Privacy Policy

1. Scope and who we are

This policy covers the TradeCowboy desktop and mobile applications, TradeCowboy accounts and hosted features, the tradecowboy.com website and email list, and support communications (together, the Services).

TradeCowboy is operated by Diego Fernandez, an Australian sole trader (ABN 52 517 363 809) (we, us or our). Our business address is 77 Parkwood Bvd, Parkwood QLD 4214, Australia. Contact us at [email protected].

“Personal information” in this policy includes information that identifies you or can reasonably be linked to you. A wallet address, trading account identifier or device identifier may be personal information when linked to your account.

2. What is handled, and where

3. How and why we use information

We collect information directly from you, from your device when an online feature is enabled, from providers you connect, and from Apple or RevenueCat for subscription events. We use it to:

• provide, secure and troubleshoot the Services;
• authenticate accounts, enforce per-user access and prevent abuse;
• sync data and deliver cloud freshness only when those features are enabled;
• retrieve information from the exchanges, brokers and market-data providers you choose;
• perform AI and semantic-search operations you enable or request;
• administer beta access, subscriptions, renewals, restores, refunds and entitlement status;
• answer support requests and investigate security or reliability issues;
• send TradeCowboy news, product information and occasional promotional offers to email-list members, with an unsubscribe option; and
• comply with law, enforce our Terms, and protect users, the public and the Services.

If information is necessary for account authentication, billing or an online feature and you do not provide it, that feature may not work. The local desktop journal can operate without optional sync and hosted AI configuration.

4. AI features are a separate data flow

Encrypted phone sync does not mean AI inputs stay encrypted from AI providers. When you use an AI feature, TradeCowboy must send readable content needed for that request:

• Cowboy chat and related analysis: DeepSeek may receive your prompt, recent conversation, trader profile, selected journal excerpts, trade/account context, live-market context and tool results. Cowboy chat transcripts and its learned trader profile are also stored in the encrypted phone-sync mirror so the same signed-in, paired account can retain its history across supported devices.
• Journal chart attachments: a chart attached in Cowboy chat is kept as evidence for the journal entry you ask Cowboy to create or update. The chart bytes are not placed in the model prompt, conversation history, learned profile or AI-provider request. Cowboy is told only that an unseen user-supplied chart exists so the app can attach it after the journal write succeeds.
• Receipt and statement extraction and Claude-powered review: Anthropic may receive the selected image or PDF, extracted text, prompts and relevant context.
• Generated note titles: DeepSeek may receive a bounded excerpt of the note text so it can propose a short title.
• Semantic journal search: note bodies are sent to OpenAI to create embeddings when they are saved or backfilled, and search text is sent to create a query embedding. Consumer builds send these requests through our hosted AI proxy; a bring-your-own-key build may send them directly under the key you supply. The resulting vectors are stored locally on the relevant device.

Consumer builds may send hosted AI requests through our Cloudflare Worker. The proxy authenticates your account and records account UUID, device ID, IP address, provider, operation, time, response status, daily request counts and token-usage totals for access control, security and billing. The proxy does not intentionally write prompt bodies or model responses to its application database, but Cloudflare and the AI provider process the request in transit.

Self-hosted or bring-your-own-key builds may send the same content directly to the provider, in which case we do not receive the request body. Your separate account and the provider's terms apply. Provider retention varies: for example, Anthropic states that standard API inputs and outputs are normally deleted within 30 days, subject to its stated exceptions. Do not submit information you do not want processed by the relevant provider.

5. Service providers, disclosure and overseas processing

We disclose information only as needed for the purposes above, when you direct us to connect a service, when required by law, to investigate abuse or protect rights and safety, or as part of a genuine business reorganisation or sale subject to appropriate confidentiality and this policy.

Current categories of recipient include:

• Supabase for authentication, database, Edge Functions and encrypted object storage;
• Cloudflare for website hosting, email-list storage, Web Analytics and the hosted AI proxy;
• Fly.io for optional Cloud freshness hosting;
• DeepSeek, Anthropic and OpenAI for the AI operations described above;
• RevenueCat and Apple for subscription processing;
• SnapTrade, your linked broker, and any exchange or trading platform you choose to connect;
• market-data and foreign-exchange-rate sources used to answer a request or calculate a display, which may include Binance, Coinbase, Yahoo Finance, Finnhub, Twelve Data, Frankfurter and the Reserve Bank of Australia; and
• Google Fonts and email/support infrastructure.

