Traider Coach Privacy Policy
1. Introduction and scope
Your privacy and trust are important to us. This Privacy Policy explains how Traider Coach Pty Ltd, trading as Traider Coach (“Traider Coach”, “we”, “us”, or “our”), collects, holds, uses, discloses, protects, and otherwise handles your personal information when you access or use Traider Coach.
Traider Coach is currently offered as a beta release to individual consumers. This Privacy Policy applies wherever you access or use Traider Coach and is not directed at, or targeted to, any particular country. During the beta, Traider Coach is provided through a downloadable desktop application; our website is used for information and sign-up. As our baseline standard we handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) and, wherever you are, we aim to handle your personal information consistently with the data-protection standards that apply to you. Where the law of your country gives you additional privacy rights, those rights apply (see Sections 16 and 21).
This Privacy Policy should be read together with the Traider Coach Terms and Conditions, the Risk Disclosure & No Financial Advice Notice, the End User Licence Agreement (EULA), the Cookie Policy, and any feature-specific notices presented to you. Capitalised terms that are used but not defined here have the meaning given to them in the Terms and Conditions.
You must be at least 18 years old to use Traider Coach. If you do not agree with this Privacy Policy, you should not access or use Traider Coach.
2. Who we are and how to contact us
Traider Coach Pty Ltd is the entity responsible for the personal information handled under this Privacy Policy. Our registered address is Tower 3 International Towers, Level 38, 300 Barangaroo Avenue, Sydney, New South Wales 2000, Australia.
If you have a question, request, or complaint about this Privacy Policy or how we handle your personal information, you can contact us by email at [email protected] or by post at the address above. During the beta, our support and privacy contact channel is email.
3. The kinds of personal information we collect
We collect and hold different types of information depending on how you use Traider Coach, which features you use, which third-party accounts you connect, and what you choose to provide. The main categories are set out below.
3.1 Account, registration, and contact information
When you create or manage an Account, start a Trial, purchase a Subscription, or contact us, we may collect information such as your name, email address, username, contact preferences, account details, registration information, and your communications and support history with us. We also collect authentication data such as your username, a hashed (not plain-text) password, multi-factor authentication status, access tokens, session data, and account-recovery information.
3.2 Onboarding and experience information
During onboarding, we ask you to indicate your general trading experience. We use the broad experience category you select to propose default Daily Stop and Trade Stop values (“Suggested Levels”) as a neutral starting point. The Suggested Levels are general defaults associated with broad experience categories; they are not based on, and do not take into account, your personal financial situation, objectives, or needs, and they are not a recommendation. You choose your own levels and can change them at any time in Settings (see also Section 7 and the Terms and Conditions).
3.3 Payment, subscription, and billing information
If you purchase a Subscription, payments are processed by our third-party payment processor, Stripe, and we do not receive or store your full payment card number, card security code, or other payment-method details — those are handled by Stripe. On our own systems we store only the billing and subscription information we need to manage your Subscription: a Stripe customer identifier, Stripe subscription and price identifiers, your Subscription tier, status, and interval, the current billing-period end and any trial end date, and related timestamps. Some additional customer and payment information may be visible to us within the Stripe dashboard, but it is stored and managed by Stripe, not on our systems.
3.4 Trading data and connected-account data
If you connect an exchange or broker account, we collect and process trading-related data through that connection. This may include trade history, orders, positions, balances, fills, partial fills, rejected and cancelled orders, fees, execution history, account activity, market data, strategy data, risk metrics, simulator data, behavioural trading data, alerts, reports, and other Platform Outputs. Connections use trade and read permissions only and never withdrawal or transfer permissions.
3.5 Order instruction and order-transmission data
When you use the Platform’s order-entry and User-Directed Order Transmission features, we process the order instructions you create and submit. This may include order type, asset, market, exchange or broker, order side, quantity, price, timing, amendment and cancellation instructions, the destination you select, order status, timestamps, transmission records, rejection messages, and fill information. We process this information to transmit your instruction to the venue you select, to show order status, to provide and support the Platform, to maintain records, to keep the service secure, and to comply with our legal obligations. We do not select the venue and do not execute orders ourselves.
