Privacy Policy

Last Updated: December 25, 2025

1. Who We Are & Scope

Trade Tactics Algo Limited ("Signal Swap," "we," "us") operates a non-custodial automation and signals Platform. This Policy explains what we collect, why, how we share, how long we keep it, your rights, and how to contact us. It applies to Users, Creators, and visitors.

2. Data We Collect

2.1 Account & Identity

Email, display name/handle, password hash, auth tokens, optional phone/SMS for security/alerts; age attestation (18+), country/region for geofencing/sanctions screening.

Identity Verification (KYC) Data: If required by law (FinCEN MSB obligations, MiCA, state licensing) or risk assessment, we collect:

• Government ID: Driver's license, passport, national ID (scanned image + extracted data: name, DOB, ID number, expiry, issuing authority)
• Selfie/Liveness: Photo or video to verify you match the ID
• Proof of Address: Utility bill, bank statement (address, date, issuer)
• Tax ID: SSN (U.S.), NI Number (UK), etc.
• Enhanced Due Diligence (EDD): Source of funds, occupation, expected trading volume, beneficial ownership (if entity account)

KYC Providers: We use Jumio, Onfido, Persona, or similar to verify identity. They process your ID images and biometric data under their privacy policies and data processing agreements with us. KYC data is encrypted and stored separately from general account data.

Retention: KYC data retained for 5 years after account closure per AML/CTF record-keeping requirements (FinCEN, FATF guidance).

2.2 Platform & Device Usage

App events, IP, device/browser/OS, language, time zone, referral data, crash logs, session telemetry.

Geolocation & Sanctions Screening: Your IP address is matched against:

• Geolocation databases: MaxMind GeoIP2, IP2Location (to determine country/region)
• Sanctions lists: OFAC SDN, EU Consolidated List, UK HM Treasury (to block prohibited users)
• VPN/Proxy detection: Databases of known data center IPs, Tor exit nodes

We retain geolocation data (country, region, city) for compliance audits. Raw IP addresses are retained per Section 8 (Performance, Logs, and Retention).

Session Recordings & Heatmaps: We use Microsoft Clarity (a third-party analytics service) to record anonymized user sessions, including:

• Mouse movements, clicks, scrolls
• Page views and navigation paths
• Form interactions (we mask sensitive fields like passwords and API keys)
• Device/browser information, screen resolution

Clarity helps us understand how users interact with the Platform to improve usability. Session recordings are anonymized (no PII like names/emails visible) and retained by Microsoft per their retention policies.

Clarity Privacy: Microsoft Clarity operates under Microsoft's Privacy Statement: https://privacy.microsoft.com/privacystatement

Real-Time Data Streaming (WebSockets): The Platform uses WebSocket connections to stream real-time data to your browser/app:

• Live price updates (market data from exchanges)
• Order status changes (submitted → filled/rejected)
• Position updates (open positions, PnL)
• Bot status alerts (started, stopped, errors)

WebSocket Session Data:

• Connection logs (timestamp, duration, IP address)
• Message frequency and payload sizes (for capacity planning and abuse detection)
• Disconnection reasons (network errors, server restarts, user logout)

WebSocket sessions are ephemeral; data is not stored long-term except in aggregated telemetry metrics. Connection logs retained for 30 days for troubleshooting.

Third-Party WebSocket Services: We may use third-party WebSocket infrastructure providers (e.g., AWS API Gateway WebSockets, Pusher, Ably) operating under data processing agreements. Real-time market data is sourced from exchange APIs or licensed data providers.

2.3 Trading Configuration & Activity

Bot settings, risk caps, allowed symbols/leverage, connected venues (names only).

• Crypto auto-execution: order requests we submit, acknowledgements, rejections, fills, and proof bundles (signal id, inputs, user risk hash, venue snapshot, order payload, acks/fills, timings).
• Securities signals-only: delivered signals and your subscription choices; no order transmission by us.

2.4 API Credentials (Crypto)

Exchange API key identifiers and encrypted API secrets for read/trade scopes only (no withdrawals). We keep scope metadata and last validation timestamp.

2.5 Payments & Payouts

Subscription status, invoices, and limited card/payment tokens via the payment processor; Creator payout preferences via the payout processor.

