Privacy Policy

This Privacy Policy describes how Freeze Time Inc., a Delaware corporation doing business as PrecisionTrader ("PrecisionTrader," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you use our web-based trading platform (the "Service"). By accessing or using the Service, you consent to the data practices described in this Privacy Policy. If you do not agree, please do not use the Service.

We collect only the data necessary to operate the Service and provide you with trading workflow tools.

1. Information You Provide Directly:

• Account Information: email address, password (hashed), display name (if provided).

• Payment Information: processed by Stripe, Inc. We do NOT store full credit card numbers; Stripe handles payment data in accordance with PCI-DSS standards.

• Communications: If you contact us via email or support channels, we collect your name, email, and message content.

• PrecisionAI: If you use the PrecisionAI, we collect the messages you send, the responses generated for you, and associated session metadata (such as session title, timestamps, and linked account identifier).

2. OAuth Access Tokens:

When you authorize PrecisionTrader to access your TradeStation account via OAuth 2.0, we receive transient access and refresh tokens. We do NOT store your TradeStation username, password, or any other login credentials. Tokens are encrypted at rest and used solely to authenticate API requests on your behalf when you initiate an action (e.g., placing an order, fetching account data).

3. Automatically Collected Information:

• Usage Data: Pages visited, features used, clicks, timestamps, session duration, and feature interactions.

• Device and Browser Information: IP address, browser type and version, operating system, device type, screen resolution, and language preferences.

• Cookies and Local Storage: Session identifiers, preferences, authentication tokens, and feature settings (see "Cookies and Tracking Technologies" below).

• Log Data: Server logs, error reports, and diagnostic information (timestamps, request/response codes, API call logs).

4. Market and Trading Data:

When you use the Service, we may temporarily cache market data (quotes, charts, trade history) provided by TradeStation and third-party data vendors for display purposes. This data is NOT personal information but may be associated with your account activity.

We use the information we collect for the following purposes:

1. Provide and Operate the Service:

• Authenticate your identity and maintain your session.

• Transmit your user-initiated order instructions to TradeStation's API.

• Display real-time market data, account balances, positions, and order status.

• Enable features like trade journaling, alerts, risk controls, and performance tracking.

• Operate the PrecisionAI, including sending your prompts and relevant account context (such as trading rules configuration, recent rule violations, and journal entries) to third-party AI service providers to generate responses.

2. Process Payments and Subscriptions:

• Charge subscription fees, process refunds, and manage billing cycles via Stripe.

3. Communicate with You:

• Send account-related notifications (password resets, subscription renewals, feature updates).

• Respond to support inquiries and troubleshoot technical issues.

• Notify you of critical service outages, security incidents, or policy changes.

4. Improve and Develop the Service:

• Analyze usage patterns to identify bugs, optimize performance, improve the service, and prioritize and build new features.

• Conduct internal research and analytics (aggregated and anonymized where possible).

• Utilize aggregated, anonymized, and de-identified data for machine learning, new product offerings, marketing, or otherwise sell such data to third parties.

5. Ensure Security and Prevent Fraud:

• Monitor for suspicious activity, unauthorized access, or abuse of the Service.

• Investigate and respond to security incidents, fraudulent transactions, or violations of our Terms.

6. Comply with Legal Obligations:

• Respond to subpoenas, court orders, or lawful requests from government authorities.

• Enforce our Terms of Service and protect our legal rights.

We do NOT use your identifiable information for marketing or promotional campaigns unless you explicitly opt in.

We do NOT sell, rent, or trade your personal information to third parties for their marketing purposes.

1. Service Providers and Partners:

We share information with trusted third-party service providers who assist us in operating the Service:

• Stripe: Payment processing and subscription management.

• Hosting Providers: Cloud infrastructure and server hosting.

• Analytics Tools: Aggregated usage analytics (e.g., traffic patterns, feature adoption).

• AI Service Providers: Third-party artificial intelligence providers that process prompts and related context to operate the PrecisionAI (such as Anthropic). These providers process data on our behalf to generate responses and are subject to their privacy policies and our agreements with them.

These service providers are bound by confidentiality obligations and may only use your information to perform services on our behalf.

2. TradeStation:

When you authorize PrecisionTrader to access your TradeStation account, we transmit your OAuth access token to TradeStation's API to execute your trading instructions. TradeStation's use of your information is governed by its own privacy policy and customer agreements.

