Privacy Policy

Effective date: 25.07.2026 v.1.2 Applies to users of Path2Trade, with additional rights for users in the European Union, European Economic Area, United Kingdom, and other jurisdictions where applicable.

Privacy at a glance — please read

• Who we are. Path2Trade is an online education platform for learning to read charts and recognize trading patterns. It is not a broker, exchange, or financial service. We do not hold your money or execute trades.
• What we collect. Account and profile details, your learning activity (answers, attempts, progress, streaks), payment-related and support information, and technical data such as device and usage information collected through cookies and similar technologies.
• Why. To provide and personalize the learning experience, run your account and subscription, keep the Service secure, comply with law, and improve our product. We do not sell your personal data.
• If you are in the EU/EEA or UK, you have rights under the GDPR — including access, correction, deletion, portability, and objection — and the right to complain to a data-protection authority (see Section 10).
• If you are in the United States, you may have rights under California (CCPA/CPRA) and other state laws, including to access, delete, correct, and opt out of "sharing" for targeted advertising (see Section 11).
• Age. The Service is for adults (18+). It is not directed to children (see Section 12).

This summary is for convenience only. The full Policy below is what governs.

This Privacy Policy (the "Policy") explains how Path2Trade ("Path2Trade," "we," "us," or "our"), collects, uses, shares, and protects personal data about you when you access or use the Path2Trade websites and related online services (together, the "Service"). For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") and equivalent laws, Path2Trade is the controller of the personal data described in this Policy.

This Policy should be read together with our Terms of Use. Capitalized terms that are not defined here have the meaning given to them in the Terms of Use. This Policy is provided to explain how we process personal data. It is not intended to create a separate consent mechanism. Where we rely on consent, we will ask for it separately.

Table of Contents

1. Introduction and Scope
2. Information We Collect
3. How We Use Information
4. Cookies and Similar Technologies
5. How We Share Information
6. Advertising and Analytics
7. Data Retention
8. Data Security
9. International Data Transfers
10. Your Privacy Rights — EU, EEA, and UK
11. Additional Privacy Rights for Certain US Residents
12. Children's Privacy
13. Third-Party Links and Services
14. Changes to This Policy
15. How to Contact Us

1. Introduction and Scope

This Policy applies to personal data we process about visitors to our Websites, registered users, and customers of the Service, regardless of where you access it. It does not apply to the practices of third parties that we do not own or control, including brokers, exchanges, payment networks, advertisers, or other websites and services that may be linked from the Service. Those third parties have their own privacy policies, which we encourage you to review.

Because Path2Trade is an educational service and not a financial service, we do not open brokerage or trading accounts, do not custody funds or securities, and do not collect the kinds of financial-account, order, or position data that a broker or exchange would. Where we mention "payment information," we mean the limited information needed to process a subscription through our payment processor, as described below.

2. Information We Collect

2.1 Information you provide to us

• Account and registration data: such as your name or display name, email address, password (stored in hashed form), and, where applicable, country or region.
• Profile and preferences: optional profile details, learning goals, language, notification settings, and similar preferences you choose to provide.
• Payment-related data: if you purchase a paid subscription, billing details and transaction records. Card and bank details are collected and processed directly by our payment provider, Stripe. We receive limited information such as transaction status, billing country, subscription status, card brand, and the last four digits of the payment card. Stripe may process certain payment data as an independent controller for its own legal, security, fraud-prevention, and regulatory obligations, as described in its own privacy policy. See Section 5.
• Support and communications: the content of messages, support requests, survey responses, and other communications you send to us, including any information you choose to include.
• User content: any notes, comments, screenshots, or other materials you submit where the Service allows it, as described in the Terms of Use.

2.2 Learning Activity Data

When you use the educational activities in the Service, we collect information generated by your use, which we refer to as "Learning Activity Data." This may include your answers and attempts, the practice prompts you respond to (for example, "Buy," "Sell," or "Nothing"), timing and accuracy, lessons and cases completed, scores, streaks, levels, badges, progress and completion status, and skill-map and interaction data. We use Learning Activity Data to provide feedback, personalize your practice, measure progress, maintain and secure the Service, develop new features, and improve educational quality, and we may create aggregated or de-identified analytics from it. This concept is also described in Section 22 of the Terms of Use.

Learning Activity Data reflects your use of educational simulations and practice exercises. It does not represent actual trades, brokerage orders, investment positions, portfolio holdings, or financial account activity.

2.3 Information collected automatically

• Device and connection data: such as IP address, device type, operating system, browser type, language settings, and unique device or app identifiers.
• Usage and log data: such as pages and screens viewed, features used, links clicked, dates and times of access, referring and exit pages, session duration, crash and diagnostic data, and similar activity logs.
• Approximate location: a general, non-precise location (for example, country or region) inferred from your IP address. We do not collect precise GPS location without your consent.
• Cookies and similar technologies: as described in Section 4.

