Introduction
This Privacy Policy explains how tradeSteward, LLC ("tradeSteward," "we," "us," or "our") collects, uses, retains, shares, and protects information in connection with the tradeSteward website and services (collectively, the "Service"). It applies to individuals who visit our website, create an account, or link a brokerage account to the Service.
This Privacy Policy supplements, and is incorporated into, our Terms of Service. Capitalized terms not defined here have the meaning given to them in the Terms of Service. If there is any conflict between this Privacy Policy and the Terms of Service regarding the treatment of your data, the provision that is more protective of your data ownership rights controls. By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.
Your Data Belongs to You; Our Role as Custodian
Your data is yours. All data relating to your account and any linked brokerage accounts remains your property and will not be used by the Service for any reason not directed by you.
tradeSteward is a custodian of this data and is not the owner of it. We hold and process your data only to provide the Service to you and only as you direct. Because we act solely as a custodian, and notwithstanding anything to the contrary elsewhere, tradeSteward will not be liable for the loss of any account data of which we are a custodian. We nonetheless take reasonable measures, described in Section 7, to protect that data.
Information We Collect
3.1 Information You Provide to Us
When you register for and use the Service, we collect information you provide directly, including:
Contact information. A valid email address and phone number, which you agree to provide and keep current in your Account Settings so that we can contact you about issues with your account or the Service.
Account credentials. The credentials used to secure your account, including a high-security password and, if you enroll, two-factor authentication information (see Section 7). You agree not to share your account credentials with anyone for any reason.
Subscription and billing information. Information necessary to establish and maintain your paid subscription.
3.2 Information From Your Linked Brokerage Accounts
When you link a brokerage account to the Service, we periodically record data from your linked accounts, including your account balances, account positions, account transactions, and other related data. This brokerage data is an integral part of the functionality of the Service. As stated in Section 2, this data remains your property, and we hold it only as your custodian.
3.3 Information Collected Automatically
When you visit our public website, we and our website tools may automatically collect limited technical information about your visit, such as your IP address, browser type, device and operating system information, referring pages, and pages viewed, through cookies and similar technologies.
This automatically collected website-usage information is separate from, and does not include, your account data or linked brokerage data described in Sections 3.1 and 3.2. You can control cookies through your browser settings; disabling cookies may affect how parts of the website function.
How We Use Your Information
We use your information only to operate, provide, maintain, and support the Service, and only as directed by you. Specifically, we use it to:
create, authenticate, and secure your account;
retrieve and display your linked brokerage balances, positions, transactions, and related data so the Service can function;
provide, maintain, and improve the features you use;
contact you about issues with your account or the Service, including security notices; and
administer your subscription.
We do not use data relating to your account or linked brokerage accounts for any purpose you have not directed.
How We Share and Disclose Your Information
We do not share your data with others for their own purposes. We will make your data available only in the limited circumstances described below.
5.1 Service Providers Acting as Our Agents
We may make your data available to service providers that act solely as our agents (for example, providers of cloud hosting, data storage, and similar infrastructure necessary to operate the Service). These service providers process your data only on our behalf and on our instructions, and only to the extent necessary to provide the Service to you. They are bound by contractual obligations of confidentiality, may use your data solely to perform services for us, and are not permitted to use, disclose, sell, or retain your data for their own purposes. Because these providers operate as our agents rather than as independent recipients, making your data available to them for these limited purposes is not a sharing of your data with "others."
5.2 Legal Process
We will disclose your data where we are compelled to do so by a valid court order or other legally binding legal process. If we are served with such a court order or legal process seeking your data, you will be notified upon the disclosure, except to the extent we are legally prohibited from notifying you.
5.3 Servicing Your Account
We will disclose your data where disclosure is made in accordance with the agreements between you, your broker, and us that are necessary to service your account. You will be notified upon any such disclosure.
Apart from the circumstances described in this Section 5, we will never share your data with others.We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
Data Retention and Deletion
We retain your data for as long as your account and subscription remain active so that we can provide the Service.
After the conclusion of your paid subscription period, the Service will continue to maintain your data for thirty (30) days. After that thirty-day period, your data is subject to being deleted at any time and may not be recoverable after that time. If you would like your data deleted sooner, or have questions about deletion, contact us at support@tradesteward.com.
Data Security
We take reasonable measures to protect your data. The Service requires high-security passwords and offers two-factor authentication using our preferred method (an RFC-6238 HMAC-compliant one-time-password system) or via a random code sent to your registered email address.
Protecting your account also depends on you. You are responsible for keeping your credentials confidential and for enrolling in the security protections we make available. If you decline available protections such as two-factor authentication, you have affirmatively decided not to take all available measures to secure your account.
No method of transmission or storage is completely secure. Consistent with our role as custodian described in Section 2, the Service and its content are provided "as is" and "as available," and we cannot guarantee absolute security of your data.
Third-Party Content and Links
The Service uses data from your brokerage and brokerage account, and such data is an integral part of the Service's functionality. We make no warranties, express or implied, about the validity, accuracy, timeliness, or any other characteristic of that data.
Market data that appears on our website or within the Service remains the property of the respective data providers and may not be exported, scraped, shared, or used for any purpose beyond making your personal investment decisions.
The Service may contain links to third-party websites or services that we do not operate or control. This Privacy Policy does not apply to those third parties, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.
Children's Privacy
The Service is intended for adults and is not directed to children. We do not knowingly collect personal information from anyone under the age of 18. If you believe a minor has provided us with personal information, please contact us at support@tradesteward.com and we will take appropriate steps to delete it.
Your California Privacy Rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, provides you with certain rights regarding your personal information, subject to exceptions:
the right to know the categories and specific pieces of personal information we have collected about you;
the right to request deletion of your personal information;
the right to correct inaccurate personal information;
the right to opt out of the sale or sharing of your personal information; and
the right not to receive discriminatory treatment for exercising these rights.
We do not sell your personal information and do not share it for cross-context behavioral advertising. To exercise any of these rights, contact us at support@tradesteward.com. We will verify your request before responding, and you may use an authorized agent to submit a request on your behalf.
Other Privacy Notices Other U.S. state privacy rights. Residents of other U.S. states that have enacted comprehensive privacy laws may have similar rights to access, correct, delete, or obtain a copy of their personal information. To exercise any such rights, contact us at support@tradesteward.com.
International users. The Service is operated in the United States and is intended for users in the United States. If you access the Service from outside the United States, you understand that your information will be processed and stored in the United States, where data-protection laws may differ from those in your jurisdiction.
"Do Not Track." Some browsers offer a "Do Not Track" ("DNT") signal. Because there is no common industry standard for interpreting DNT signals, our website does not currently respond to them. You can still control cookies through your browser settings as described in Section 3.3.
Governing Law
Any dispute arising from this Privacy Policy and your use of the Service will be governed by and construed and enforced in accordance with the laws of the State of Delaware, consistent with our Terms of Service.
How We Contact You and Changes to This Policy
We contact you using the email address and phone number in your Account Settings, for example to alert you to issues with your account or the Service, and to notify you upon any disclosure described in Section 5. Please keep that contact information current.
We may update this Privacy Policy from time to time. When we do, we will revise the "Revised Date" above and, where appropriate, notify you. Your continued use of the Service after an update takes effect constitutes your acknowledgement of the revised Privacy Policy.
Contact Us
If you have questions about this Privacy Policy or how we handle your data, contact us at: