Privacy Policy
Strategy Trader – Your Trading Companion
IMPORTANT DISCLAIMER
Strategy Trader is NOT a trading platform, broker, or financial advisor. We are a trading journal, analysis tool, and educational companion application. We do not execute trades, hold funds, or provide investment advice.
Any AI-generated insights, psychology reviews, or strategy suggestions provided through our Services are for informational and educational purposes only and do not constitute financial, investment, or trading advice. Trading involves significant financial risk. You should consult with a licensed financial advisor before making any investment decisions.
PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS.
Strategy Trader Inc. (“Strategy Trader,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile applications (iOS and Android), website (strategytrader.ai), and related services (collectively, the “Services”). This policy complies with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Legislation (CASL), the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), Google Play Store requirements, and Apple App Store guidelines.
1 About Us and Accountability
Strategy Trader Inc. is a Canadian corporation headquartered in Ontario, Canada. We are accountable for the personal information under our control. Our Privacy Officer is responsible for ensuring compliance with this Privacy Policy and applicable privacy laws, including maintaining the accuracy of personal information we hold.
Strategy Trader Inc.
162 Oakdale Ave
St. Catharines, Ontario L2P 2K9
Canada
Privacy Officer: Omid Mohamad Beigi
Email: [email protected]
Phone: +1 (365) 323-4477
Website: https://strategytrader.ai
2 Scope of This Policy
This Privacy Policy applies to:
- Our mobile applications available on the Apple App Store and Google Play Store
- Our website at strategytrader.ai
- Any related services, features, or content we provide
- Communications between you and Strategy Trader
Important: This policy does not apply to third-party websites, applications, or services linked from our Services. We encourage you to review the privacy policies of any third-party services you access.
3 Personal Information We Collect
Under PIPEDA, “personal information” means any information about an identifiable individual. We collect the following types of personal information:
3.1 Information You Provide Directly
| Category | Data Collected | Required/Optional |
|---|---|---|
| Account Information | Email address, username, password (encrypted) | Required |
| Profile Information | Name, profile picture, bio, phone number, social links (Telegram, TradingView) | Optional |
| Trading Preferences | Preferred currency, timezone, markets (forex, crypto, stocks) | Optional |
| Trading Journal | Trade details (symbol, direction, entry/exit prices, P&L), notes, chart screenshots | User Generated |
| Psychological Data | Emotional states before/after trades, confidence levels (1-10), plan adherence, lessons learned, mistakes | User Generated |
| Strategy Configurations | Trading strategies, indicators, conditions, backtest parameters | User Generated |
| Communications | Support requests, feedback, survey responses | Optional |
| Payment Information | Processed securely by Stripe; we do not store credit card numbers | For Subscriptions |
3.2 Information Collected Automatically
| Category | Data Collected | Purpose |
|---|---|---|
| Device Information | Device type, operating system, unique device identifiers, advertising ID | Service delivery, security |
| Usage Data | Features used, screens visited, actions taken, time spent in-app, session duration | Service improvement |
| Log Data | IP address (partially masked in displays), access times, request paths, response codes | Security, debugging |
| Location Data | Approximate location based on IP address only (no GPS or precise location) | Regional settings, fraud prevention |
| Session Data | Login history, active sessions, device fingerprints, last active timestamps | Account security |
| Crash Reports | Error logs, performance data (anonymized – no email, IP, or username sent) | App stability |
3.3 Information from Third Parties
If you sign in using a third-party service (Google Sign-In or Apple Sign-In), we may receive your name, email address, and profile picture from that service, subject to your privacy settings with that provider.
3.4 Anonymized and Aggregated Data
We may create anonymized or aggregated data from your personal information. This means:
- Anonymized Data: Personal identifiers are permanently removed or replaced so the data can no longer be linked to you, even when combined with other data. Anonymization is irreversible
- Aggregated Data: Individual-level data is combined with data from many users to create statistical summaries (e.g., “average win rate across all users”). Aggregated data does not identify individuals
Once data is truly anonymized or aggregated, it is no longer considered personal information under PIPEDA and may be used for research, analytics, and service improvement without restriction.
