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Privacy at Tracom
This Privacy Policy explains how Tobistech Ltd (Company No. 16037879), operating as Tracom Trading Journal ("we," "us," "our"), collects, uses, shares, and protects your personal information. We are committed to protecting your privacy and complying with global data protection laws including GDPR, UK GDPR, CCPA, and other applicable regulations.
🔒 We NEVER sell your personal data. Your trading information is yours alone.
1. Data Controller
Tobistech Ltd is the data controller responsible for your personal data processed through Tracom.
Registered Office: 82 King Street, Manchester, England, M2 4WQ
Company Number: 16037879
ICO Registration: [To be provided if registered]
Contact: support@tobistech.co.uk
Data Protection Officer: dpo@tobistech.co.uk
2. Information We Collect
2.1 Account Information
Required Information:
Optional Information:
2.2 Trading Journal Data
2.3 Payment & Subscription Data
Note: We use Stripe for payment processing. We do NOT store credit card numbers.
2.4 Technical & Usage Data
2.5 Social Login Data (If Used)
If you sign in using social providers, we receive:
3. How We Use Your Information
| Purpose | Legal Basis (GDPR) |
|---|---|
| Provide trading journal services | Contract performance |
| Process payments and subscriptions | Contract performance |
| Send service notifications | Contract performance |
| Customer support | Legitimate interest |
| Marketing communications | Consent |
| Improve app features | Legitimate interest |
| Security and fraud prevention | Legal obligation |
| Comply with legal requirements | Legal obligation |
Important: We NEVER use your trading data for our own trading purposes or share it with third parties for trading purposes. Your strategies and trades remain confidential.
4. How We Share Your Information
🔒 We NEVER sell, rent, or trade your personal information.
We only share your data in these limited circumstances:
4.1 Service Providers
Stripe
Payment processing (PCI-DSS compliant)
AWS (Amazon Web Services)
Cloud hosting and data storage (Virginia, USA)
SendGrid/Email Provider
Transactional emails and notifications
Analytics Providers
App performance and usage analytics (anonymized)
4.2 Your Public Sharing
When you choose to share journals publicly or with subscribers, that content becomes visible to those users. You control what to share.
4.3 Legal Requirements
We may disclose data when required by law, such as:
- • Court orders or legal processes
- • Protection of our legal rights
- • Prevention of fraud or security threats
- • Protection of public safety
5. Your Privacy Rights
Depending on your location, you have specific rights regarding your personal data:
🇪🇺 European Union & UK (GDPR/UK GDPR)
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate information
- Erasure: Request deletion ("right to be forgotten")
- Portability: Receive data in machine-readable format
- Restriction: Limit processing of your data
- Object: Opt-out of certain processing
- Withdraw Consent: Any time for consent-based processing
Supervisory Authority: You may lodge a complaint with the UK ICO (ico.org.uk) or your local data protection authority.
🇺🇸 California (CCPA/CPRA)
- Know: What personal information we collect and how we use it
- Delete: Request deletion of your personal information
- Opt-Out: We don't sell data, but you can opt-out of sharing
- Non-Discrimination: Equal service regardless of privacy choices
- Correct: Update inaccurate personal information
- Limit: Restrict use of sensitive personal information
How to Exercise Your Rights
Contact us at:
- 📧 Email: privacy@tobistech.co.uk
- 📱 In-App: Settings → Privacy → Request Data
- ⏱️ Response Time: Within 30 days
We may verify your identity for security purposes before processing requests.
6. How We Protect Your Data
We implement industry-standard security measures to protect your personal information:
Technical Measures
- • 256-bit SSL/TLS encryption
- • Encrypted database storage
- • Secure AWS infrastructure
- • Regular security audits
Operational Measures
- • Access controls & authentication
- • Regular backups
- • Incident response procedures
- • Staff training & NDAs
Note: While we use best practices, no internet transmission is 100% secure. Please use strong passwords and protect your account credentials.
7. International Data Transfers
Your data may be transferred and processed internationally:
Primary Data Location:
🇺🇸 United States (AWS Virginia) - Main servers
🇬🇧 United Kingdom - Company headquarters
Safeguards for International Transfers:
- • Standard Contractual Clauses (SCCs) for EU-US transfers
- • UK International Data Transfer Agreement (IDTA)
- • Appropriate technical and organizational measures
- • Data Processing Agreements with all processors
By using Tracom, you consent to the transfer of your data as described above, with appropriate safeguards in place.
9. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Account information | Until account deletion + 30 days |
| Trading journals | Until you delete them |
| Payment records | 7 years (legal requirement) |
| Support communications | 2 years |
| Security logs | 1 year |
| Marketing preferences | Until withdrawn |
Account Deletion: You can request account deletion anytime. We'll delete your data within 30 days, except where legal retention is required.
10. Children's Privacy
Age Restriction: Tracom is NOT for users under 18 years old.
We do not knowingly collect data from minors. If we discover a user is under 18, we will immediately:
- • Terminate the account
- • Delete all associated data
- • Notify the user if possible
If you believe a minor is using Tracom, please contact us immediately at safety@tobistech.co.uk
11. California Privacy Rights (CCPA)
Categories of Information We Collect:
- • Identifiers (name, email, IP address)
- • Commercial information (subscription history)
- • Internet activity (app usage)
- • Geolocation data (country/region)
- • Professional information (trading data)
Your California Rights:
- ✅ We DO NOT sell personal information
- ✅ We DO NOT share data for cross-context behavioral advertising
- ✅ You can request data deletion anytime
- ✅ You can access your data via app settings
To exercise your rights, email: privacy@tobistech.co.uk with "California Privacy Rights" in the subject.
12. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements.
When we make changes:
- • Update the "Last Updated" date
- • Notify you via email for material changes
- • Post in-app notifications
- • Request new consent if required
Continued use after changes means you accept the updated policy.
13. Contact Us
For privacy questions, requests, or concerns:
Data Protection Officer
📧 dpo@tobistech.co.uk
For formal data protection inquiries
General Privacy Inquiries
📧 privacy@tobistech.co.uk
For general privacy questions
Postal Address
Tobistech Ltd
82 King Street
Manchester, England, M2 4WQ
United Kingdom
Response Times
⏱️ General inquiries: 5 business days
⏱️ Data requests: 30 days (as required by law)
⏱️ Urgent security issues: 24 hours
Supervisory Authorities
If you're not satisfied with our response, you may contact:
🇬🇧 United Kingdom
Information Commissioner's Office (ICO)
ico.org.uk
🇪🇺 European Union
Your local data protection authority
edpb.europa.eu