Privacy Policy

#1. Scope of This Policy

This Policy applies to information we collect through the Service, including our website, web application, public journal and leaderboard pages, in-app support chat, EA software, and related communications. It does not apply to third-party websites or services that we do not own or control (such as your broker, trading platform, prop firm, or payment provider), even if linked from or connected to the Service; those are governed by their own policies.

#2. Information We Collect

Depending on the features you use, we collect:

• Account information: your name, email address, password (handled by our authentication provider in hashed, non-reversible form), profile photo (if you upload one or sign in with Google), the display name you set in your profile, your subscription plan (Essential, Pro or Ultra), and account settings such as theme and notification preferences
• Security information: multi-factor authentication settings, a random device identifier stored in your browser together with the list of devices signed in to your account (used to enforce the device limit), sign-in timestamps, and verification tokens
• Journal content: trades and everything you record about them (instrument, direction, prices, size, P&L, result, times, session, setup and entry model, strategy confluences, emotions, rule adherence, mistakes, narrative, lessons, post-trade review, trade notes), tags, screenshots and images (including ones you paste from your clipboard), playbooks, strategies, Notebook notes, daily notes, session preps and game plans, HTF analysis images, pre-session checklists, day-view mood notes, backtesting and replay sessions, and certificates you generate
• Broker and platform data: if you connect a trading account, the platform type, broker server, account number or login, account currency, balance and equity snapshots, open positions, and trade history imported from that account; if you use the EA, the EA key issued to your account and the trade data the EA sends; and if you import a file, the contents of that report
• Broker credentials: for MT5 / MT4 Direct Connect, the account number, investor (read-only) password, and server you enter; for other platforms, the login details or authorisation tokens needed to connect (for cTrader, OAuth access and refresh tokens). See Section 7 for how these are handled
• Auto-sync tokens: your token balance, purchases, usage events, and sync mode (Daily or Live)
• ETW AI data: the messages you send to ETW AI, the journal context we include with them, AI responses, images you attach, and — if you use voice input — short audio recordings of your speech and their transcripts
• Plan usage data: counters we keep on your account so each plan's limits work — the number of ETW AI conversations started each day, the trades you opened in Trade Replay each month (by trade reference), the backtesting sessions you created in the current billing month, and which of your independent journal accounts are within your plan's limit
• Backtesting backup (Ultra): if you are on Ultra, a compressed copy of your backtesting workspace — sessions, simulated trades, drawings, backtesting notes, chart settings, and progress — so it can be restored on another device or after your browser data is cleared. These are simulated trades, not real account data
• Journal Score, rank & competition data: your monthly Journal Score and its components, rank tier, number of journaled trades, time zone, rank-up history, and journaling-activity records (such as which days you journaled and which journal features you used), stored per month; and, if you join Monthly Winners, your public leaderboard profile (display name, profile photo, opt-in status), your published monthly score entry, and any prize-claim and verification information you provide (for example, identity details requested by us or the prize sponsor)
• Mentor & community data: mentor/student connections, invite codes, and messages exchanged in Mentor Mode; public journal and shared playbook links you create
• Referral information: your personal referral code; if you joined through someone's referral link or code, which code was used, which account it belongs to, and when; for referrals you make, each referred friend's sign-up date, the plan and billing cycle they purchased, the related payment references and status (including refunds or chargebacks), and the bonus days you earned, saved, used, or had reversed. See Section 10
• Billing information: our payment processors (Gumroad and, for some payments, Pesapal) collect and process payment details on our behalf — we do not receive or store your full card number or payment credentials, only transaction and order references, plan or product purchased (including token packs and tips), amount, currency, and status
• Support communications: messages you send via in-app support chat or email, including attachments you choose to share
• Notifications: if you allow push notifications, a push token for your browser or device; and a record of in-app notifications, announcements, and guided-tour progress (for example, whether you have finished or skipped the app guide)
• Usage & device data: browser type and version, device type, operating system, screen size, general feature usage, page views within the app, timestamps, error logs, and approximate location derived from IP address, used to secure, operate, and improve the Service

We do not intentionally collect special categories of personal data. Please do not include health, identity-document, or financial-account details (other than what a broker connection requires) in your notes, screenshots, or AI messages.