3.6 Connection, API, and permission data
If you connect an exchange or broker account, we process connection metadata, account identifiers, permission settings, authentication status, and connection-status information needed to provide the relevant functionality. Traider Coach does not store your trade-enabled API keys; those keys are held on your device (client-side) or through your third-party broker or exchange connection, and we never use withdrawal or transfer permissions. You should grant only the minimum permissions necessary for order-entry and data access, and you can review, restrict, disable, or revoke permissions through the relevant exchange or broker, or through Traider Coach where applicable.
3.7 Platform outputs, analytics, simulator, education, and settings data
We collect, generate, or process data relating to Platform Outputs, Analytics, dashboards, alerts, Market Monitor and Risk Alert settings, Strategy Feedback, simulator and backtesting activity, strategy experiments, education progress, exercises, preferences, feature settings, and notification settings.
3.8 Behavioural insights and mindset-related indicators
Traider Coach processes trading-behaviour data and generates behavioural-awareness indicators, discipline indicators, emotional-pattern indicators, consistency observations, and similar trading-performance reflection outputs. These indicators are about your trading behaviour. They are not medical or psychological diagnoses, therapy, counselling, or health assessments, and we do not use them to infer health information about you.
3.9 Information collected automatically
When you use the desktop application or visit our website, we automatically collect technical, device, usage, diagnostic, and security information. This may include IP address, device type and identifiers, operating system, language preferences, approximate location and country, time zone, access times, features used, session activity, error and crash data, performance data, and logs. We use this to operate, secure, troubleshoot, analyse, and support the Platform. On our website, we use only strictly necessary cookies, which are needed for the website to work and to keep it secure (see Section 11).
3.10 Local device data, cache, logs, and diagnostics
Because the beta is delivered as a desktop application, certain data may be stored, cached, or temporarily held on your device or in your local environment, including local settings, logs, cache and temporary files, authentication tokens, session information, preferences, diagnostics, crash reports, and device identifiers. Some local data may remain on your device after logout, disconnection, software update, or uninstall, depending on your device and settings.
3.11 Beta data
During the beta, we process beta-related data, including settings, configurations, alerts, reports, simulator results, strategy experiments, education progress, behavioural insights, diagnostics, bug reports, usage observations, Platform Outputs, and support communications. Beta data may be reset, deleted, modified, become unavailable, or not be migrated to later versions of the Platform. You should not rely on beta data as your sole record of your trading activity, account activity, or Platform use.
3.12 Information you choose to provide
You may give us additional information through support requests, feedback, bug reports, surveys, communications, product suggestions, complaints, or other interactions.
Note for the beta: Traider Coach does not currently offer third-party or “social” login. If we introduce it in future, we will update this Privacy Policy to describe the information we receive from those providers.
4. We do not collect “sensitive information”
“Sensitive information” has a specific meaning under the Privacy Act — it includes information such as health, genetic, or biometric information, racial or ethnic origin, political or religious beliefs, and sexual orientation. Traider Coach does not seek to collect sensitive information, and the trading, financial, behavioural, and mindset-related data we handle is not “sensitive information” in this sense; we treat it as ordinary personal information and handle it carefully. We do not make health-related inferences about you. Please do not send us sensitive information unless we specifically ask for it; if you provide it unprompted, we will deal with it only as permitted by law, including by deleting it where appropriate.
5. How we collect your personal information
We collect personal information in three main ways: directly from you (for example, when you register, complete onboarding, subscribe, or contact us); from the exchange or broker accounts you choose to connect, using the trade-and-read permissions you authorise; and automatically, through your use of the desktop application and website (for example, device and usage data). Where it is reasonable and practicable, we collect personal information directly from you. If we receive personal information we did not ask for and could not have collected under the APPs, we will deal with it as the APPs require, including by de-identifying or destroying it where appropriate.
