Privacy Policy

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

We do not store complete payment card numbers. Payments are processed by Stripe, which handles card data directly under its own terms and PCI obligations.

• 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 preferences — drawing objects, indicator settings, watchlists, alert thresholds, display settings. Why: operate the features you have turned on.
• 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.

2.3 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.

• Stripe — payment processing and subscription billing
• Our hosting and CDN provider — website and database hosting, backups, bot protection
• 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.

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.

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.