3.5 Accuracy of Personal Information
In accordance with PIPEDA’s accuracy principle, we strive to ensure that personal information we use or disclose is accurate, complete, and up-to-date. You may update your personal information at any time through:
- In-app: Settings → Profile → Edit
- Email: [email protected]
If you believe any information we hold about you is inaccurate, please contact us and we will correct it promptly.
4 How We Use Your Information
We identify the purposes for collecting personal information at or before the time of collection. We use your information for:
| Purpose | Legal Basis (GDPR) |
|---|---|
| Provide and maintain our Services (account management, core features) | Contract Performance |
| Process payments and subscriptions | Contract Performance |
| AI-powered features (chart analysis, psychology reviews, strategy suggestions) | Consent |
| Trading analytics and performance metrics | Contract Performance |
| Send service-related notifications | Contract Performance |
| Marketing communications (with consent) | Consent |
| Security, fraud prevention, and abuse detection | Legitimate Interests |
| Improve our Services and develop new features | Legitimate Interests |
| Legal compliance and responding to lawful requests | Legal Obligation |
We do not sell your personal information to third parties.
5 Psychological Profiling and Behavioral Analysis
Our Services include AI-powered psychological analysis features that analyze your trading behavior and emotional patterns. This section explains exactly how this profiling works.
5.1 What Data Is Analyzed
When you use our Trading Journal and opt into psychology features, we analyze:
- Emotional states: Your self-reported emotions before and after trades
- Confidence levels: Your self-reported confidence ratings (1-10)
- Trading patterns: Win rates, timing patterns, streak data
- Plan adherence: Whether you followed your trading plan
- Mistakes and lessons: Self-documented errors and learnings
5.2 How Profiling Is Used
This analysis generates:
- Personalized psychology tips and mindset suggestions
- Identification of emotional trading patterns (e.g., “You tend to overtrade after losses”)
- Danger zones and warning indicators
- Strengths and areas for improvement
- Daily mindset recommendations
Important: Psychological profiling does NOT make automated decisions that produce legal effects or similarly significantly affect you. All insights are informational and educational only. No trading decisions are made automatically on your behalf.
5.3 Your Rights Regarding Profiling
- Opt-out: You may disable psychology features at any time (Settings → Privacy → AI Features)
- Human review: Request human review of any AI-generated insight
- Explanation: Request an explanation of how specific insights were generated
- Deletion: Request deletion of your psychological profile data
6 AI and Machine Learning Processing
Our Services utilize artificial intelligence to enhance your trading experience. This section provides detailed disclosure of our AI processing.
6.1 Chart Screenshot Analysis
| Attribute | Details |
|---|---|
| Purpose | Extract trading information from chart images to auto-populate journal entries |
| Data Sent to AI | Chart image, user ID (anonymized), requested extraction fields |
| AI Provider | Microsoft Azure OpenAI (GPT-4o Vision) or Anthropic Claude |
| Data Retention by Provider | Azure: 30 days for abuse monitoring; Anthropic: Not used for training |
| Can Opt Out? | Yes – manually enter journal data instead |
6.2 Psychology Review Generation
| Attribute | Details |
|---|---|
| Purpose | Generate personalized trading psychology insights and recommendations |
| Data Sent to AI | Aggregated journal metrics (win rates, emotion patterns, timing data), anonymized user ID |
| AI Provider | OpenAI (GPT models) |
| Data Retention by Provider | API data not used for training; retained up to 30 days for abuse monitoring |
| Can Opt Out? | Yes – Settings → Privacy → Disable Psychology Features |
6.3 Strategy Analysis
| Attribute | Details |
|---|---|
| Purpose | Generate strategy descriptions and optimization suggestions |
| Data Sent to AI | Strategy parameters, indicator conditions, backtest results (no personal identifiers) |
| AI Provider | OpenAI |
| Data Retention by Provider | API data not used for training |
| Can Opt Out? | Yes – use strategies without AI-generated descriptions |
How to Opt Out of AI Processing
You may opt out of AI-powered features in the following ways:
- In-App Settings: Settings → Privacy → AI Processing → Toggle OFF
- Email Request: Send “AI OPT-OUT” to [email protected]
- Online Form: strategytrader.ai/privacy-request
What happens when you opt out:
- Chart analysis will be disabled; enter journal data manually
- Psychology reviews will not be generated
- Strategy AI suggestions will be disabled
- Core app functionality remains fully available
We will process your opt-out within 15 days.
7 Third-Party Services
We share your personal information with the following categories of third-party service providers:
Stripe
Secure payment processing. Card data goes directly to Stripe – we never see or store it.
Payment Processing
Data: Payment amount, currency, customer ID
Amazon Web Services (AWS)
Cloud hosting, email delivery (SES), and screenshot storage (S3).
Infrastructure
Data: All app data (encrypted at rest)
Sentry
Crash reporting and error tracking. PII is scrubbed before transmission – no email, IP, or username sent.
App Stability
Data: Anonymized error logs, device info
OpenAI
AI-powered psychology insights and strategy analysis.
AI Features
Data: Aggregated metrics, anonymized context. Privacy Policy
Microsoft Azure OpenAI
AI-powered chart screenshot analysis (GPT-4o Vision).
AI Features
Data: Chart images, extraction context. Privacy Policy
Anthropic (Claude)
Alternative AI provider for chart analysis.
AI Features
Data: Chart images. Privacy Policy
Google OAuth
Sign in with Google authentication.
Authentication
Data: OAuth token, email, name, profile picture. Privacy Policy
Apple Sign-In
Sign in with Apple authentication.
Authentication
Data: OAuth token, email (may be hidden), name. Privacy Policy
Telegram Bot API
Trading signal distribution. Only activated if you connect your Telegram account.
Signal Alerts
Data: Telegram user ID, chat ID, username (only if connected). Privacy Policy
Market Data Providers
Bybit, Yahoo Finance, Finnhub for real-time market data (public data only).
Market Data
Data: None – read-only public APIs
ClickHouse Cloud
Analytics and time-series data storage. Data is aggregated and anonymized before storage.
Analytics
Data: Anonymized usage metrics, no PII
These service providers are contractually obligated to protect your personal information and use it only for the purposes for which it was disclosed. We maintain Data Processing Agreements with all providers.
8 Consent
8.1 Express Consent
We obtain your express consent for:
- Sending marketing and promotional communications
- Processing psychological/emotional data through AI services
- Sharing chart screenshots with AI providers for analysis
- Collecting camera/photo library data for chart screenshots
- Push notifications (you can manage preferences)
8.2 Implied Consent
Your consent may be implied when you:
- Voluntarily provide personal information for an obvious purpose
- Continue to use our Services after being notified of changes to this Privacy Policy
8.3 Withdrawing Consent
You may withdraw your consent at any time:
- Marketing communications: Click “unsubscribe” in any email or disable in app settings
- Push notifications: Disable in your device settings or Settings → Notifications
- AI features: Settings → Privacy → AI Processing → Toggle OFF
- Other purposes: Contact our Privacy Officer at [email protected]
9 International Data Transfers
Your personal information may be transferred to, stored, and processed in countries outside of Canada:
| Provider | Location | Purpose | Safeguards |
|---|---|---|---|
| AWS | US, Canada | Infrastructure, storage | Standard Contractual Clauses |
| Stripe | US | Payments | PCI-DSS compliant |
| OpenAI | US | AI Processing | Data Processing Agreement |
| Azure OpenAI | US | AI Processing | Standard Contractual Clauses |
| Anthropic | US | AI Processing | Data Processing Agreement |
| ClickHouse | US | Analytics | Standard Contractual Clauses |
For EU/EEA Residents: Canada has been recognized by the European Commission as providing an adequate level of protection for personal data. For transfers to the United States, we rely on Standard Contractual Clauses approved by the European Commission.