6. Why we collect, hold, use, and disclose your personal information
We use and disclose personal information for the purposes for which it was collected, for related purposes you would reasonably expect, and for other purposes permitted by law. These purposes include to: create, verify, secure, and manage Accounts; provide, operate, maintain, support, secure, debug, and improve the Platform, including the desktop application, dashboards, simulator, education, Market Monitor, Risk Alerts, Strategy Feedback, the Trading Mindset Module, order-entry, and User-Directed Order Transmission; propose Suggested Levels from the experience category you select; connect supported exchanges and brokers and enable the desktop application to send the order instructions you create directly to the venue you select; display, analyse, and generate Trading Data, Platform Outputs, Analytics, alerts, and reports; process payments and manage Subscriptions, Trials, renewals, cancellations, invoices, and refunds; provide support and respond to your enquiries and complaints; send administrative, transactional, security, billing, service, and policy communications; send marketing communications where you have consented or where otherwise permitted (see Section 8); understand and improve how our website performs; detect, prevent, and respond to fraud, misuse, unauthorised access, security incidents, sanctions and financial-crime risk, market-abuse concerns, and breaches of our Terms; comply with our legal, regulatory, tax, accounting, and audit obligations; establish, exercise, or defend legal rights; support beta testing and improve reliability; and create and use aggregated, anonymised, or de-identified data.
7. Automated decisions, AI-assisted analysis, profiling, and behavioural insights
Traider Coach uses automated analysis, algorithmic models, and AI-assisted features to produce Platform Outputs — including Suggested Levels, Risk Alerts, Market Monitor outputs, Strategy Feedback, behavioural insights, Trading Mindset Module outputs, simulator feedback, and execution-quality analysis. These outputs are generated automatically, without human review, from the data described in this Privacy Policy (such as your settings, connected-account trading data, usage data, and the experience category you select).
These features are decision-support and informational tools. They do not provide financial advice, investment advice, trade recommendations, or psychological, medical, or professional advice, and the Suggested Levels are general defaults that you choose and can change at any time — they are not a personal recommendation and are not based on your personal financial situation, objectives, or needs. You remain in control: you can review and adjust Suggested Levels and other settings, and you can update your inputs, correct your Account information, or contact us about an output that appears wrong.
These outputs are decision-support only: they are suggestions, defaults, analysis, and feedback that you review and control, and you make your own decisions using them. They are not automated decisions that produce legal or similarly significant effects for you — for example, they do not determine your eligibility, pricing, or access to the Platform. We will keep this section up to date in line with the transparency requirements that apply to automated decision-making wherever you are.
Today, we do not use your personal, trading, or behavioural information to train or improve our models or AI systems. If we decide to do this in future, we will update this Privacy Policy first, and any such use will be based on your consent or limited to de-identified data.
8. Direct marketing
We may send you marketing or promotional communications only where this is permitted by law and consistent with the consent and opt-out requirements of the Privacy Act and the Spam Act 2003 (Cth). At sign-up, marketing consent is captured separately from your acceptance of the Terms and Conditions and this Privacy Policy, through a distinct, optional opt-in that is not pre-selected — so consenting to marketing is never a condition of using Traider Coach. Every marketing email will include an easy way to unsubscribe, and you can also opt out by contacting us. Even if you opt out of marketing, we may still send you transactional, administrative, security, billing, service, account, and policy communications.
9. Who we share your personal information with
We disclose personal information to the service providers and other parties that help us provide and operate Traider Coach, and where the law permits or requires. Our current service providers are: Scaleway (cloud infrastructure, in France and Poland); Hetzner (cloud infrastructure, in Germany); Amazon Web Services (infrastructure services only, in Germany — no user data is stored there); Stripe (payment processing; a United States company, processing payment data primarily in the EU); Resend (transactional email delivery, in Ireland and Germany); and Cloudflare (web application firewall and reverse proxy; a United States company, using EU endpoints). We also disclose personal information to the exchanges and brokers you choose to connect, to the extent needed to provide connected-account functionality. We may also disclose personal information to our professional advisers (such as lawyers, accountants, and auditors); to regulators, law-enforcement agencies, courts, or other authorities where permitted or required by law, or where reasonably necessary to protect rights, safety, security, or market integrity, or to prevent misuse; in connection with a business transaction such as a merger, acquisition, financing, or sale of assets; and with your consent or at your direction. We do not sell your personal information, and we do not share it with third parties for targeted or behavioural advertising.
