Privacy Policy

1. Who We Are

Cerebral Trading Labs ("CTX", "we", "us", "our") operates the CTX trading journal platform. For the purposes of applicable data protection law, CTX is the data controller responsible for your personal information.

Our contact details for data-related enquiries are set out at the end of this policy.

2. Information We Collect

We collect the following categories of information when you use the Service:

a) Account Information

When you register, we collect your email address, display name, and (if you use social sign-in) limited profile information provided by your identity provider. We use this to create and manage your account.

b) Trading Data & Journal Entries

When you use CTX to log trades and write journal entries, we collect and store this data, including trade details, entry prices, exit prices, outcomes, notes, and any attachments. This data is yours and is stored in encrypted form.

c) AI Interaction Data

When you use AI features (Sage AI Coach, Journal.AI, Insight Lab), we process the content you provide to generate responses. This may include your trade data and journal entries. We do not use this data to train our own AI models.

d) Usage Data

We automatically collect information about how you interact with CTX, including pages visited, features used, time spent, and browser/device information. This helps us understand usage patterns and improve the platform.

e) Payment Information

We do not store your full payment card details. Payment processing is handled by our payment processor, who provides us with limited information (such as transaction ID and last four digits) needed to manage your subscription.

f) Communications

If you contact our support team, we store your emails and any attachments to help respond to your enquiry.

3. How We Use Your Data

We use your personal data for the following purposes:

• To provide and maintain the CTX Service
• To process your subscription and payments
• To send transactional emails (account confirmations, password resets, receipt)
• To improve and optimise the platform based on usage patterns
• To provide customer support
• To comply with legal obligations
• To detect and prevent fraud or misuse
• To send optional marketing communications (only with your consent)

4. Data Retention

We retain your personal data for as long as your account is active. If you delete your account, we delete your personal data within 30 days, except where retention is required by law (e.g., for tax or compliance purposes).

AI feature interactions are processed by our third-party AI provider and may be retained by them according to their policy. For details, see the Third-Party Services section.

5. Third-Party Services

We use the following third-party services that may process your personal data:

• Cloud Database & Authentication Provider: We use a reputable cloud infrastructure provider to host your data and handle authentication. Your data is encrypted in transit and at rest.
• Payment Processor: Your payment information is processed by a PCI-compliant payment processor. We do not see or store your full card details.
• AI Language Model Provider: Content you submit to AI features is sent to a third-party AI model provider to generate responses. This provider may retain your queries according to their policy. Please review their privacy policy before using AI features.
• Analytics Provider: We use analytics tools to understand how users interact with CTX. This data is anonymised and not linked to your identity.
• Email Service Provider: We use a third-party email service to send transactional and optional marketing emails.

Each third party has signed a data processing agreement and is required to maintain appropriate security standards.

6. Data Security

We implement industry-standard security measures to protect your data, including encryption, secure authentication, and regular security audits. However, no system is 100% secure. We encourage you to use a strong password and enable two-factor authentication if available.

7. Data Sharing

We do not sell or rent your personal data to third parties. We only share your data with the third-party service providers listed in Section 5, and only as necessary to provide the Service.

We may disclose your data if required by law, or to protect the rights, safety, or property of CTX, our users, or the public.

8. International Data Transfers

If you are located outside Canada, your data may be transferred to and processed in Canada or other jurisdictions where our service providers operate. By using CTX, you consent to such transfers. We ensure appropriate safeguards are in place, such as standard contractual clauses.

9. Your Rights

Depending on your location, you may have the following rights:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can ask us to correct inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): You can request deletion of your data, subject to legal retention obligations.
• Right to Restrict Processing: You can ask us to limit how we use your data in certain circumstances.
• Right to Data Portability: You can request your data in a portable format.
• Right to Object: You can object to our processing of your data for certain purposes, such as marketing.
• Rights Related to Automated Decision-Making: You have rights if we make automated decisions that have legal or significant effects on you.

To exercise any of these rights, contact us using the details in Section 16.

10. Cookies & Tracking

We use cookies and similar technologies to authenticate you, remember your preferences, and analyse usage. For full details on cookies, see our Cookie Policy.

11. California Privacy Rights (CCPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act:

• Right to know what personal data we collect, use, share, and sell
• Right to delete personal data we have collected from you
• Right to opt-out of the sale or sharing of your personal data
• Right to non-discrimination for exercising your rights

CTX does not sell or share your personal data in the traditional sense. We may share data with service providers as described in this policy. To exercise these rights, contact us at [email protected].

12. Do Not Track

Some browsers include a Do Not Track (DNT) feature. We do not respond to DNT signals at this time, as there is no industry standard for recognition.

13. Children Privacy

CTX is not intended for children under 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will delete it promptly.

14. Third-Party Links

CTX may contain links to third-party websites. We are not responsible for their privacy practices. We recommend reviewing their privacy policies before providing your information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email and/or by posting a prominent notice within the Service, at least 14 days before the changes take effect.

Your continued use of the Service after the effective date of any update constitutes your acceptance of the updated Policy. If you do not agree with the changes, you must stop using the Service.

16. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact our privacy team:

Cerebral Trading Labs - Privacy
Email: [email protected]
Ontario, Canada

We aim to respond to all legitimate requests within 30 days. Occasionally it may take longer if your request is complex or you have made multiple requests - in that case, we will keep you informed.