Creator Tax Information (U.S.):

• W-9 Form Data: Legal name, SSN or EIN, business type, address (for U.S. Creators)
• W-8 Form Data: Foreign tax identification numbers, treaty claims (for non-U.S. Creators)
• Payout Records: Amounts, dates, payment methods, tax withholding (if applicable)

IRS Reporting: We report Creator earnings to the IRS via Form 1099-K or 1099-NEC where required (U.S. Creators earning $600+ annually). Tax data retained per IRS record-keeping rules (minimum 4 years).

2.6 Communications

Support tickets, emails, in-app messages, notification preferences, and Creator–Subscriber messaging metadata (message content only if necessary for abuse review).

2.7 Creator Verification (Optional)

If a Creator opts in, read-only broker/exchange credentials/tokens and associated fill/position data for verification only (no trading permissions accepted for verification).

2.8 Referrals & Affiliate Data

Referral codes/IDs, partner IDs, affiliate links/cookies, and attribution metadata to administer the Affiliate Program and apply User benefits. We do not add extra exchange/broker fees to Users because of the referral.

Affiliate Payout Data:

• PayPal email / bank account details (for commission payments)
• Tax information: W-9 form data (name, SSN/EIN, address) for U.S. affiliates earning $600+
• Commission history, payout records, referral performance metrics

Tax Reporting: We report affiliate earnings to the IRS via Form 1099-NEC where required (U.S. affiliates earning $600+ annually). W-9 data is retained per IRS record-keeping requirements (minimum 4 years).

Retention: Referral tracking data retained while affiliate status is active + 4 years for tax audit purposes.

2.9 AML/KYC & Regulatory Compliance Data

Where required by law (e.g., FinCEN MSB obligations, state money transmitter laws), we may collect:

• Identity verification data: Government-issued ID, Social Security Number (SSN) or Tax Identification Number (TIN), date of birth, residential address
• Enhanced Due Diligence (EDD): For high-risk users or large transaction volumes, source of funds, beneficial ownership, occupation, expected activity
• Sanctions screening results: OFAC SDN list checks, EU/UK sanctions, UN sanctions
• Transaction monitoring data: Patterns, velocity, counterparties, amounts, timestamps for AML risk scoring

Legal Basis: FinCEN Bank Secrecy Act (BSA) compliance, state money transmitter laws, sanctions compliance (OFAC Executive Orders).

Sharing: We may share AML/KYC data with:

• FinCEN (SARs, CTRs)
• State financial regulators (licensing compliance)
• Law enforcement (subpoenas, court orders)
• Third-party KYC/AML service providers (IDology, Jumio, Chainalysis, etc.)

We practice data minimization and pseudonymization where feasible.

3. Why We Use Data (Legal Bases)

• Provide services (Contract): authenticate, route signals, submit crypto orders you instruct, generate dashboards, deliver notifications.
• Security & abuse (Legitimate Interests / Legal Obligation): detect scope drift, prevent fraud/spam, rate-limit, investigate incidents, maintain audit logs.
• Compliance (Legal Obligation): sanctions screening, lawful requests, record-keeping.
• Product improvement (Legitimate Interests): telemetry, diagnostics, aggregated analytics.
• Consent:
  • Marketing emails (where permitted): You may opt-in to receive:
    • Product updates and new feature announcements
    • Educational content (trading tips, strategy guides)
    • Promotional offers (discounts, affiliate deals)

    Unsubscribe Process:

    • Every marketing email includes an "Unsubscribe" link in the footer
    • Clicking "Unsubscribe" takes you to a preference center where you can opt-out of specific email types or all marketing emails
    • No login required to unsubscribe (link is uniquely tokenized)
    • Unsubscribe requests processed within 10 business days (CAN-SPAM compliance)

    Transactional Emails Still Sent: Even if you unsubscribe from marketing, you will still receive:

    • Account security alerts (password changes, 2FA)
    • Order confirmations and trade notifications
    • Legal/compliance notices (ToS updates, policy changes)
    • Billing and payment receipts
    • Responses to support inquiries
  • Creator verification connections
  • Cookies beyond strictly necessary
  • Affiliate attribution

4. Security

• Encryption & Isolation: envelope encryption with a managed KMS/HSM for secrets/sensitive fields; TLS in transit; least-privilege services for order routing.
• Operational Controls: 2FA, RBAC, audit logging, and background checks for staff with production access.
• Key Hygiene: withdrawal scopes rejected; periodic re-validation; IP allow-listing supported where available.

No system is 100% secure. You are responsible for your device hygiene and account security.

4.1 Internal Access Controls

Signal Swap employees with production access (DevOps, Support, Compliance) may access your data as necessary to:

• Troubleshoot technical issues you report
• Investigate security incidents or abuse
• Comply with legal obligations (subpoenas, audits)
• Perform system maintenance and monitoring

What Admins Can See:

• Account details (email, subscription tier, registration date)
• Bot configurations (strategy names, symbols, risk settings) — NOT decrypted API secrets
• Order history and execution logs (submitted orders, fills, rejections)
• Marketplace activity (subscriptions, Creator payouts, performance metrics)
• Support tickets and communications

Audit Logging: All admin access to production data is logged with timestamps, user IDs, and actions taken. Logs are retained for 1 year for security audits.

Background Checks: Employees with production access undergo background checks and sign confidentiality agreements prohibiting unauthorized disclosure of user data.

5. Where We Process & Transfers

Primary regions include the United States, Singapore, and United Arab Emirates, with additional nodes for redundancy/CDN. If you are in the EEA/UK, transfers use appropriate safeguards such as Standard Contractual Clauses (SCCs) and UK addenda where applicable.

6. How We Share

We do not sell personal information. We share only with:

• Service Providers (cloud, databases, analytics, email/notifications, payments) under appropriate data-processing terms:
  • Microsoft Corporation: Clarity analytics (session recordings, heatmaps)
  • AWS / Google Cloud / Azure: Infrastructure and data storage
  • Stripe / PayPal: Payment processing
  • SendGrid / Mailgun: Transactional and marketing emails
  • Jumio / Onfido / Persona: Identity verification (KYC)
  • Chainalysis: Blockchain analytics and sanctions screening (if applicable)
  • [Other providers as needed for platform operations]
• Exchanges/Brokers only when you connect and authorize (e.g., crypto order submission you requested; Creator verification if opted in).
• Affiliates (operations/support) under this Policy.
• Law Enforcement/Regulators where required by law or to protect rights, safety, or the Platform.
• Business Transfers (merger/acquisition) with protections and notice.

7. Cookies & Similar Tech

We use essential cookies (authentication/security) and functional cookies/SDKs (telemetry/crash reporting). No third-party ad cookies. You can control cookies in your browser; essential cookies are required for login.

Analytics & User Experience:

• Microsoft Clarity: Session replay, heatmaps, user behavior analytics. Uses cookies to identify repeat sessions. You can opt-out via browser settings or Clarity's opt-out: https://clarity.microsoft.com/opt-out

8. Performance, Logs, and Retention

• Execution/telemetry logs: retained for operations and disputes (typical 90–365 days).
• Proof bundles (crypto): Tamper-evident execution records (signal ID, inputs, risk hash, venue snapshot, payload, acks/fills, timings) retained in WORM/Object-Lock storage for 7 years to resolve disputes about order execution, exchange failures, or regulatory inquiries.
• Creator verification data: retained while verification is active; removed on disablement or key revocation, subject to audit/legal retention.
• Referral/affiliate data: retained while benefits are active and for a reasonable period afterward for accounting/compliance.
• Account data: kept while the account is active; deleted or anonymized upon verified request or closure, except where retention is required by law or for legitimate interests (e.g., fraud prevention, dispute handling).
• Legal holds: we may preserve relevant data as required.

8.1 Trade History Retention

Trade History (User-Accessible):

• Dashboard Access: Your trade history (orders submitted, fills, PnL calculations) is accessible via dashboard for 3 years from trade date.
• Download/Export: You may export trade history as CSV/JSON at any time during the accessible period. We recommend exporting annually for your tax records.
• After 3 Years: Trade history older than 3 years is archived (no longer visible in dashboard) but retained in WORM storage for 7 years total (to comply with IRS/tax authority record-keeping requirements).
• Deletion After 7 Years: Trade data older than 7 years is permanently deleted unless subject to legal hold (active litigation, audit, investigation).

Backtest Results:

• Your Backtests: Results and logs retained for 1 year from completion date, then deleted (unless you re-run the backtest, which resets the retention clock).
• Marketplace Bot Backtests: Performance data displayed on marketplace retained for 3 years or until Creator delists the bot (whichever is earlier).