Important Disclosure: PrecisionTrader is not affiliated or associated with, or a partner of, or an agent, representative, delegate, associated person, or introducing broker for, any TradeStation company. The products and services offered by PrecisionTrader are not sponsored, endorsed, sold, or promoted by any TradeStation company, and TradeStation makes no representation regarding any products or services offered by PrecisionTrader. Equities, equity options, and commodity futures products and services are offered by TradeStation Securities, Inc. (Member NYSE, FINRA, CME and SIPC).

3. Legal Obligations:

We may disclose your information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to:

• Comply with a subpoena, court order, or lawful government request.

• Enforce our Terms of Service or investigate potential violations.

• Protect the rights, property, or safety of PrecisionTrader, our users, or the public.

4. Business Transfers:

If PrecisionTrader is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred to the successor entity. We will provide notice before your information is transferred or becomes subject to a different privacy policy.

5. With Your Consent:

We may share your information with third parties if you provide explicit consent (e.g., authorizing a third-party integration).

We use cookies, local storage, session storage, and similar browser-based storage mechanisms (collectively, "Cookies") to maintain your session, store preferences, and analyze usage patterns. What Are Cookies: Cookies are small text files placed on your device when you visit a website. They help us recognize your device, remember your preferences, and improve your browsing experience. Types of Cookies We Use:

1. Essential Cookies (Strictly Necessary):

Required for the Service to function. Without these, core features like login, order entry, and session persistence would not work. These cannot be disabled.

• Authentication tokens (session identifiers).

• CSRF (Cross-Site Request Forgery) protection tokens.

• Load balancing and routing information.

2. Functional Cookies (Preferences):

Remember your choices and preferences to provide a personalized experience.

• User interface settings (sidebar collapsed/expanded, chart time frames, indicator settings).

• Display preferences (theme, language, time zone).

• Feature toggles (e.g., risk control settings, alert preferences).

If you disable functional Cookies, some features may not work as expected, and you may need to reconfigure settings each time you visit.

3. Analytics and Performance Cookies:

Help us understand how users interact with the Service by collecting aggregated, anonymous data.

• We may use third-party analytics tools to collect this data.

• Analytics data is used solely to improve the Service, identify bugs, and prioritize new features.

You can opt out of analytics Cookies using browser settings, but this will not affect your ability to use the Service.

4. Security Cookies:

Help us detect and prevent fraudulent activity, unauthorized access, or abuse.

• Login attempt monitoring and rate limiting.

• Detection of suspicious behavior patterns.

Third-Party Cookies:

We may allow third-party service providers to place Cookies on your device:

• Stripe: Payment processing and fraud prevention.

• Hosting/CDN Providers: Content delivery and load balancing.

• Analytics Providers: Aggregated usage analytics.

These third parties have their own privacy policies. We do NOT control third-party Cookies and are not responsible for their practices.

Managing Cookies:

You can control Cookies through your browser settings:

• Chrome: Settings > Privacy and Security > Cookies and other site data.

• Firefox: Preferences > Privacy & Security > Cookies and Site Data.

• Safari: Preferences > Privacy > Manage Website Data.

• Edge: Settings > Cookies and site permissions > Manage and delete cookies.

Important: If you disable essential Cookies, you will NOT be able to use the Service. Disabling analytics Cookies may affect your experience but will not prevent core functionality.

Cookie Lifespan:

• Session Cookies: Temporary, deleted when you close your browser.

• Persistent Cookies: Remain for 30 days to 1 year for preferences, analytics, and security.

Do Not Track (DNT):

Our Service does not currently respond to "Do Not Track" signals from web browsers because there is no industry consensus on how to interpret DNT signals. We honor opt-out preferences where applicable under state privacy laws.

We take data security seriously and implement industry-standard safeguards to protect your information:

• Encryption: All data transmitted between your browser and our servers is encrypted using SSL/TLS (HTTPS).

• Token Encryption: OAuth access and refresh tokens are encrypted at rest.

• Access Controls: We limit access to personal information to authorized personnel on a need-to-know basis.

• Regular Audits: We periodically review and update our security practices.

However, no method of transmission or storage is 100% secure. While we strive to use commercially reasonable safeguards, we cannot guarantee absolute security. You are responsible for safeguarding your account credentials and using strong, unique passwords.

Account Data:

We retain your account information, OAuth tokens, and usage data as long as your account remains active and as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce our Terms.