#3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and personalise ETW Journal — including your dashboard, calendar, Day View, reports, strategies, and greeting you by your chosen display name
• Import, sync, de-duplicate, and display trades from connected accounts, the EA, and imported files, and meter and bill auto-sync token usage
• Calculate your Journal Score and Journal Rank each month, show rank-up celebrations, and run the Monthly Winners competition — including ranking participants, publishing results, contacting winners, verifying eligibility and genuine entries, and arranging prizes with the prize sponsor
• Power ETW AI features, such as answering your questions, analysing your journal, detecting recurring tag and behaviour patterns, generating coaching notes, market briefings, notifications, and transcribing voice input — based on your own data
• Run the Refer & Earn program — recording who referred whom, confirming that a referred friend is a new customer, calculating, applying, saving, and reversing bonus days, and preventing self-referrals and other program abuse
• Show the guided app tour, competition announcements, and other in-app and push notifications
• Authenticate you, enforce the device limit and plan restrictions, secure your account, and detect and prevent fraud, abuse, and competition manipulation
• Process payments, manage subscriptions, upgrades, token packs, and tips, and administer billing, renewals, and refunds
• Enable sharing features you choose to use, such as your public journal, shared playbooks, leaderboard profile, and Mentor Mode
• Respond to support requests and communicate service-related updates, including billing, renewal, token, and prize notices
• Maintain, troubleshoot, debug, and improve the Service, including understanding which features are used
• Comply with legal, tax, and accounting obligations

We do not use your trading data for advertising or behavioural profiling for third parties, and we do not sell it. We do not use your journal content, screenshots, notes, broker data, AI conversations, or voice recordings to train our own or third-party AI models.

#4. Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area or United Kingdom, we process your personal data on the basis of: performance of our contract with you (providing the paid Service, syncing accounts you connect, providing AI features you use, calculating your score); our legitimate interests (securing the Service, enforcing device and plan limits, preventing fraud and competition manipulation, improving the Service); your consent (joining the public leaderboard and Monthly Winners, connecting a broker account, push notifications, microphone access for voice input, and optional communications — each of which you can withdraw); and compliance with legal obligations (tax, accounting, and prize-related records).

#5. How We Share Your Information

We do not sell your personal data. We share information only with the following recipients, and only as necessary:

• Sub-processors that host, store, or process data on our behalf, including AI and broker-connection providers (see Section 16)
• Your broker or trading platform, to the extent needed to authenticate and read your account when you connect it
• Our payment processors, to process subscriptions, token packs, and tips
• The public and other users, but only for content you choose to make public: your public journal and shared playbooks (to anyone with the link), your leaderboard profile and published monthly results (on the public Monthly Winners page and in the app), and journal data you share with a mentor or student you connect with
• The person who referred you, if you signed up through a referral link or code — limited to a masked version of your email address (for example, "j•••@gmail.com"), the date you joined, whether you have subscribed, the plan and billing cycle you chose, whether a payment was refunded, and the bonus days they earned from it. Your trades, journal content, payment details, and full email address are never shared with them (see Section 10)
• The prize sponsor (a prop firm), for Monthly Winners prize winners only — your name, email, and the details the sponsor needs to open your funded account, after you accept the prize
• Professional advisers (such as accountants or lawyers), where necessary and subject to confidentiality obligations
• Law enforcement, regulators, or other parties where required by law, legal process, or to protect the rights, property, or safety of ETW, our users, or the public
• A successor entity, in the event of a merger, acquisition, or sale of assets, subject to this Policy continuing to apply to your data

#6. Payment Processing

Every subscription, token-pack purchase, and tip is processed by a third-party payment processor — currently Gumroad (which acts as merchant of record and may collect sales tax or VAT) and, for some payments or regions, Pesapal. The processor collects the payment details needed to complete your transaction (such as card, mobile-money, or PayPal details, depending on the method) and handles checkout and receipts under its own privacy policy. We receive only confirmation of payment status, the plan or product purchased, the amount and currency, your account identifier passed through checkout, and a transaction or order reference, which we use to activate and manage your subscription or credit your tokens. A pending order reference may be kept temporarily in your browser so a payment can be confirmed if checkout is interrupted.