10 Data Retention
We retain your personal information only as long as necessary to fulfill the purposes for which it was collected:
Account Information
Retained while your account is active and for 2 years after deletion for legal compliance
Trading Journal & Strategies
Retained while your account is active; deleted within 30 days of account deletion request
Chart Screenshots
Retained while your account is active; deleted within 30 days of account deletion request
Usage Data & Analytics
Retained in identifiable form for up to 24 months, then aggregated or anonymized
Transaction Records
Retained for 7 years as required by Canadian tax law and financial regulations
Security & Login Logs
Retained for 24 months for security and fraud prevention
Security Breach Records
Retained for minimum 24 months as required by PIPEDA
Marketing Preferences
Retained until you unsubscribe or withdraw consent
10.1 What Happens After Account Deletion
When you delete your account:
- Profile, journal entries, strategies, and screenshots are deleted within 30 days
- Transaction/payment records are retained for 7 years (legal requirement)
- Anonymized aggregate analytics may be retained indefinitely
- Any data shared with AI providers follows their retention policies (typically 30 days)
- Backup systems are purged within 90 days
11 Security Safeguards
We implement appropriate technical, administrative, and physical security measures to protect your personal information:
- Encryption: Data encrypted in transit (TLS 1.3) and at rest (AES-256)
- Password Security: Passwords stored using industry-standard hashing (bcrypt)
- Token Security: API tokens stored as SHA-256 hashes; raw tokens shown only once at creation
- Access Controls: Employee access limited on a need-to-know basis
- Session Management: Active sessions trackable; users can revoke sessions remotely
- Two-Factor Authentication: Optional TOTP-based 2FA available
- Biometric Security: Optional fingerprint/face unlock (processed locally on device hardware – never sent to servers)
- IP Masking: IP addresses partially masked in user-facing displays
- Regular Assessments: Ongoing security monitoring and assessments
While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.
12 Your Rights Under Canadian Law (PIPEDA)
Under PIPEDA and applicable Canadian privacy laws, you have the following rights:
Right to Access
Request access to personal information we hold about you within 30 days
Right to Correction
Request correction of inaccurate or incomplete personal information
Right to Withdraw Consent
Revoke consent for collection, use, or disclosure at any time
Right to Deletion
Request deletion of your personal information, subject to legal requirements
Right to Know
Inquire how your information is used and disclosed
Right to Challenge
File complaints about our data handling practices
12.1 Right to Data Portability
You may request a copy of your personal data in a structured, commonly used, machine-readable format. This includes:
- Your trading journal entries (JSON or CSV format)
- Strategy configurations (JSON format)
- Profile information (JSON format)
- Activity logs (CSV format)
To request your data export:
- In-app: Settings → Privacy → Export My Data
- Email: Send “DATA EXPORT REQUEST” to [email protected]
We will provide your data within 30 days of receiving your verified request, free of charge.
To exercise any of these rights:
- In-app: Settings → Privacy → Data Request
- Email: [email protected]
We will respond to your request within 30 days.
13 Additional Rights for EU/EEA Residents (GDPR)
European Economic Area & United Kingdom
If you are located in the European Economic Area or United Kingdom, you have the following additional rights under the General Data Protection Regulation (GDPR):
Your GDPR Rights
- Right to Access (Article 15): Obtain confirmation of processing and a copy of your personal data
- Right to Rectification (Article 16): Correct inaccurate or incomplete data
- Right to Erasure (Article 17): Request deletion (“right to be forgotten”) in certain circumstances
- Right to Restrict Processing (Article 18): Limit how we use your data
- Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format (JSON/CSV)
- Right to Object (Article 21): Object to processing based on legitimate interests or for direct marketing
- Rights Related to Automated Decision-Making (Article 22): Not be subject to decisions based solely on automated processing; obtain human intervention
Legal Basis for Processing
| Purpose | Legal Basis |
|---|---|
| Account management, service delivery | Contract Performance (Art. 6(1)(b)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| AI-powered features | Consent (Art. 6(1)(a)) |
| Analytics and service improvement | Legitimate Interests (Art. 6(1)(f)) |
| Fraud prevention and security | Legitimate Interests (Art. 6(1)(f)) |
| Tax and legal compliance | Legal Obligation (Art. 6(1)(c)) |
Right to Object to Direct Marketing
You may object at any time to processing of your personal data for direct marketing purposes. If you object, we will immediately stop using your data for marketing.