These providers may process information outside Australia. Likely countries include Australia, the United States, Canada, Singapore and the People's Republic of China, as well as other countries where a selected exchange, broker or provider operates. DeepSeek states that it processes and stores submitted personal data in the People's Republic of China. Anthropic states that API data may be processed in the United States, Europe, Asia and Australia, with storage in the United States. RevenueCat states that end-user data is stored in the United States. Provider locations and subprocessors can change; follow the linked policies for current details.

We do not sell or rent personal information, share it with data brokers, or use it for third-party advertising or cross-service tracking.

6. Security

Measures used by the Services include TLS in transit, private per-user cloud storage rules, AES-256-GCM encryption for paired sync content, operating-system credential storage for release-build secrets and sessions, and encryption at rest for poller-held feed keys and SnapTrade API credentials.

No system is completely secure. You are responsible for protecting your device, email account, sync password and provider credentials, using read-only exchange permissions, and keeping independent exports and backups. A TradeCowboy sync mirror is not a substitute for backing up your vault or retaining source statements.

7. Your choices, access, correction and deletion

• Local data: you can inspect, export, edit and delete your Markdown files and attachments directly. Removing the app or deleting your TradeCowboy account does not delete a separately stored vault or every operating-system backup.
• Sync: you can disable phone sync in Settings. You can also request removal of remote sync objects by deleting your TradeCowboy account.
• Cloud freshness: turn it off before deleting your account so the separate poller enrolment and feed are removed. If you cannot do that, contact us and ask us to confirm removal.
• Connections: delete credentials and connections in the app and revoke access at the exchange, broker or SnapTrade portal. Removing a TradeCowboy connection does not close the provider account.
• AI: do not configure a bring-your-own key, disable hosted AI, or do not invoke an AI feature. Deleting a local conversation does not retroactively delete a provider's operational copy; contact us about hosted requests and the provider about direct requests.
• Marketing: use the unsubscribe link in an email or contact us.

Account deletion: Settings → Account → Delete account & cloud data initiates deletion of your TradeCowboy account and Supabase-hosted synced data. It does not cancel an Apple subscription, delete your local vault/logs, close linked provider accounts, or erase records Apple and other providers control or must retain. Manage Apple billing before or after deletion through Apple Subscriptions.

You may ask us to access, correct or delete personal information we control by emailing [email protected]. We may need to verify your identity. Some requests can be limited where retention is required by law, needed for security or disputes, or concerns information we do not control. Local-only data is accessible only to you.

8. Retention

• Local vault data, app databases, credentials and logs remain until you delete them, clear the relevant app data, or the operating system removes them.
• Account and encrypted sync data are kept while the account is active and until deletion is completed, subject to temporary backups, security records and legal requirements.
• Email-list information is kept until you unsubscribe, ask us to delete it, or it is no longer needed for the TradeCowboy communications for which it was collected.
• Hosted AI request metadata, usage totals and security logs are kept only as long as reasonably needed for access control, billing, abuse prevention, incident response and legal obligations. AI providers apply their own retention schedules.
• Subscription and transaction information may be retained by Apple, RevenueCat and us for billing, tax, fraud prevention and dispute purposes after an account is deleted.
• Support correspondence and in-app beta reports are kept as long as reasonably needed to investigate the feedback, resolve the request and maintain necessary business or legal records.

Deletion from active systems may not immediately remove information from encrypted backups or provider systems. Backup copies are isolated from ordinary use and expire or are overwritten under the relevant provider's schedule.

9. Children

The Services are intended for people aged 18 or older. We do not knowingly create accounts for or collect personal information from children. If you believe a child has provided personal information, contact us so we can investigate and delete it where appropriate.

10. Changes to this policy

We will update this page when our practices change and revise the date above. If a change materially affects how account data is used, we will give reasonable notice through the app, website or account email before it takes effect where practicable.

11. Contact and privacy complaints

Email [email protected] with “Privacy request” or “Privacy complaint” in the subject. Describe what happened and the outcome you want. We aim to acknowledge a complaint promptly and respond within 30 days.

You may also write to: Diego Fernandez, 77 Parkwood Bvd, Parkwood QLD 4214, Australia. ABN 52 517 363 809.

We comply with the privacy laws that apply to us. Australian privacy law contains exemptions for many small businesses; where the Privacy Act 1988 (Cth) applies to a complaint and you are not satisfied after giving us a reasonable opportunity to respond, you may contact the Office of the Australian Information Commissioner. Other local privacy rights and regulators may also apply depending on where you live.