Exception - Account Deletion: If you delete your account, we will:

• Immediately remove trade history from dashboard access
• Within 30 days: Delete non-archived trade data
• Retained for 7 years: Archived trade data (for tax/compliance), then permanently deleted
• Retained indefinitely: Anonymized aggregated data for fraud prevention (no personally identifiable information)

8.2 User Scripts & Pine Code Retention

User-Uploaded Scripts: Pine Scripts and trading strategies you upload for backtesting are stored encrypted on our servers while your account is active.

Anonymized Script Hash: A cryptographic hash is a one-way mathematical fingerprint of your script created using SHA-256 or similar algorithms. Key properties:

• One-Way: We cannot reverse the hash to reconstruct your original Pine Script code
• Unique: Each unique script produces a different hash; even 1-character changes create completely different hashes
• Collision-Resistant: It's computationally infeasible for two different scripts to produce the same hash

Why We Retain Hashes: After you delete a script, we may retain its hash (but not the script content) to:

• Detect duplicate submissions or plagiarism in the Marketplace
• Prevent resubmission of scripts flagged for abuse (e.g., malware, market manipulation)
• Maintain audit trails for compliance investigations

Hash Retention Period: Anonymized script hashes retained for 3 years after script deletion for fraud prevention. Cannot be used to reconstruct your code.

Specific periods may vary by region, feature, or incident-response needs.

9. Your Rights

Depending on your location (e.g., GDPR/UK GDPR, CPRA/CCPA, PIPEDA), you may have rights to access, rectify, delete, port, restrict, or object to processing, and to withdraw consent. We will not discriminate for exercising rights. Requests: support@signalswap.io. We may need to verify identity and account control.

9.1 Right to Deletion / Account Closure

How to Request:

1. Self-Service: Visit Account Settings → "Close Account" → Follow prompts
2. Email Request: Send email to support@signalswap.io from your registered email with subject "Account Deletion Request"

Identity Verification: To prevent unauthorized deletion, we may ask you to:

• Confirm via email link sent to registered address
• Provide last 4 digits of payment method on file
• Answer security questions (if account recovery is enabled)

Processing Timeline:

• Self-Service: Immediate account closure (dashboard access disabled)
• Email Request: Verified and processed within 30 days (GDPR) or 45 days (CPRA), whichever applies to your jurisdiction

What Gets Deleted: Upon verified deletion request:

• ✅ Immediately: Dashboard access disabled, bots stopped, exchange API keys disconnected
• ✅ Within 30 days: Account data (email, profile), non-archived trade history, backtest results
• ⚠️ Retained (7 years): Archived trade history (tax compliance), Creator payout records (IRS reporting), affiliate commission records (tax/audit)
• ⚠️ Retained (indefinitely): Anonymized fraud prevention data (hashed identifiers, no PII)

Exceptions to Deletion: We may retain data despite deletion request if:

• Active subscription exists (must cancel first, wait for billing cycle to end)
• Outstanding Creator/affiliate payments pending
• Active legal dispute or investigation
• Required by law (tax records, AML/KYC data, regulatory audit)

Confirmation: We will send confirmation email to your registered address once deletion is complete (within timeline above). If you don't receive confirmation, contact support@signalswap.io.

Re-Activating Closed Account: Once deleted, accounts cannot be recovered. You may create a new account, but:

• Previous trade history is not recoverable
• Marketplace subscriptions must be re-purchased
• Creator verification must be re-done

10. Children

The Platform is for individuals 18+. We do not knowingly collect data from children. If you believe a minor provided data, contact us for deletion.

11. Automated Decisions

We use automation to route signals, enforce risk caps, and protect the Platform (e.g., auto-halts on scope drift). We do not make solely automated decisions producing legal or similarly significant effects without appropriate human oversight where required by law.

12. Region-Specific Disclosures

12.1 EEA/UK

Controller: Trade Tactics Algo Limited. You may lodge a complaint with your supervisory authority. SCC copies and representative details available upon request.

12.2 California

We provide CPRA disclosures and honor applicable rights (access, deletion, correction, opt-out of "sale/share" — we do not sell personal information). Categories: identifiers, online activity, transaction metadata via processors, professional info for Creators.

12.3 Canada

We comply with PIPEDA and applicable provincial privacy laws. Contact us to access/correct information.

13. Changes

We may update this Policy. We will post the updated date and, for material changes, provide reasonable notice via Platform/email. Continued use after the effective date constitutes acceptance.

14. Contact

Trade Tactics Algo Limited

Email: support@signalswap.io

By using Signal Swap, you acknowledge that you have read and understood this Privacy Policy.