Automated Decision-Making
Our AI features analyze your data but do NOT make decisions that produce legal effects or similarly significantly affect you without human involvement. All AI insights are informational only. You may request human review of any AI-generated analysis.
International Transfers
Your data may be transferred outside the EEA. Canada is recognized by the European Commission as providing adequate protection. For transfers to the US, we use Standard Contractual Clauses.
Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your residence. Find your local authority at: EDPB Member List
Contact
For GDPR-related inquiries, contact us at: [email protected]
14 Additional Rights for California Residents (CCPA/CPRA)
California Consumer Privacy Act
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):
Your California Privacy Rights
- Right to Know: Request disclosure of categories and specific pieces of personal information collected, sources, purposes, and third parties with whom we share
- Right to Delete: Request deletion of personal information we collected from you
- Right to Correct: Request correction of inaccurate personal information
- Right to Opt-Out: Opt out of the sale or sharing of personal information
- Right to Limit Use: Limit use and disclosure of sensitive personal information
- Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights
Categories of Personal Information Collected
| CCPA Category | Collected? | Sold/Shared? |
|---|---|---|
| A. Identifiers (name, email, IP address, device ID) | Yes | No |
| B. Personal Records (name, address, phone, financial info) | Yes | No |
| C. Protected Classifications (age, race, religion, sexual orientation) | No | No |
| D. Commercial Information (transaction history, purchase tendencies) | Yes | No |
| E. Biometric Information | No** | No |
| F. Internet/Network Activity (browsing, app usage) | Yes | No |
| G. Geolocation (approximate, from IP only) | Yes | No |
| H. Sensory Data (photos, chart screenshots) | Yes*** | No |
| I. Professional/Employment Information | No | No |
| J. Education Information | No | No |
| K. Inferences (preferences, trading patterns, psychological traits) | Yes | No |
| Sensitive Personal Information | Limited* | No |
*Account login credentials only, used solely for authentication purposes.
**Biometric data for app unlock is processed locally on your device and never transmitted to our servers.
***User-uploaded chart screenshots only, with explicit consent.
We do not sell or share your personal information for cross-context behavioral advertising.
How to Exercise Your Rights
- Online Form: strategytrader.ai/privacy-request
- Email: [email protected]
- Phone: +1 (365) 323-4477
Response Timeline
We will respond to verifiable consumer requests within 45 days. If we need more time (up to 90 days total), we will notify you in writing.
Verification
We will verify your identity using information associated with your account. If you do not have an account, we may request additional information.
Authorized Agents
You may designate an authorized agent to submit requests on your behalf. We may require written proof of authorization.
Global Privacy Control (GPC)
We recognize and honor Global Privacy Control (GPC) signals from your browser as a valid opt-out request for the sale/sharing of personal information.
15 Account Deletion
You may delete your account at any time through:
- Mobile app: Settings → Account → Delete Account
- Website: Account Settings → Delete Account
- Email: Contact [email protected]
When you delete your account:
- Your profile and account information will be permanently deleted within 30 days
- Your trading strategies, journal entries, and analytics will be deleted
- Your uploaded screenshots will be removed from our servers
- If using Sign in with Apple, we will revoke your tokens via Apple’s REST API
- Transaction/payment records retained for 7 years (legal requirement)
- Anonymized aggregate data may be retained
- Data in AI provider systems follows their retention policies
Account deletion is permanent and cannot be undone.