#7. Broker Connections & Credentials

Connecting a trading account is optional. When you connect one:

• For MT5 / MT4 Direct Connect (Pro and Ultra), the account number, investor password, and server you enter are sent over an encrypted connection to our backend and passed to our connection provider, MetaApi, which logs in to your account on our behalf to read history and positions. Please use your investor (read-only) password, which cannot place trades or withdraw funds. Credentials are not stored in your browser and are not visible to other users
• For cTrader, you sign in on cTrader's own page and we receive OAuth tokens rather than your password; these tokens are stored in a private area of our database that cannot be read from the app by anyone, including you, and are used only by our backend
• For TradeLocker and DXtrade, the login details you enter are sent to our backend to establish a session with the platform for reading your history, and may be stored securely on our backend only while the connection is active
• For the ETW EA, the EA runs on your own terminal and sends your trade history to our backend using your personal EA key; it does not send your trading password
• For file imports, the report you upload is read to create trades in your journal

You can disconnect an account at any time from the Brokers page; we then stop syncing and ask our connection provider to remove the account from its service. Imported trades remain in your journal until you delete them. Running out of auto-sync tokens also disconnects the account automatically.

#8. ETW AI & Voice Input

When you use ETW AI, your message and the parts of your journal relevant to it (for example recent trades, tags, notes, and statistics) are sent through our backend to our AI provider, Groq, which runs the language and speech-to-text models, and the response is returned to you. Some coaching analyses are processed by our own AI service hosted on Render. Our AI provider processes this data under its own terms to generate the response; we do not use your data to train AI models. Voice input only starts when you press the microphone or start a live voice session and grant microphone permission; the recording is sent for transcription and we use it only to produce the transcript. Voice input and live voice sessions are available on the Ultra plan. To apply each plan's daily ETW AI allowance, we keep a count of the conversations you start each day (not their content) on your account; the count resets daily. Spoken replies are produced by your own device's built-in speech engine. Recent AI conversations and insights may be kept in your account or browser so you can continue where you left off; they are deleted with your account.

#9. Journal Score, Monthly Winners & What Is Public

• Your Journal Score and rank are calculated in the app from your own journal. A monthly summary (score, tier, number of journaled trades, time zone, and activity totals) is saved to your account, and rank-up history is kept so we do not repeat celebrations
• Nothing about you is public unless you opt in. If you join Monthly Winners by creating a public leaderboard profile, your display name, profile photo (or an initial if you have none), rank tier, monthly score, journaled-trade count, and placing become visible on the public Monthly Winners page and inside the app. Your trades, notes, screenshots, P&L, and account balances are never shown on the leaderboard
• Monthly results are kept and may remain visible after the month ends as a record of past winners. If you turn your public profile off, you are removed from future leaderboards and your current-month entry is hidden, but results already published for closed months may remain
• To verify a potential winner, we may review that person's journal entries for the competition month and ask for identity and eligibility information. Verification information is used only for the competition and prize, shared with the prize sponsor only as described in Section 5, and kept only as long as needed for legal and accounting purposes

#10. Refer & Earn Referral Program

If you take part in the Refer & Earn program described in Section 16 of our Terms of Service, either by inviting others or by signing up through someone's referral link or code:

• Referral links. When you open a referral link, the referral code in it is saved in your browser's local storage until you sign in, so that it can be linked to your account. It is then removed from your browser. We do not use referral links to track you across other websites
• Linking a referral. When the code is applied, we record on our servers which referrer's code was used, the referrer's and your account identifiers, and the date. To keep the program fair, we check that you are not already a customer and not the referrer, including by comparing a normalised form of the email addresses on both accounts
• Rewarding a referral. When your payment is confirmed by our payment provider, we use the plan, billing cycle, order reference, and the email address on the payment to calculate the referrer's reward and confirm the purchase was not made by the referrer. If the payment is later refunded or reversed, we record that and adjust the reward
• What the referrer sees. The referrer sees only a masked version of your email address, the date you joined, your subscription status, the plan and billing cycle you chose, and the bonus days they earned. They never see your name, full email, trades, journal content, account balances, or payment details
• What you see as a referrer. You see the same limited, masked information for each person you invited, together with your code, link, and reward totals
• Retention. Referral records are kept while either account involved remains open, and afterwards for as long as needed to handle refunds, chargebacks, fraud prevention, and accounting. If you delete your account, the referral record is deleted or anonymised, except for the minimum needed for those purposes; the other party will see the referral only in anonymised form
• Legal basis. For EEA/UK users, we process referral information to perform our contract with participants (awarding the rewards promised in the Program Rules) and on the basis of our legitimate interest in preventing fraud and abuse of the program

#11. Data Storage, Hosting & Security

Your account and journal data are stored in Google Firebase (Authentication and Cloud Firestore), with encryption in transit (TLS) and at rest. Screenshots and images are stored via Cloudinary. The app is hosted on Netlify, and our backend services (broker sync, AI proxy, payment verification) run on Render. Access to your data is restricted to your own account by server-side security rules — no other user can read your trades, notes, or personal information unless you choose to share them through a public link, the leaderboard, or a mentor connection. Our security rules also validate competition score entries, keep broker tokens in a private area clients cannot read, and protect token balances and billing records from being changed from the app. We use Firebase App Check to help confirm that requests come from our genuine app, offer multi-factor authentication, and limit the number of devices signed in to an account. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

#12. Google Sign-In

When you sign in with Google, we receive your name, email address, and profile photo from Google's OAuth service. We do not receive or store your Google password. Google's own Privacy Policy governs how Google handles your data.

#13. Cookies, Local Storage, Device Permissions & Do Not Track

ETW Journal uses essential authentication tokens and your browser's local storage to keep you signed in and to remember things such as your theme, sidebar layout, last page viewed, device identifier, display name for your account on that device, notification and announcement status, a referral code from a referral link you opened (until it is applied to your account), app-guide progress, chat-panel state, your backtesting sessions and settings, which independent journal account you are using, and cached app files for offline use (if you install the app). Backtesting data is kept in your browser; we ask the browser to keep it persistently, and on Ultra it is also backed up to our servers as described in Section 2. Inside the ETW Journal app we do not use advertising cookies, third-party ad trackers, or cross-site tracking pixels. Embedded charts provided by TradingView may set their own cookies under TradingView's policy. The app asks for device permissions only when a feature needs them — the microphone for voice input, notifications for push alerts, and the clipboard when you press "Paste screenshot" — and you can refuse or revoke these at any time in your browser settings. We do not currently respond differently to browser "Do Not Track" signals.

Advertising on our blog. Our public blog pages (the blog index and individual articles) display ads served by Google AdSense. Ads are not shown inside the ETW Journal app or on our homepage, sign-in, account, or payment pages. On blog pages, third-party vendors, including Google, use cookies to serve ads based on your prior visits to this website or other websites. Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to our site and/or other sites on the Internet. You may opt out of personalised advertising by visiting Google's Ads Settings, and you can opt out of some third-party vendors' use of cookies for personalised advertising at www.aboutads.info. To learn more about how Google uses information from sites that use its services, see How Google uses information from sites or apps that use our services. Where required by law (for example, for visitors in the European Economic Area, the United Kingdom, and Switzerland), we ask for your consent before personalised ads are shown, and you can change your choice at any time. Ad cookies set on blog pages are not linked to your ETW Journal account, and we never share your journal or trading data with advertisers.

