PortfolioTA — Privacy Policy
PortfolioTA.com — Owned and operated by Trade Confident LLC
Document: privacy
Version: 2026-08-20

portfoliota.com/privacy — What we collect, why we collect it, and the choices you have.

## 1. Who we are and what this covers
Trade Confident LLC (“Trade Confident,” “we,” “us,” “our”), a California limited liability company, operates PortfolioTA.com (the “Website”). This policy explains what personal information we collect, why, who we share it with, and what rights you have.
Contact: privacy@portfoliota.com · 418 Broadway St., Chico, CA 95928

## 2.1 Information you give us
Payments. We use Paddle.com Market Limited (“Paddle”) as our merchant of record and payment processor. When you subscribe, Paddle collects and processes your payment information directly. We never receive or store your full card number. Paddle acts as an independent controller of the personal data it collects for payment processing, fraud prevention and tax compliance. Paddle’s privacy notice is at paddle.com/legal/privacy.
What we share with Paddle: your name, email address, billing address and country, transaction and subscription details, and IP address and device information used for fraud screening and tax determination.
International transfers. Paddle may process this data outside the United States. Those transfers are covered by appropriate safeguards, including Standard Contractual Clauses where required.
- Account — name, email address, password (stored hashed). Why: create and secure your account.
- Position data — asset names and symbols, entry prices, quantities, fees, dates, notes, price levels you set. Why: the core of the service — used to calculate your break-even, cost basis and profit and loss, and to draw them on your charts. Your position data is never used to compute any indicator or model — those are calculated from public market price data only.
- Chart annotations and preferences — drawing objects you place, including horizontal lines, trendlines, rectangles, Fibonacci levels and risk-to-reward measurements, together with their price levels, timeframes and any labels, plus indicator settings, watchlists, alert thresholds and display settings. Why: operate the features you have turned on, and keep your charts as you left them when you return. Stored with your account, and included in any access, export or deletion request you make.
- Billing — name, billing address, subscription plan and status, transaction history, payment processor customer identifier. Why: process payments, meet tax and accounting obligations.
- Support — messages you send us. Why: respond to you.

## 2.2 Information collected automatically
IP address, approximate location derived from IP address, browser and device information, pages and features accessed, login and access timestamps, referring website, and cookie identifiers — used for security, fraud prevention, debugging and understanding which features are used.

## 2.2b Google sign-in
If you create an account using Continue with Google, we receive your name, email address and profile picture from Google in order to create and identify your account.
We do not receive your Google password, and we do not access your Gmail, Drive, Contacts, Calendar or any other Google service. The sign-in exchange is carried out on our behalf by the application and authentication platform listed in Section 5, which receives the same name, email address and profile picture solely in order to create and secure your account. We use this information only to create your account, sign you in and contact you about your subscription — never for advertising, and we do not share it. You can revoke our access at any time from your Google Account permissions page at myaccount.google.com/permissions, and you can delete your account with us at any time from account settings.

## 2.3 What we deliberately do NOT collect
- We do not connect to your brokerage, exchange or bank accounts. All position data is entered by you manually. We never ask for and never need account credentials or API keys.
- We do not collect precise geolocation.
- We do not collect government identifiers, biometric data or health data.
- We do not collect information about your investment goals, risk tolerance, time horizon, income, net worth or personal financial circumstances, and the Website does not generate output tailored to any such information.
- We do not place advertising or social media tracking pixels on any page that displays your positions, portfolio or profit and loss.

## 3. Information you must never submit
Do not submit wallet private keys or seed phrases; exchange, brokerage or online banking passwords; payment card numbers; Social Security or tax identification numbers; government identification documents; authentication codes; or exchange, brokerage or wallet API keys of any kind, including read-only keys.
We will never ask for any of these. If you submit sensitive information unnecessarily, we cannot guarantee it will be identified or removed immediately.

## 4. How we use your information
We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
We do not use your position data to generate recommendations, and we do not sell, license or share aggregated position data with third parties as a market-sentiment or analytics product.
- To provide the Website: calculate your break-even, cost basis and P&L from the positions you enter, render your charts, and send alerts you configured. Indicators and models are computed from public market price data and do not use your position data
- To authenticate you and secure your account
- To process payments and manage your subscription
- To send service messages: renewal notices, price change notices, cancellation confirmations, security alerts and material changes to these policies
- To respond to support requests
- To detect and prevent fraud, abuse and security incidents
- To understand aggregate feature usage and improve the product
- To comply with legal obligations, defend claims, and respond to payment disputes

## 5. Who we share it with
Each service provider is bound by a written agreement limiting its use of your information to providing services to us.
- Paddle — merchant of record, payment processing, invoicing, tax calculation and fraud prevention
- Our hosting and CDN provider — website and database hosting, backups, bot protection
- Our application and authentication platform — hosting the Website, creating and securing your account, and handling sign-in, including the exchange with Google if you use Google sign-in
- Twelve Data — market data supply. We do not send them your personal or position information — we request price data for symbols.
- Our email delivery provider — transactional email and notifications
- Our analytics provider, where enabled — aggregate product usage measurement
- Our customer support tool — handling your requests
- Professional advisers — legal, accounting, as needed
- Authorities — where legally required, in response to valid legal process
- An acquirer — in a merger, acquisition, financing or sale of assets, subject to this policy

## 6. How long we keep it
You can delete your account and your position data at any time from account settings.
Some information may remain temporarily in backups and logs for the periods above.
- Account and position data — for the life of your account, then 30 days after deletion, then permanently deleted
- Billing and transaction records — 7 years, required for tax and accounting
- Consent records (auto-renewal, terms acceptance) — 4 years, needed to demonstrate compliance
- Support correspondence — 2 years
- Server and security logs — 90 days
- Backups — purged on the normal rotation, 30 days, set to match the deletion window above

## 7. Security
We use encryption in transit (TLS) and at rest, access controls, least-privilege internal access, multi-factor authentication on administrative accounts, and regular dependency patching.
No system is perfectly secure. We treat portfolio data as high-sensitivity regardless of its legal classification. If a breach affecting your personal information occurs, we will notify you and any required regulator within the timeframes the law requires.

## 8. Cookies and tracking
We honour Global Privacy Control (GPC) and other recognised universal opt-out preference signals. We request consent before setting non-essential cookies.
- Strictly necessary — login session, security, load balancing. Can you turn it off? No — the Website will not work without them.
- Preferences — remembering chart and display settings. Can you turn it off? Yes.
- Analytics — aggregate usage measurement. Can you turn it off? Yes.

## 9. Your rights — everyone
Access · Correction · Deletion · Export (a portable copy of your position data) · Opt out of marketing email at any time via the unsubscribe link. Service messages about billing and security cannot be opted out of while you hold an account.
Exercise any of these from account settings, or email privacy@portfoliota.com. We will acknowledge your request within 10 business days and respond substantively within 45 calendar days, after verifying your identity.
We work Monday to Friday, excluding United States federal holidays, and a “business day” in this policy means a day that is not a Saturday, Sunday or federal holiday. Deadlines expressed in calendar days are not affected by that — they run continuously, including over weekends and holidays, and we plan for them accordingly.

## 10.1 California (CCPA/CPRA)
Categories of personal information we collect: identifiers (name, email, IP address); commercial information (subscription and transaction records); financial information (the position data you enter); internet or network activity (usage data).
Sensitive personal information: we do not collect sensitive personal information as defined by Cal. Civ. Code §1798.140(ae). We do not collect account credentials, precise geolocation, government identifiers, biometric, health, racial or ethnic data.
Payment and transaction data — your name, email, billing address and country, transaction and subscription records, and the IP and device information used for fraud screening and tax determination — is disclosed to our merchant of record, Paddle, for the business purposes of processing payments, preventing fraud and meeting tax obligations. It is disclosed under a written contract that limits its use to those purposes.
We do not sell or share personal information as those terms are defined by the CCPA, and have not done so in the preceding 12 months. That includes payment and transaction data disclosed to Paddle.
You have the right to know, delete, correct, obtain a portable copy, opt out of sale or sharing, and to non-discrimination for exercising these rights. You may use an authorised agent.

## 10.2 Other US states
If you reside in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Indiana, Tennessee, New Jersey, New Hampshire, Nebraska, Minnesota, Maryland, Rhode Island, Kentucky or another state with a comprehensive privacy law, you have substantially similar rights, including the right to appeal a denied request.
To appeal, email privacy@portfoliota.com with “Privacy Appeal” in the subject line. We will acknowledge within 2 business days and respond within the period your state’s law requires — which is counted in calendar days and is not extended by weekends or holidays. If we deny the appeal, we will tell you how to contact your state Attorney General.

## 11. EU and UK residents (GDPR)
Lawful bases: performance of a contract (providing the Website); legitimate interests (security, fraud prevention, product improvement); consent (marketing and non-essential cookies); legal obligation (tax and accounting records).
Your rights: access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and the right to lodge a complaint with your supervisory authority.
International transfers: your information is processed in the United States under Standard Contractual Clauses where required.
Your position data is not a “special category” of personal data under Article 9.
Representatives. PortfolioTA.com is operated from the United States and is not directed at individuals in the European Union or the United Kingdom. We have not appointed an Article 27 representative. We nevertheless honour the rights described above for any user who is entitled to them — write to privacy@portfoliota.com.

## 12. Children
The Website is not intended for anyone under 18, and we do not knowingly collect information from children. If you believe a child has provided us information, contact privacy@portfoliota.com and we will delete it.

## 13. Third-party links
The Website may link to or integrate with third-party services. We are not responsible for their privacy practices. Review their policies before providing information.

## 14. Changes
We will post updates here with a revised “Last Updated” date. For material changes we will notify you by email or in-app notice at least 30 days in advance.

## 15. Contact
Trade Confident LLC · 418 Broadway St., Chico, CA 95928 · privacy@portfoliota.com
PortfolioTA.com is owned and operated by Trade Confident LLC. PortfolioTA is an informational and educational tool and is not investment advice.