10. Sending information overseas
Traider Coach stores your personal information on servers located within the European Union — in France, Germany, and Poland. Because we use the service providers listed in Section 9, your personal information is likely to be disclosed to, or accessed from, overseas recipients. In particular, your data is hosted in France, Germany, and Poland; and two of our service providers, Stripe and Cloudflare, are United States companies that may access personal information from the United States even though they process it using EU-based facilities. Before disclosing personal information to an overseas recipient, we take steps that are reasonable in the circumstances to ensure the recipient handles it consistently with this Privacy Policy and applicable data-protection standards, and we remain accountable for personal information we disclose overseas as required by the Privacy Act and other laws that apply to you.
11. Cookies and similar technologies
Our website, including its sign-up and account pages, uses only strictly necessary cookies and similar technologies. These are needed for the website to work and to keep it secure — for example, to maintain sign-up, registration, and login sessions, to authenticate you, to protect the website against bots, fraud, and misuse, and to support account and payment flows. Because these cookies are strictly necessary to provide the service you request, they do not require your consent, and we therefore do not display a cookie-consent banner. We do not currently use analytics, advertising, or tracking cookies, and we do not use cookies to show you targeted advertising. In future we may use privacy-friendly website analytics to understand how our website is used; if we ever introduce cookies or similar technologies that are not strictly necessary, we will update this Privacy Policy and our Cookie Policy and, where the law requires, ask for your consent before using them. The downloadable desktop application does not use cookies, although it generates and processes local technical data such as logs, diagnostics, crash reports, cache, settings, and session information, as described in this Privacy Policy and the EULA. More detail is set out in our Cookie Policy. You can block or delete cookies through your browser settings, but if you block strictly necessary cookies, parts of the website (such as sign-up and login) may not work properly.
12. Keeping your information accurate
We take reasonable steps to ensure the personal information we collect, use, and disclose is accurate, up to date, complete, and relevant, having regard to the purpose for which it is held. You can help us by keeping your Account information current and by letting us know if any information we hold is inaccurate or out of date (see Section 16).
13. How we keep your information secure
We take reasonable technical and organisational steps to protect personal information from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. These steps include access controls, encryption in transit, hashing of passwords, and security monitoring. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are also responsible for protecting your Account, devices, credentials, email account, authentication methods, local environment, and connected-account permissions, and for any data you export or store outside Traider Coach.
14. Data breaches
If a data breach occurs that is likely to result in serious harm to affected individuals, we will assess and respond to it in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying the affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.
Traider Coach maintains a documented Data Breach Response Plan aligned with the Notifiable Data Breaches scheme. If an eligible data breach occurs, we will assess it and, where required, notify the affected individuals and the Office of the Australian Information Commissioner as the scheme requires.
15. How long we keep your information
We keep personal information only for as long as we reasonably need it for the purposes described in this Privacy Policy, or for as long as we are required to keep it by law. When we no longer need it, we take reasonable steps to destroy it or to de-identify it. Our current retention periods are, in summary:
Account, profile, onboarding, settings, trading and connected-account data, order and behavioural data: kept while your Account is active, then deleted or de-identified within about 90 days after your Account is closed (you can export your trading history before deletion). Payment and billing records: kept for seven years, to meet tax, accounting, and audit obligations. Connection and API metadata (we never store trade-enabled keys): kept while the connection is active and removed on disconnection or within about 90 days of Account closure. Technical and usage data: about 12 months. Application and security logs: operational logs about 90 days, security logs about 12 months. Support communications: about two years after the matter is resolved. Marketing consent records: for the duration of the marketing relationship plus about three years, while unsubscribe/suppression records are kept indefinitely so we continue to honour your opt-out. De-identified and aggregated data: may be kept indefinitely, as it is no longer personal information.