#14. Data Retention

Your journal and account data are kept for as long as your account remains active, or as needed to provide the Service. If your subscription lapses or is cancelled, we may keep your data for a reasonable period in case you resubscribe, after which it may be deleted or anonymised. Referral records are kept as described in Section 10. Broker credentials and tokens are kept only while the account is connected and are removed when you disconnect. Voice recordings are not kept after transcription. Plan usage counters are kept only for the period they apply to (a day or a month) plus a short buffer. The Ultra backtesting backup is replaced each time it is updated, is kept while your account exists so it can be restored if you return to Ultra, and is deleted with your account. Device records are cleared after a long period of inactivity. Published Monthly Winners results are kept as a historical record of the competition. If you request account deletion, we will delete or anonymise your personal data within a reasonable timeframe, except where we must keep certain records (such as billing, token-purchase, and prize records) for legal, tax, or accounting purposes, which we keep for the period required by law.

#15. Your Privacy Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data (you can also edit most of your data directly in the app)
• Request deletion of your account and associated personal data ("right to be forgotten")
• Request a portable copy of your data in a structured, commonly used format
• Object to or restrict certain processing of your data
• Withdraw consent at any time — for example by turning off your public leaderboard profile, disconnecting a broker, revoking microphone or notification permission, or unpublishing your public journal — without affecting the lawfulness of processing before withdrawal
• Lodge a complaint with your local data protection authority

To exercise these rights, contact us at supportetwjournal@gmail.com or through our in-app support chat. We will respond within a reasonable timeframe and may need to verify your identity before actioning certain requests. Exercising these rights is free of charge, except where a request is manifestly unfounded or excessive.

#16. Third-Party Services & Sub-Processors

ETW Journal works with the following third parties, each governed by its own privacy policy:

• Google Firebase — authentication, database (Cloud Firestore), App Check, push notifications (Firebase Cloud Messaging), and transactional email (e.g., verification and password-reset emails)
• Cloudinary — storage and processing of screenshots and images
• Netlify — website and application hosting
• Render — hosting of our backend services for broker sync, AI requests, and payment verification
• Groq — AI language-model and speech-to-text processing for ETW AI
• MetaApi — connection to MetaTrader 4/5 accounts for Direct Connect
• cTrader, TradeLocker, and DXtrade — the trading platforms you choose to connect
• TradingView — embedded price charts in replay and related views
• Google AdSense — display of ads on our public blog pages only, as described in Section 13
• Gumroad and Pesapal — payment processing for subscriptions, token packs, and tips
• The Monthly Winners prize sponsor (a prop firm) — for prize winners only, as described in Section 5

We may add or change sub-processors as our infrastructure evolves; where required by law, we will update this Policy to reflect material changes.

#17. International Data Transfers

Our providers may process and store data in countries other than your own, including the United States and the European Union. Where required, we rely on appropriate safeguards, such as standard contractual clauses or equivalent mechanisms recognised under applicable data-protection law, to protect data transferred internationally.

#18. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended, including the right to know what personal information we collect, the right to request deletion and correction, and the right to non-discrimination for exercising your privacy rights. We do not sell or "share" personal information as those terms are defined under the CCPA, and we do not use sensitive personal information to infer characteristics about you. You can exercise these rights using the contact details in Section 15.

#19. Children's Privacy

ETW Journal is not intended for, and may not be used by, individuals under 18 years of age, and minors may not take part in Monthly Winners. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly and close the associated account.

#20. Automated Processing & Decision-Making

ETW AI analyses your own trade, tag, and note data to surface patterns and generate insights, briefings, and notifications; these outputs are informational only and apply solely to your account. Your Journal Score and rank are calculated automatically from your journal, and Monthly Winners placings are determined automatically from eligible participants' scores using the published ranking order. Because these placings can affect whether you receive a prize, every potential winner's result may be reviewed by a person before a prize is awarded, and you may contact us to ask for a review of your score or placing. Automated processing is never used to decide your access to the Service or the price you pay.

#21. Data Breach Notification

In the event of a security incident that compromises your personal data, we will investigate promptly, take reasonable steps to contain and remediate the incident (including disconnecting affected broker connections where appropriate), and notify affected users and, where legally required, relevant supervisory authorities, without undue delay and in accordance with applicable law.

#22. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, the Service, or legal requirements. We will indicate the effective date of the latest revision above and, where changes are material, notify users via the platform or email. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.

#23. Contact Us

Questions about your privacy or this Policy? Reach us at supportetwjournal@gmail.com or through our in-app support chat.