16 Mobile App Permissions
Our mobile applications may request the following device permissions:
| Permission | Purpose | Required? |
|---|---|---|
| Internet | Connect to our servers for all app functionality | Required |
| Camera | Take photos of trading charts for AI analysis and journal entries | Optional |
| Photo Library | Select existing chart screenshots from your device | Optional |
| Notifications | Receive trading alerts, signal notifications, and account updates | Optional |
| Biometrics | Secure app access using fingerprint or face recognition (processed locally) | Optional |
You can manage these permissions in your device settings at any time.
16.1 Push Notifications
If you enable push notifications, you may receive:
- Trading alerts: Price alerts, position updates, margin calls, order fills
- Strategy signals: New signals from subscribed strategies
- Market updates: Breaking news, earnings announcements
- Account notifications: Login alerts, security events, billing updates
To manage notifications:
- iOS: Settings → Notifications → Strategy Trader
- Android: Settings → Apps → Strategy Trader → Notifications
- In-app: Settings → Notifications → Manage Preferences
You can configure quiet hours to prevent notifications during specific times.
17 Cookies and Tracking Technologies
Our website uses cookies and similar technologies:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential | Authentication, security, load balancing | Session |
| Functional | Preferences, settings, language | 1 year |
| Analytics | Usage patterns (anonymized) | 90 days |
Managing Cookies:
- Browser settings: Block or delete cookies
- Mobile app: No cookies (uses secure tokens instead)
- Industry opt-out: DAA Opt-Out (US) | Your Online Choices (EU)
18 Commercial Electronic Messages (CASL Compliance)
In compliance with Canada’s Anti-Spam Legislation (CASL), we will only send you commercial electronic messages (such as marketing emails or promotional push notifications) with your express consent or where we have implied consent based on an existing business relationship.
Each commercial electronic message we send will:
- Clearly identify Strategy Trader Inc. as the sender
- Include our physical mailing address
- Provide a clear and easy-to-use unsubscribe mechanism
We will process unsubscribe requests within 10 business days as required by CASL.
19 Data Breach Notification
In accordance with PIPEDA, if we become aware of a breach of security safeguards involving your personal information that creates a real risk of significant harm to you, we will:
- Notify the Office of the Privacy Commissioner of Canada as soon as feasible
- Notify you directly as soon as feasible, providing information about the breach and steps you can take to protect yourself
- Notify any other organizations or government institutions that may be able to reduce the risk of harm
We maintain records of all breaches of security safeguards for a minimum of 24 months as required by law.
20 Children’s Privacy
Our Services are not intended for individuals under the age of 18. Trading involves significant financial risk and is not suitable for minors. We do not knowingly collect personal information from children under 18.
If we become aware that we have collected personal information from a minor, we will take steps to delete that information as soon as possible. If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected].
21 Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:
- Update the “Last Updated” date at the top of this policy
- Notify you through the Services, by email, or by other appropriate means
- Obtain your consent where required by law
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
22 Challenging Compliance
You have the right to challenge our compliance with this Privacy Policy and applicable privacy laws:
- Contact us first: Please contact our Privacy Officer at [email protected]. We will investigate your complaint and respond within 30 days.
- Office of the Privacy Commissioner of Canada: If you are not satisfied with our response, you may file a complaint:
- Website: www.priv.gc.ca
- Toll-free: 1-800-282-1376
- EU Supervisory Authority: EEA residents may lodge a complaint with their local data protection authority.
- California Attorney General: California residents may contact the CA Attorney General at oag.ca.gov.
23 Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
162 Oakdale Ave
St. Catharines, Ontario L2P 2K9, Canada
Privacy Officer: Omid Mohamad Beigi
Privacy Inquiries: [email protected]
General Support: [email protected]
Phone: +1 (365) 323-4477
Website: https://strategytrader.ai
