching interactions are never shared with other users or sold to third parties. No user can access another user's trade data. Your edge stays YOUR edge. We will never resell your data under any circumstances. Legal Basis for Processing (GDPR): We process your data under the following legal bases: - Contractual necessity: to provide the Service you signed up for. - Legitimate interest: for analytics, security, and platform improvement. - Consent: for marketing emails and optional data sharing (you may withdraw consent at any time). For privacy-related inquiries, contact us at: [email protected]

We use the following third-party services to operate the platform. Each operates under their own privacy policies: Stripe (Payment Processing): - Processes all subscription payments and manages billing. - Receives your payment card details directly; we never see or store full card numbers. - Privacy policy: https://stripe.com/privacy Cloudflare (CDN and Security): - Provides content delivery, DDoS protection, and performance optimization. - May process IP addresses and request metadata for security purposes. - Privacy policy: https://cloudflare.com/privacypolicy Anthropic (AI Services): - Powers the AI Mentor through the Claude API. - Receives trade data and conversation content necessary to provide coaching. - According to Anthropic's current API policy, data submitted via the API is not used for model training. We recommend reviewing Anthropic's latest terms for the most current information. - Privacy policy: https://anthropic.com/privacy Vercel (Hosting): - Hosts the landing site and frontend application. - May process IP addresses and usage data for performance monitoring. - Privacy policy: https://vercel.com/legal/privacy-policy We do NOT sell, rent, or trade your personal information to any third party for marketing purposes.

Depending on your location, you may have the following rights regarding your personal data: Right of Access: - You may request a copy of all personal data we hold about you. We will provide this information in a machine-readable format (JSON or CSV) within 30 days of your request. Right to Deletion: - You may request deletion of your account and all associated personal data. Upon deletion, we will remove your data within 30 days, except where retention is required by law. - Certain anonymized, aggregated data that cannot be traced back to you may be retained for analytical purposes. Right to Portability: - You may request an export of your trade history, AI chat logs, and performance data in a structured, commonly used format. Right to Rectification: - You may request correction of any inaccurate personal data we hold about you. Right to Opt-Out: - You may opt out of promotional emails at any time by clicking the unsubscribe link in any promotional email or by updating your notification preferences in your account settings. - California residents (CCPA): You have the right to opt out of the "sale" of your personal information. We do not sell personal information, but you may still exercise this right by contacting us. - EU/EEA residents (GDPR): You have the right to withdraw consent for data processing at any time, the right to object to processing, and the right to lodge a complaint with your local data protection authority. To exercise any of these rights, contact us through our Discord community or via the email address listed on our website. We will respond to all rights requests within 30 days.

We use minimal, session-based cookies that are strictly necessary for the operation of the Service: Essential Cookies: - Authentication cookies to keep you logged in during your session. - Session cookies to maintain your preferences and simulator state. - Security cookies to prevent cross-site request forgery (CSRF) attacks. We do NOT use: - Third-party advertising or tracking cookies. - Cross-site tracking pixels or beacons. - Persistent cookies for behavioral advertising. You can configure your browser to refuse cookies, but this may prevent you from using certain features of the Service.

The Service is intended for users who are at least 18 years of age. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have collected personal data from a child under 18, we will take immediate steps to delete that information from our servers. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately so we can take appropriate action.

We retain your personal data for as long as your account is active and as needed to provide the Service. Active Accounts: - All account data, trade history, AI chat logs, and performance data are retained for the duration of your active account. - Billing records are retained for the duration required by applicable tax and financial regulations. Deleted Accounts: - Upon account deletion, we initiate a 30-day purge process during which all personal data associated with your account is permanently deleted. - During this 30-day period, you may contact us to reactivate your account and recover your data. - After the 30-day period, deletion is irreversible. Anonymized, aggregated data that cannot be linked to your identity may be retained. Inactive Accounts: - Accounts with no login activity for 12 consecutive months may be flagged as inactive. We will send a notification email before taking any action on inactive accounts.

Our servers are located in the United States and Germany (Hetzner data centers). If you access the Service from outside these regions, your data will be transferred to and processed in these locations. For users in the European Economic Area (EEA), United Kingdom, or other jurisdictions with data transfer restrictions, we rely on Standard Contractual Clauses approved by the European Commission and other appropriate safeguards to ensure your data receives an adequate level of protection during international transfers.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes: - We will post the updated policy on this page with a revised "Last Updated" date. - We will notify registered users via email or in-platform notification at least 30 days before material changes take effect. - We will obtain your consent where required by applicable law. We encourage you to review this Privacy Policy periodically for any changes.

