Privacy Policy

Last updated: April 2026

TradingPlan Ltd. ("Company", "we", "us", "our") is committed to protecting your privacy. This policy explains what personal information we collect, why we collect it, how we use it, and your rights in relation to it.

This policy applies to our website at tradingplan.io (the "Website") and our mobile and desktop application TradingPlan (the "App"). Please read it carefully. If you do not agree with any part, please discontinue use of our Services.

1. What Data We Collect

We collect the minimum personal information necessary to provide our Services:

• Authentication identifier — when you sign in using Sign In With Apple, Apple provides us with a unique user identifier and, where you have chosen to share it, your email address (or an Apple-generated relay address). We use this solely to identify your account.
• Support communications — if you contact us for help, we retain those communications to provide support and improve our Service.

We do not collect, store, or have access to the contents of your trading plan. All trading plan data — your strategies, rules, routines, risk parameters, and notes — is stored exclusively on your device and synced via your personal iCloud account. It never passes through our servers.

2. Sign In With Apple

TradingPlan uses Sign In With Apple as its only authentication method. This means:

• Your account is tied to your Apple ID, not a TradingPlan-managed password.
• Apple may share your name and email address (or a private relay address) with us at sign-in. We use this only to identify your account and communicate with you if needed.
• We never see your Apple ID password.
• Apple's handling of your credentials and authentication data is governed by Apple's Privacy Policy.

3. Your Trading Plan Data and iCloud

All content you create in TradingPlan — your trading strategies, rules, risk framework, routines, mindset notes, and plan data — is stored in iCloud's private database, associated with your Apple ID. TradingPlan Ltd. has no access to this data at any time.

Because this data is managed through iCloud, Apple's privacy practices apply to its storage and sync. We encourage you to review Apple's Privacy Policy for further information.

You can delete all your App data at any time by uninstalling TradingPlan and removing its data from iCloud (Settings → [your name] → iCloud → Manage Account Storage).

4. App Analytics and Tracking

The TradingPlan app contains no analytics, tracking, or third-party SDKs. We do not monitor how you use the app, which features you access, or how long you use it. Your in-app behaviour is entirely private.

5. Website Analytics

Our website uses Google Analytics to understand how visitors use it. This data is anonymised and used only to improve the website. No analytics cookies are set until you give your explicit consent via the cookie banner.

Google Analytics data is processed by Google LLC, which is based in the United States. Google uses Standard Contractual Clauses (SCCs) approved by the European Commission as the lawful mechanism for transferring data from the UK and EEA to the US. For more information, see Google's Privacy Policy.

The cookies used are:

• _ga — Google Analytics. Distinguishes users. Expires after 2 years.
• _ga_* — Google Analytics. Persists session state. Expires after 2 years.

We do not use advertising cookies, tracking pixels, or third-party marketing cookies. If you decline cookies, the site functions normally and no analytics data is collected.

6. How We Use Your Data

We use the personal information we hold for the following purposes:

• To authenticate your account and provide access to the App
• To respond to support requests you send us
• To send you service-related communications (e.g. important updates to these terms)
• To improve our Website using anonymised analytics data (only with your consent)

We will never sell, rent, or share your personal information with third parties for marketing purposes.

7. Legal Basis for Processing

We are a UK-based company and are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where we process the personal data of individuals in the European Economic Area (EEA), we also comply with the EU General Data Protection Regulation (EU GDPR).

Our legal bases for processing are:

• Contract performance — processing your authentication identifier is necessary to provide you with the App.
• Legitimate interests — retaining support communications to maintain and improve the Service, where this does not override your rights.
• Consent — setting analytics cookies on the Website, which you can withdraw at any time.

8. International Data Transfers

Our Website uses Google Analytics, which transfers data to Google's servers in the United States. This transfer is made under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for your data.

Your App data is stored in iCloud and is subject to Apple's data transfer and storage practices. See Apple's Privacy Policy for details.

We do not otherwise transfer your personal data outside the UK or EEA.

9. Your Rights

Under UK GDPR and EU GDPR, you have the following rights regarding your personal data:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate data
• Right to erasure — to request deletion of your personal data
• Right to restrict processing — to ask us to limit how we use your data
• Right to object — to object to processing based on legitimate interests
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to withdraw consent — for any processing based on consent (e.g. analytics cookies), at any time

To exercise any of these rights, contact us at hello@tradingplan.io. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). If you are based in the EEA, you may contact your local data protection authority.

10. California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you the following additional rights:

• Right to know — to request disclosure of the categories and specific pieces of personal information we collect, use, and disclose
• Right to delete — to request deletion of your personal information, subject to certain exceptions
• Right to opt out of sale — we do not sell your personal information to any third party, and we never will
• Right to non-discrimination — we will not discriminate against you for exercising any of your CCPA rights

To exercise your California rights, contact us at hello@tradingplan.io.

11. Data Retention

We retain your authentication identifier for as long as you have an active account. Support communications are retained for a reasonable period to help us maintain and improve the Service. You may request deletion of your data at any time by contacting hello@tradingplan.io.

Website analytics data is retained in accordance with Google Analytics' standard retention settings.

12. Account Deletion

You can request deletion of your account and all associated personal data at any time by contacting us at hello@tradingplan.io. We will process your request promptly.

Your trading plan data is stored in your own iCloud account and can be removed independently at any time by uninstalling the App and managing your iCloud storage.

13. Customer Support

If you contact us for support, you may share personal information such as your email address and device details. We use this solely to respond to and resolve your request. We do not use support communications for marketing purposes.

14. Children

TradingPlan is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, contact us and we will delete it promptly.

15. Changes to This Policy

We reserve the right to update this policy at any time. Where changes are material, we will provide notice by email or via a notice on our website. Your continued use of the Services after changes take effect constitutes acceptance of the revised policy.

16. Contact

TradingPlan Ltd. is the data controller responsible for your personal data under UK GDPR.

For any questions, concerns, or requests relating to this Privacy Policy or your data, please contact us at hello@tradingplan.io.