TradeWinds Privacy Policy

Effective Date: October 12, 2026

Last Updated: October 21, 2026

1. Introduction

TradeWinds (“TradeWinds,” “we,” “us,” or “our”) is a financial market sentiment and social networking application developed and operated by Armada Trading Technologies LLC (“Company”).

This Privacy Policy describes how we collect, use, store, disclose, and protect personal information when you use the TradeWinds mobile application, associated websites, APIs, and related services (collectively, the “Services”).

We are committed to protecting user privacy while providing a platform for sharing financial market opinions, analyzing market sentiment, and evaluating historical prediction performance.

By using TradeWinds, you acknowledge the data practices described in this Privacy Policy. Where required by law, we will obtain your consent before processing personal information.

Data Controller: Armada Trading Technologies LLC

Privacy Contact: [email protected]

Website: https://tradewinds-app.com

2. Information We Collect

We collect information necessary to operate, maintain, secure, and improve TradeWinds.

2.1 Account and Profile Information

When creating or maintaining an account, we may collect:

• Email address and username.
• Display name and optional profile information.
• Authentication credentials, or authentication identifiers supplied by third-party sign-in providers.
• Account creation dates, preferences, and settings.
• Subscription or account access status, where applicable.

Email/password authentication is handled by Supabase Auth, which stores password hashes rather than plaintext passwords. When you use Apple or Google sign-in, we receive authentication identifiers and the account information the provider makes available, not your Apple or Google password. Session tokens are used to keep you signed in and authorize requests. Your email address, password, password hash, and authentication tokens are not displayed to other TradeWinds users and are never included in data products or redistributed for others’ independent use.

2.2 Market Predictions and User-Generated Content

TradeWinds allows users to express opinions about publicly traded securities and interact with other users.

We may collect and store:

• Bullish or bearish stock predictions.
• Securities or ticker symbols associated with predictions.
• Prediction timestamps and selected prediction horizons.
• Historical prediction outcomes, accuracy statistics, and performance metrics.
• User-selected watchlists and market preferences.
• Profile visibility, friend requests, accepted friendships, follows, group memberships, invitations, and shared group watchlists.
• Analysis layouts and indicator settings.
• Backtest results, including simulated performance statistics.
• Virtual coin rewards, spending, and community-data unlock records.

Prediction records may be associated with a user account to calculate historical accuracy, display user activity, and provide platform functionality.

Your watchlist, historical performance, and analysis layout are private by default and shared with accepted friends. Broader access requires you to choose Public visibility. Basic social identity and shared group activity have the limited exceptions explained in Section 5.1. Private-account predictions still contribute to anonymous community sentiment; private visibility does not exclude predictions from these calculations.

2.3 Technical and Usage Information

When you use the Services, we may collect technical information such as:

• Device type, operating system, and app version.
• IP address and approximate location inferred from network information.
• Application activity, feature usage, and request timestamps.
• Error reports, crash diagnostics, and performance measurements.
• Security and authentication logs.

We use this information to operate the Services, troubleshoot problems, prevent abuse, maintain security, and improve reliability.

We do not collect precise device location unless a feature explicitly requires it and the user grants the necessary permission.

2.4 Communications and Feedback

When you contact us, report a problem, or participate in beta testing, we may collect correspondence, feedback, bug reports, and related diagnostic information.

2.5 TestFlight Beta Testing

Apple automatically collects crash and usage information through TestFlight and shares it with us. This can include device and operating-system details, build versions, sessions, and crashes. Email invitations may also disclose your name and invitation email; joining through a public link alone does not disclose those details to us through TestFlight. Creating a TradeWinds account is a separate collection of account information.

Feedback you choose to submit may contain comments, screenshots, and contact details. Avoid including passwords or unnecessary personal information. We use TestFlight-provided information to improve TradeWinds and related products, and do not share that information with third parties or include it in commercial prediction datasets. Apple’s rules for this information take precedence over the general sharing provisions below.

TestFlight diagnostic collection cannot be disabled while participating. You can stop testing and uninstall the beta; this does not automatically delete your TradeWinds account or previously collected information. Apple handles its own processing under TestFlight & Privacy and its TestFlight terms.