Deletion Upon Account Closure:

If you close your account or your subscription lapses and remains inactive for 90 days, we will delete your OAuth tokens and account data, except as required for legal, tax, or regulatory purposes.

AI Chat Sessions:

PrecisionAI conversation history is stored with your account while your account remains active. You may delete individual chat sessions from within the Service. Upon account closure, we delete AI chat session data within the same timeframe as other account data, except as required for legal, tax, or regulatory purposes.

Log and Analytics Data:

Server logs, error reports, and aggregated analytics data may be retained for up to 24 months for operational and security purposes, after which they are deleted or anonymized.

Depending on your location, you may have certain rights regarding your personal information:

1. Right to Know/Access:

Request a copy of the personal information we maintain about you.

2. Right to Delete:

Request deletion of your personal information, subject to certain legal exceptions (e.g., records required for tax compliance, fraud prevention, or ongoing legal matters).

3. Right to Correction:

Request correction of inaccurate personal information. Note: This right applies to personal data we control (e.g., your email address). It does NOT permit altering executed trades, order history, profit/loss records, or brokerage data maintained by TradeStation.

4. Right to Opt-Out of Sale:

We do NOT sell your personal information, so there is no need to opt out of sales.

5. Right to Non-Discrimination:

We will not discriminate against you for exercising your privacy rights.

6. State-Specific Rights:

• California (CCPA/CPRA): California residents have additional rights under the California Consumer Privacy Act. See "California-Specific Disclosures" below.

• Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA): Residents of these states have similar rights to access, delete, correct, and opt out of certain data processing activities.

To exercise your rights, email us at legal@precisiontrader.tech. We may need to verify your identity before fulfilling your request. We will respond within 45 days (or as required by applicable law).

Categories of Personal Information Collected (Last 12 Months):

• Identifiers: email, IP address, device ID.

• Commercial Information: subscription records, payment history.

• Internet Activity: Interaction with the Service.

• Professional Information: trading activity, account data (from TradeStation).

Categories of Sources:

Directly from you, automatically via cookies/logs, and from TradeStation (via OAuth authorization).

Business Purposes for Use:

Provide the Service, process payments, improve features, ensure security, and comply with legal obligations.

Categories of Third Parties We Share With:

Service providers (Stripe, hosting), TradeStation (for order execution), legal authorities (when required).

If you are a California resident, you may exercise the following rights under the CCPA:

• The right of access means that you have the right to request that we disclose what personal information we have collected and maintained about you in the past 12 months.

• The right of deletion means that you have the right to request that we delete personal information, subject to certain exceptions.

• The right of correction means that you have the right to request that we correct any inaccurate personal information.

• The right to request information concerning the categories of personal information (if any) that we disclose to third parties or affiliates for their direct marketing purposes.

Right to Opt-Out of "Sale" or "Sharing":

We do NOT sell personal information or share it for cross-context behavioral advertising.

Right to Limit Use of Sensitive Personal Information:

We do NOT collect or use sensitive personal information (e.g., Social Security numbers, biometric data, precise geolocation, health data, financial account credentials).

• The right to appeal means that you can appeal any decision by us to deny your privacy rights under applicable laws.

• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

Retention:

Account data is retained while the account is active; logs are retained for up to 24 months.

California residents may submit requests via legal@precisiontrader.tech or designate an authorized agent to act on their behalf.

The Service is NOT directed to individuals under the age of 18. We do NOT knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13, we will promptly delete it. If you believe a child has provided us with personal information, please contact us at legal@precisiontrader.tech.

PrecisionTrader is based in the United States, and the Service is intended for U.S. residents. If you access the Service from outside the United States, your information will be transferred to, processed, and stored in the United States, where data protection laws may differ from those in your jurisdiction. By using the Service, you consent to the transfer and processing of your information in the United States.

The Service may contain links to third-party websites, tools, or services (e.g., TradeStation, Stripe) that are not operated by PrecisionTrader. We are NOT responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party services you use.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or Service features. The "Last Updated" date at the top of this policy indicates when the latest changes were made. If we make material changes that reduce your privacy rights, we will provide notice via email or an in-app notification at least 30 days before the changes take effect. Your continued use of the Service after the effective date constitutes acceptance of the updated Privacy Policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: Email: legal@precisiontrader.tech; For California-specific requests under CCPA/CPRA, use the email above and include "CCPA Request" in the subject line.