These periods may be extended where we are required or permitted by law to retain information, or where it is needed to establish, exercise, or defend a legal claim. If you disconnect an exchange or broker, we stop receiving new data from that source, although previously collected data may remain in your Account, backups, logs, or records as described here. Deleting an Account may not immediately remove all data from backups, logs, support records, or payment and legal records, some of which we may need to retain.
16. Accessing and correcting your information
You may ask us for access to the personal information we hold about you, and you may ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading. To make a request, email [email protected]. We will respond within a reasonable period and, in most cases, give access in the way you ask. We may need to verify your identity first. If we refuse access or correction, we will tell you why in writing (except where it would be unreasonable to do so) and explain how you can complain. There is no charge to make a request, although we may charge a reasonable cost for giving access in some cases. Depending on where you live, you may also have additional rights — such as to request deletion or erasure, to object to or restrict certain processing, to withdraw consent at any time, and to data portability. To exercise any of these, contact us at the same address; we will respond within the time your law requires and may need to verify your identity.
17. Dealing with us anonymously
Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym — for example, when making a general enquiry. However, for most of Traider Coach’s features (such as creating an Account, subscribing, connecting an exchange or broker, or submitting orders) we need to identify you in order to provide the service, keep it secure, and meet our legal obligations, so anonymous use of those features is not practicable.
18. Making a privacy complaint
If you think we have breached the Australian Privacy Principles or otherwise mishandled your personal information, please contact us first at [email protected] so we can investigate and respond. We will acknowledge your complaint and aim to resolve it within a reasonable time. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au, by phone on 1300 363 992, or by post to GPO Box 5288, Sydney NSW 2001. If you are located in another country, you may also have the right to complain to the privacy or data-protection authority for your country.
19. Children
Traider Coach is intended only for individuals who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has provided us with personal information, please contact us and we will take appropriate steps to delete it.
Traider Coach is intended only for individuals who are at least 18 years old. At sign-up you must confirm, through a required check-box, that you are at least 18. In addition, the trading features of the Platform require you to have a pre-existing account with a supported exchange or broker, which those providers generally make available only to adults. We do not knowingly collect personal information from anyone under 18; if we become aware that we have, we will take reasonable steps to delete it.
20. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version is shown by the “Last updated” date at the top. If we make a material change, we will take reasonable steps to notify you, such as by email or an in-app or website notice, where required by law. Your continued use of Traider Coach after an updated Privacy Policy takes effect indicates your acknowledgement of the update, to the extent permitted by law.
21. Other countries (future)
This Privacy Policy applies wherever you use Traider Coach. Where the law of your country gives you additional or different privacy rights — for example, the General Data Protection Regulation for users in the European Union or the United Kingdom, or state privacy laws in the United States — those rights apply to you, and if we open or target specific markets we may provide additional local privacy terms at that time.
22. Relationship between this Privacy Policy and the Terms
If there is any inconsistency between this Privacy Policy and the Terms and Conditions about how personal information is collected, held, used, disclosed, or protected, this Privacy Policy applies to the extent of the inconsistency, unless the law requires otherwise. For other matters — such as Platform access, Subscriptions, Trials, billing, trading responsibility, risk disclosures, order-entry and User-Directed Order Transmission, and limitations of liability — the Terms apply to the extent of any inconsistency, unless the law requires otherwise.
23. Contact us
If you have any questions, requests, or complaints about this Privacy Policy or how we handle your personal information, contact us at:
Email: [email protected]
Post: Traider Coach Pty Ltd, Tower 3 International Towers, Level 38, 300 Barangaroo Avenue, Sydney, New South Wales 2000, Australia.
Traider Coach may currently fall below the A$3 million small-business threshold under the Privacy Act. Regardless of whether that threshold applies, we have chosen to comply with the Privacy Act and the Australian Privacy Principles, and this Privacy Policy is written on that basis.