2.6 Website Waitlist

If you join the website waitlist, we collect your email, consent record, submission time, and signup source to send launch and early-access updates. Cloudflare hosts the website, stores the waitlist, and provides Turnstile verification against automated abuse. The verification service processes network information including your IP address; the waitlist database does not intentionally store that IP address. Contact [email protected] to withdraw from the waitlist or request deletion. Waitlist details are not sold, licensed, or used for unrelated marketing.

2.7 Payments and Subscriptions

If TradeWinds introduces paid subscriptions or purchases, we may receive transaction identifiers, purchase status, subscription status, and other information necessary to provide purchased services.

TestFlight participation and digital test purchases are free; test transaction records may still be processed.

Payments processed through Apple or another payment provider are subject to that provider’s privacy practices. We do not require access to full payment card details when payments are handled entirely by an external payment processor.

3. How We Use Information

We use collected information for the following purposes:

Providing the Services

• Creating and authenticating user accounts.
• Recording and displaying market predictions.
• Calculating prediction outcomes and historical accuracy.
• Supporting social networking features.
• Personalizing market information and application layouts.
• Maintaining watchlists and user preferences.

Improving the Services

• Diagnosing technical problems and software errors.
• Understanding application usage and performance.
• Improving interface design and product functionality.
• Developing and validating sentiment analytics and statistical models.

Security and Administration

• Preventing unauthorized access, fraud, spam, and abuse.
• Enforcing applicable terms and community rules.
• Responding to support requests.
• Complying with applicable legal obligations.

Aggregated Market Sentiment Analytics

We may analyze user-generated market predictions to produce statistical datasets, aggregate sentiment indicators, historical trend analyses, and related commercial analytics.

Only prediction-derived information may be used in externally distributed analytics, subject to Section 4. Account, security, support, and website information is used to operate the Services as described here, not as a commercial data product.

4. Aggregated Data and Commercial Use

A central function of TradeWinds is the aggregation and analysis of user-generated financial market sentiment.

We may create aggregate indicators and analytical products derived from user predictions, such as:

• The percentage of bullish and bearish predictions for a security.
• Changes in sentiment over time.
• Aggregate prediction accuracy.
• Sentiment measures across user groups or performance categories.
• Historical and statistical sentiment datasets.

Only prediction data and analytics derived from predictions may be redistributed or licensed as data products. These may include stock symbols, bullish/bearish direction, horizons, outcomes, and statistical summaries, but only in genuinely anonymous forms that do not identify or reasonably permit identification of individual users. This applies to predictions from both Private and Public accounts. Making a profile Public does not authorize sale or licensing of that user’s identity.

We do not sell, rent, license, or redistribute personal account information for recipients’ independent commercial use. In particular, emails, passwords, password hashes, authentication tokens, usernames, account or device identifiers, friend relationships, watchlists, analysis layouts, individual backtest records, support messages, and TestFlight diagnostics or feedback are excluded from prediction data products. We do not provide personal information to data brokers or for third-party advertising.

Before any external release, we must assess reidentification risk, remove identifying links, and aggregate, generalize, or suppress records where necessary, including small groups and precise timestamps. Merely replacing a name with a user ID is pseudonymization, not anonymity. Information that remains reasonably linkable to a person remains personal information and is not eligible for redistribution under this policy.

Any commercial distribution is subject to applicable law and Apple agreements; this policy does not itself authorize a use those rules prohibit. Necessary processing by service providers, user-directed social visibility, and legally required disclosures are distinct from commercial data redistribution and are explained in Section 5.

5. Sharing of Personal Information

We may disclose information in the following circumstances.

5.1 Other TradeWinds Users

Private by default. New accounts use Private data visibility. Your personal watchlist, historical prediction performance, and analysis layout are available to you and your accepted friends. A pending friend request, following relationship alone, or shared group membership does not grant access to these private details.

Public only by your choice. In Profile → Account, choose Edit, turn on Public data visibility, and save to make these details accessible to other TradeWinds users, including through applicable discovery and leaderboard features. You can switch back to Private and save at any time. This withdraws access for non-friends and removes their follows; removing a friend withdraws that person’s access while your account is Private. It cannot retrieve screenshots or copies someone already made while authorized to view your information.