2.4 Information we receive from third parties

• Sign-in providers: if you register or log in using a third-party account (for example, a social or single-sign-on provider), we may receive information such as your name, email address, profile image, account identifier, and authentication tokens, depending on the provider and your settings.
• Payment processor: transaction status and limited billing details from Stripe, as described above.
• Analytics and advertising partners: measurement and audience information from providers such as Google (Google Analytics 4, delivered through Google Tag Manager) and Amplitude, used as described in Section 6.
• Security and fraud-prevention providers: signals used to detect and prevent abuse, fraud, and unauthorized access.

2.5 Special category and sensitive data

We do not intentionally collect special categories of personal data under the GDPR, such as health data, biometric data, political opinions, religious beliefs, or trade-union membership. Please do not include this type of information in support messages, notes, screenshots, or other user content. If you choose to provide such information, we will process it only as necessary to provide the Service, handle your request, or comply with law.

Please do not upload brokerage statements, account numbers, tax documents, government IDs, or screenshots showing financial account balances unless we specifically request them.

3. How We Use Information

We use personal data for the following purposes:

• to create and manage your account and provide the Service;
• to deliver, personalize, and improve the learning experience, including feedback, progress tracking, and recommendations based on your Learning Activity Data;
• to process subscriptions, payments, and refunds, and to maintain transaction records;
• to communicate with you about the Service, including service messages, security alerts, and support responses, and — where permitted — marketing and product updates you can opt out of;
• to maintain the security and integrity of the Service, and to detect, investigate, and prevent fraud, abuse, and violations of our Terms of Use;
• to measure and analyze usage so we can understand and improve our product and content;
• to comply with legal obligations and to establish, exercise, or defend legal claims; and
• for other purposes disclosed to you at the time of collection or with your consent.

3.1 Legal bases for processing (EU/EEA/UK)

If you are in the EU, EEA, or UK, we rely on the following legal bases under the GDPR (and UK GDPR) for the processing described above:

How each processing activity maps to a GDPR legal basis.

Where we rely on legitimate interests, you have the right to object as described in Section 10. Where we rely on consent, you may withdraw it at any time without affecting processing carried out before withdrawal.

3.2 When providing data is required

Some personal data is required to create an account, provide the Service, process subscriptions, and comply with legal obligations. If you do not provide required account, authentication, or payment-related information, we may not be able to provide the relevant parts of the Service. Optional profile information, learning goals, survey responses, and marketing preferences are not required to use the core Service.

4. Cookies and Similar Technologies

We and our partners use cookies, software development kits (SDKs), pixels, local storage, and similar technologies to operate the Service, remember your preferences, keep you signed in, measure performance, and — where permitted — support advertising. We group these into:

• Strictly necessary: required to provide core functionality, such as authentication, security, load balancing, and remembering the consent choice you have made. These cannot be switched off through our consent tool.
• Analytics/performance: help us understand how the Service is used so we can improve it.
• Advertising/Marketing: help measure and, where applicable, deliver advertising, including on the free tier.

Our consent tool offers exactly these three categories. Preference and settings storage is treated as strictly necessary rather than as a separate category, because the only preference we store in this way is your consent choice itself.

Where required by law (including in the EU/EEA and UK), we ask for your consent before setting non-essential cookies and similar technologies through a cookie banner or preference center, and you can change your choices there at any time. You can also control cookies through your browser or device settings. Some features may not work properly if you disable certain cookies. We honor recognized opt-out preference signals where required, as described in Section 11.

In the EU/EEA and UK, we will not set analytics, advertising, social-media, or other non-essential cookies, SDKs, pixels, local-storage objects, or similar technologies unless you have given prior consent, except where a limited exemption applies under applicable law.

Our cookie banner will provide equally accessible options to accept or reject non-essential cookies, will not use pre-ticked boxes for consent, and will allow you to withdraw or change your choices at any time.

More detailed information about the cookies and similar technologies we use, including provider, purpose, duration, and how to change your choices, is available in our Cookie Policy.

Summary of the main cookies and similar technologies we use. Specific providers and durations are detailed in the Cookie Policy.

5. How We Share Information

We do not sell your personal data. We also do not share your Learning Activity Data with third-party advertisers for their own advertising purposes. Where advertising or analytics partners receive personal data through cookies, pixels, SDKs, or similar technologies, we do so only as described in this Policy and subject to your consent where required. We share personal data only as described below:

• Service providers and processors: vendors that perform services on our behalf and under our instructions, such as cloud hosting and storage (Vercel,Supabase), payment processing (Stripe), email and messaging (Postmark), tag management and analytics (Google, Amplitude), customer support, and security and fraud prevention. They may process personal data only as needed to provide their services to us.
• Advertising and analytics partners: as described in Section 6. Depending on your location and choices, some of this activity may be considered "sharing" for targeted advertising under US state laws.
• Within our group: with our affiliates and corporate group for the purposes described in this Policy.
• Legal, safety, and compliance: when we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or a governmental request; to enforce our Terms of Use; or to protect the rights, property, or safety of Path2Trade, our users, or others.
• Business transfers: in connection with, or during negotiations of, a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, in which case personal data may be transferred as a business asset, subject to this Policy.
• With your consent or at your direction: for any other purpose disclosed to you at the time.
• Aggregated or de-identified data: we may share information that has been aggregated or de-identified so that it no longer reasonably identifies you.

