Privacy Policy

Last updated: Nov 25, 2025

This Privacy Policy describes how we collect, use, store, and share information when you use [Application Name], a stock trading and portfolio management application (the “Service”), operated by [Company / Individual Name] (“we,” “us,” or “our”).

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy and our Terms of Use.

1. Information We Collect

1.1 Information You Provide to Us

We collect information that you provide directly to us, such as:

  • Account information: name, email address, username, password, and other profile details.
  • Trading preferences: goals, strategies, risk preferences, and related settings you configure.
  • Communications: messages you send to us (e.g., support requests, feedback, or other inquiries).
  • Consents and settings: choices you make about notifications, data sharing, and account configurations.

1.2 Information from Linked Brokerages

When you connect a third-party brokerage account to the Service, we may receive information from that brokerage (“Brokerage Data”), such as:

  • Account identifiers (e.g., account number or account ID key);
  • Balances (e.g., cash balance, portfolio value);
  • Holdings and positions (e.g., symbols, quantities, cost basis, market values, gains/losses);
  • Order and trade information (e.g., orders submitted through the Service, fills, status, and execution prices);
  • Account status flags (e.g., trading restrictions, fractional trading eligibility) where available.

The specific data we can access depends on the permissions granted by you at the brokerage and their APIs.

1.3 Credentials and Security Information

To connect a brokerage, you may provide us with API keys, OAuth tokens, or other technical credentials (“Broker Credentials”). We store these credentials in encrypted form and use them solely to:

  • Retrieve Brokerage Data from the broker’s API; and
  • Submit, modify, and cancel trade orders at your direction.

We do not store your brokerage login password (for username/password-based logins) and we do not take custody of your funds or securities.

1.4 Usage Data

We may collect information about how you access and use the Service, including:

  • Log data (e.g., IP address, browser type, operating system, pages viewed, access times, referring URLs);
  • Interaction data (e.g., clicks, navigation paths, feature usage, error reports);
  • Device information (e.g., device type, screen size, approximate location derived from IP address).

1.5 Cookies and Similar Technologies

We may use cookies and similar technologies to:

  • Maintain your session and keep you logged in;
  • Remember your preferences and settings;
  • Measure usage patterns and improve the Service.

You can usually adjust your browser settings to refuse or limit cookies, but some parts of the Service may not function properly if you disable them.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To provide and operate the Service: create and manage your account, connect brokerages, display holdings and balances, process trade requests, and maintain your strategies.
  • To secure the Service: detect, prevent, and respond to fraud, abuse, security incidents, and technical issues.
  • To improve the Service: analyze usage and performance, develop new features, and enhance user experience.
  • To communicate with you: send administrative messages (e.g., account notices, security alerts), respond to your inquiries, and, where permitted, send updates about the Service.
  • To comply with legal obligations: meet applicable legal, regulatory, and compliance requirements, and enforce our Terms of Use.

3. Legal Bases for Processing (if applicable)

Where required by law (for example, in the European Economic Area or United Kingdom), we rely on one or more of the following legal bases to process your personal data:

  • Performance of a contract: to provide and manage the Service in accordance with our Terms of Use.
  • Legitimate interests: to maintain and improve the Service, secure our systems, and prevent misuse.
  • Consent: where we ask for your consent for specific processing (e.g., certain cookies or optional communications).
  • Legal obligations: to comply with applicable laws and regulations.

4. How We Share Information

We do not sell your personal information. We may share information in the following situations:

4.1 Service Providers

We may share information with trusted third-party service providers who perform services on our behalf, such as hosting, data storage, analytics, logging, email delivery, or customer support. These providers are authorized to use your information only as necessary to provide services to us.

4.2 Linked Brokerages

When you submit or manage trades through the Service, we share only the information necessary to perform those actions with the connected brokerages (e.g., symbols, quantities, order types, and your Broker Credentials for authentication).

4.3 Compliance with Law and Protection of Rights

We may disclose information if we believe in good faith that such disclosure is reasonably necessary to:

  • Comply with any applicable law, regulation, legal process, or governmental request;
  • Enforce our Terms of Use or other agreements;
  • Protect the security or integrity of the Service;
  • Protect our rights, property, or safety, or that of our users or the public.

4.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, subject to confidentiality obligations and applicable law.

5. Data Security

We use reasonable technical and organizational measures to protect your information, including encryption of sensitive fields (such as Broker Credentials) in storage and in transit where appropriate.

However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for limiting access to your devices.

6. Data Retention

We retain your personal information for as long as necessary to:

  • Provide the Service to you;
  • Comply with legal, regulatory, tax, or accounting obligations;
  • Resolve disputes and enforce our agreements.

When information is no longer needed, we may delete, anonymize, or aggregate it in accordance with our data retention practices and applicable law.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights in relation to your personal information, which may include the right to:

  • Access the personal information we hold about you;
  • Request correction of inaccurate or incomplete information;
  • Request deletion of your personal information, subject to legal obligations;
  • Object to or restrict certain forms of processing;
  • Withdraw consent where processing is based on your consent;
  • Receive your data in a portable format where technically feasible.

To exercise these rights, please contact us at info@snapdaisy.com. We may need to verify your identity before responding to certain requests.

8. International Transfers

Your information may be processed and stored in countries other than the country in which you are resident, which may have different data protection laws. Where required, we take appropriate measures to protect your information in accordance with applicable law.

9. Children’s Privacy

The Service is not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If you believe that a child has provided us with personal information, please contact us so that we can take appropriate action.

10. Third-Party Links and Services

The Service may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy does not apply to those third parties, and we are not responsible for their content, privacy policies, or practices. We encourage you to review the privacy policies of any third-party sites or services you visit.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by posting the updated policy on the Service and updating the “Last updated” date at the top of this page, or by other appropriate means. Your continued use of the Service after any changes become effective signifies your acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

[Company / Individual Name]
[Address]
info@snapdaisy.com