Limited social identity remains discoverable. Private does not make your account invisible: your username, app user identifier, visibility and relationship status may appear in search, friend requests, or basic profile views so people can find and connect with you. Group members can see shared group information, membership, and contributions to shared group watchlists. Group performance calculations respect the viewer’s access to individual members. Choose a username that does not disclose information you want to keep confidential.

Credentials stay private. Neither friends nor other users receive your email address, password, password hash, or authentication tokens through these social features, even when your profile is Public. Do not put your email or other sensitive information in your username or shared group content.

Anonymous consensus is separate. Private-account predictions still contribute to anonymous community sentiment and prediction-derived statistics. Profile visibility controls access to identifiable profile details, not inclusion in anonymous statistical results described in Section 4.

5.2 Service Providers

We may use third-party providers for:

• Cloud hosting and data storage.
• Authentication and account management.
• Database, caching, and background processing infrastructure.
• Application diagnostics and performance monitoring.
• Email delivery and customer support.
• Payment processing and subscription administration.

Supabase provides account authentication; Apple and Google process sign-in when you select those options; Cloudflare provides website hosting, waitlist storage, and anti-abuse verification. Other infrastructure providers process service data needed to host and operate TradeWinds. Authentication providers necessarily process credentials or tokens for login; this is not publication or commercial redistribution of your credentials.

We require providers processing personal information on our behalf to limit its use to the services they provide and to give it protection equal to that promised in this policy and required by applicable Apple rules, including appropriate confidentiality, security, retention, and deletion obligations. This paragraph does not permit onward disclosure of TestFlight-provided data contrary to Section 2.5.

5.3 Analytics Customers

Only genuinely anonymous prediction data and prediction-derived analytics meeting Section 4 may be provided to analytics customers. Identifiable or merely pseudonymized user records are not supplied as commercial datasets.

5.4 Legal and Business Requirements

We may disclose information when reasonably necessary to comply with legal obligations, respond to valid legal requests, protect the security of our Services, or protect the rights of users and the Company.

If the business undergoes a merger, acquisition, restructuring, or transfer of assets, information necessary for continued operation of the Services may be transferred subject to applicable privacy laws, Apple restrictions, and continued protection under this policy. Such a transfer does not authorize the recipient to sell personal account information or include it in analytics products. Material changes require notice and, where required, fresh consent.

6. Legal Bases for Processing

Where the European Union or United Kingdom data protection frameworks apply, we process personal information based on one or more applicable legal grounds.

Where processing is based on consent, users may withdraw that consent through available privacy controls or by contacting us.

Withdrawal of consent does not affect the lawfulness of processing performed before withdrawal.

Where processing relies on legitimate interests, we assess those interests against the rights and freedoms of affected individuals.

7. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, subject to legal and operational requirements.

In general:

• Account information: Retained while needed for an active account. Deletion disables the account, removes social records, settings, and personal watchlists, replaces the stored email, removes the username and sign-in identity link, and queues deletion of the Supabase authentication account. Authentication cleanup may take additional time and is retried on failure.
• Prediction, backtest, and audit records: Historical records may be retained after deletion for statistical integrity, research, security, and transaction auditing. They may retain an internal account identifier. Removal of an email or username does not by itself make them anonymous; any linkable records remain protected personal information, subject to applicable deletion rights and a justified retention basis. Internal retention does not authorize commercial redistribution of backtests or account records.
• Security and operational logs: Retained for a limited period appropriate to security, troubleshooting, and legal requirements.
• Support correspondence and TestFlight data: Retained only as needed for support, beta evaluation, and resolving reliability issues, subject to applicable rights and Apple restrictions.
• Waitlist records: Retained while launch communications remain active or until you withdraw or request deletion, except limited records needed to honor that request or satisfy legal obligations.
• Aggregated anonymous statistics: May be retained indefinitely where the information is no longer personal data under applicable law.

Backup copies may remain temporarily until replaced or expired under the applicable backup lifecycle. Such copies must remain restricted and must not be restored to active use without reapplying applicable deletion requests. Contact us for information about retention applicable to your records.

We will not retain personal information indefinitely solely because it may be useful for future analysis.

8. Account Deletion and User Rights

Users may request deletion of their TradeWinds account and associated personal information.

Account Deletion: Open Profile → Account → Delete account and confirm. Deletion is permanent; groups you own transfer to an eligible remaining member or are removed if empty. The data-removal and limited retention process is described in Section 7. Signing out, uninstalling, or leaving TestFlight alone does not delete your account.

Visibility: Use Profile → Account → Edit → Public data visibility → Save to choose Private or Public, and manage accepted friends in My Network.

Consent and communications: Contact [email protected] to withdraw optional consent or leave the waitlist. You may also revoke applicable device permissions in system settings. Withdrawing optional consent does not affect prior lawful processing; essential account processing and mandatory TestFlight diagnostics are explained separately above.

Users may also contact us at [email protected] to submit privacy-related requests.

Depending on applicable law, users may have the right to:

• Access personal information held about them.
• Correct inaccurate or incomplete information.
• Request deletion of their personal information.
• Request a portable copy of eligible personal information.
• Object to certain processing activities.
• Restrict certain processing activities.
• Withdraw consent where processing depends on consent.
• Lodge a complaint with an appropriate data protection authority.

We may verify your identity before fulfilling a request and may retain information where required or permitted by law.

Account deletion will not necessarily remove information that has already been lawfully transformed into genuinely anonymous aggregate statistics.

We will respond to privacy rights requests within the time limits established by applicable law.

9. Data Security

We use reasonable technical and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and loss.

These safeguards may include encrypted communications, access controls, secure credential handling, authentication mechanisms, system monitoring, and restricted access to production infrastructure.

No electronic service can guarantee absolute security. Users should protect their account credentials and notify us of suspected unauthorized access.

10. International Data Transfers

TradeWinds may use infrastructure or service providers located in countries other than the country in which a user resides.

Where personal information is transferred outside the European Economic Area, United Kingdom, or other jurisdictions with international transfer restrictions, we will use an applicable lawful transfer mechanism and appropriate safeguards where required.

Such safeguards may include recognized adequacy decisions or approved contractual protections.

Users may contact us for information about applicable international data transfer safeguards.

11. Third-Party Services and Market Data

TradeWinds may display financial market information, stock news, company information, and other content obtained from third-party data providers.

These services may operate under separate privacy policies and terms.

Where providers process personal information on our behalf, the safeguards in Section 5.2 apply.

External websites accessed through TradeWinds are not controlled by us, and their privacy practices are governed by their respective policies.

12. Children’s Privacy

TradeWinds is intended for users aged 18 and older. This is TradeWinds’ eligibility rule even though TestFlight itself may permit younger testers under Apple’s terms.

We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child contrary to this policy or applicable law, we will take appropriate steps to delete that information.

13. Cookies and Similar Technologies

Our website and Services may use cookies, authentication tokens, or similar technologies to maintain user sessions, secure accounts, and support application functionality.

Where we use optional analytics, advertising, or tracking technologies that require consent, we will request permission as required by applicable law.

Users may manage applicable tracking permissions through their device settings or privacy controls made available by the Services.

14. Automated Analysis and Profiling

TradeWinds automatically evaluates historical stock predictions to calculate statistical measures such as prediction accuracy, sentiment trends, and related performance metrics.

These calculations may be used to personalize features, display historical results, and categorize market sentiment.

We do not intend these calculations to make decisions producing legal or similarly significant effects concerning individual users.

Where applicable privacy law provides rights relating to automated decision-making or profiling, those rights will be respected.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in TradeWinds features, business practices, legal requirements, or technology.

When changes are material, we will provide appropriate notice through the application, website, email, or other available communication channels. We will seek new consent before any materially different use where required; publication of a revised policy alone is not consent.

The current version will be available at:

https://tradewinds-app.com/privacy/

16. Contact Information

For questions, concerns, or requests concerning this Privacy Policy or the processing of personal information, contact:

Armada Trading Technologies LLC

Website: https://tradewinds-app.com

Email: [email protected]

Users located in the European Economic Area may also contact their relevant data protection supervisory authority, including the Commission Nationale de l’Informatique et des Libertés (CNIL) in France, where appropriate.