If you participate in or are referred through our Referral Program, we collect and process additional data: Data Collected: - Referral codes used and generated by your account. - Click and conversion tracking on referral links (timestamp, referring URL, browser fingerprint hash). - Commission earnings, payout history, and payout method details. - Referred user relationships (we track which account referred which, but referred users cannot see your personal data and vice versa). Purpose: - To calculate and distribute referral commissions accurately. - To detect and prevent referral fraud (self-referrals, click fraud, cookie stuffing). - To provide you with referral performance analytics in your dashboard. Retention: - Referral tracking data is retained for the duration of your account plus 12 months after deletion (required for tax and financial audit purposes). - Commission payout records are retained for 7 years in accordance with IRS record-keeping requirements.

When you use the AI Mentor, we collect and store conversation data to provide personalized coaching: Data Collected: - Full conversation transcripts between you and the AI Mentor. - Trade analysis requests and the AI Mentor's responses. - Coaching preferences, learning progress, and personalization metadata. - AI-generated personality and trading profile data derived from your interactions. Storage and Processing: - AI conversations are stored in our PostgreSQL database, encrypted at rest. - Conversation data is sent to Anthropic's Claude API for processing. Per Anthropic's API terms, this data is not used for model training. - AI-generated trading profiles are stored locally and are never shared with other users. Retention: - Active accounts: AI conversation history is retained indefinitely to support ongoing coaching quality. - You may request deletion of your AI conversation history at any time via account settings or by contacting support. Deletion removes all stored conversations within 30 days. - Upon account deletion: all AI data is purged within the standard 30-day deletion window. Your Control: - You can export your full AI conversation history at any time in JSON format. - You can reset your AI coaching profile, which clears all personalization data and starts fresh. - Disabling AI Mentor in settings stops new data collection but does not delete existing data.

If you buy or sell items through the fxFundedSim Marketplace, we collect additional transaction data: Data Collected: - Purchase and sale history (items, prices, timestamps, counterparty usernames). - Seller payout details (processed via Stripe Connect). - Buyer payment confirmations and receipts. - Item reviews, ratings, and dispute records. Purpose: - To process and fulfill Marketplace transactions. - To calculate and distribute seller payouts and platform fees. - To resolve disputes between buyers and sellers. - To detect and prevent fraudulent transactions. Sharing: - Buyers can see the seller's display name and public profile. Sellers can see the buyer's display name. - No personal information (email, payment details, IP address) is shared between buyers and sellers. - Transaction data may be shared with Stripe for payment processing purposes. Retention: - Transaction records are retained for 7 years after the transaction date for tax and legal compliance. - Dispute records are retained for 3 years after resolution.

In addition to the essential cookies described in Section 6, we use PostHog for product analytics: PostHog Analytics: - PostHog is a privacy-focused, open-source analytics platform. - We use PostHog to understand how users interact with the Service, identify usability issues, and improve features. - PostHog collects: page views, feature usage events, session recordings (with personal data masked), and funnel analytics. Data Collected by PostHog: - Anonymized user identifiers (hashed, not your email or name). - Page URLs visited within the platform. - Feature interaction events (button clicks, form submissions, navigation patterns). - Device type, browser, operating system, and screen resolution. - Approximate geographic location (country/region level, derived from IP address which is then discarded). What PostHog Does NOT Collect: - Personally identifiable information (email, name, payment data). - Trade data, AI conversations, or coaching content. - Passwords or authentication tokens. Your Control: - You can opt out of PostHog analytics via the cookie consent banner or in your account privacy settings. - Opting out sets a do-not-track flag that prevents PostHog from collecting any data for your session. - We honor Do Not Track (DNT) browser headers for PostHog analytics. PostHog privacy policy: https://posthog.com/privacy

We send the following categories of email communications: Transactional Emails (cannot be opted out): - Account verification and password reset emails. - Subscription billing confirmations and payment receipts. - Security alerts (unusual login activity, password changes). - Account termination or suspension notices. - Legal notices and Terms/Privacy Policy updates. Product Emails (opt-out available): - Feature announcements and platform updates. - Weekly performance summaries and trading insights. - Tournament invitations and results. - Clan activity notifications. Marketing Emails (opt-in only): - Promotional offers and discounts. - Partner content and sponsored educational material. - Survey and feedback requests. Managing Your Preferences: - You can manage email preferences in your account settings under "Notifications." - Every non-transactional email includes an unsubscribe link that takes effect within 48 hours. - You may also email us directly to update your preferences. - We will never send marketing emails without your explicit opt-in consent. - Unsubscribing from marketing emails does not affect transactional email delivery.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through our official Discord community or by email at the address provided on our website. For GDPR-related inquiries, you may also contact your local data protection authority. fxFundedSim LLC Lexington, Kentucky, United States