6. Advertising and Analytics

We use Google Analytics 4 and Amplitude, both delivered through Google Tag Manager, to understand how the Service is used and to improve it. The free tier of the Service may include advertising, as noted in Sections 14.1 and 16 of the Terms of Use. Where we or our partners use cookies and similar technologies for analytics or advertising, we do so subject to your consent or opt-out choices as described in Section 4 and Section 11.

Some advertising may be contextual (based on the content you are viewing) and some may be interest-based (based on information about your activity over time). You can manage interest-based advertising through industry tools such as the Digital Advertising Alliance, the Network Advertising Initiative, and, in the EU, Your Online Choices, as well as through your device settings.

We do not use your Learning Activity Data, trading-pattern answers, scores, mistakes, streaks, or progress history to target third-party advertising to you, unless we clearly ask for your consent first.

7. Data Retention

We keep personal data for as long as necessary to provide the Service and fulfil the purposes described in this Policy, after which we delete or anonymize it. The actual retention period depends on the type of data and the purpose, as summarized below:

We may retain data for longer where required to comply with legal obligations, resolve disputes, or enforce our agreements.

8. Data Security

We maintain technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, and alteration, such as encryption in transit, access controls, and storage of passwords in hashed form. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential, and you should notify us promptly at support@path2trade.com if you suspect any unauthorized use of your account. Where required by law, we will notify you and the relevant authorities of a personal-data breach.

9. International Data Transfers

Some of our service providers may process personal data outside the EU/EEA, including in the United States. Where we transfer personal data to a country that has not been recognized as providing an adequate level of protection, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses. Where a US provider is certified under the EU-US Data Privacy Framework, we may rely on the European Commission's adequacy decision for transfers to that provider. You may request information about the relevant transfer safeguards by contacting us at support@path2trade.com.

10. Your Privacy Rights — EU, EEA, and UK

If you are in the European Union, the European Economic Area, or the United Kingdom, you have the following rights in relation to your personal data, subject to the conditions and exceptions in the GDPR and UK GDPR:

• Access — to obtain confirmation of whether we process your data and a copy of it;
• Rectification — to have inaccurate or incomplete data corrected;
• Erasure — to have your data deleted in certain circumstances ("right to be forgotten");
• Restriction — to restrict our processing in certain circumstances;
• Portability — to receive certain data in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible;
• Objection — to object to processing based on our legitimate interests, and to object at any time to processing for direct marketing; and
• Withdraw consent — where we rely on consent, to withdraw it at any time without affecting prior processing.

To exercise these rights, contact us at support@path2trade.com. We will respond within the timeframes required by law. For GDPR requests, we generally respond within one month of receiving your request, unless the GDPR permits an extension due to the complexity or number of requests. You can also adjust many settings directly in your account. We will not discriminate against you for exercising your rights. You may request deletion of your account by contacting support@path2trade.com or, where available, by using the account deletion option in your account settings.

Automated decision-making and profiling. We use Learning Activity Data to personalize lessons, practice prompts, progress feedback, and recommendations. This may involve profiling in the sense that we use your activity to infer your learning progress and areas for improvement. We do not use this profiling to make decisions that produce legal or similarly significant effects about you within the meaning of Article 22 GDPR.

Right to complain. You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, or — in the UK — with the Information Commissioner's Office (ICO). We would, however, appreciate the chance to address your concerns first.

11. Additional Privacy Rights for Certain US Residents

This section applies only where Path2Trade is subject to the relevant US state privacy law.

Depending on the US state in which you reside, you may have rights under laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and comparable laws in states including Virginia, Colorado, Connecticut, Utah, and others. Subject to the conditions and exceptions in the applicable law, these rights may include:

• Right to know/access the categories and specific pieces of personal data we have collected about you, the sources, the purposes, and the categories of recipients;
• Right to delete personal data we have collected from you;
• Right to correct inaccurate personal data;
• Right to opt out of the "sale" or "sharing" of personal data and of targeted (cross-context behavioral) advertising;
• Right to limit the use and disclosure of sensitive personal data, where applicable; and
• Right to non-discrimination for exercising your rights.

"Sale" and "sharing." We do not sell personal data as the term "sell" is defined under applicable US state privacy laws. However, our use of advertising and analytics cookies, pixels, SDKs, or similar technologies may be considered "sharing" or targeted advertising under some US state laws. You can opt out by using our cookie preference center, by enabling a recognized opt-out preference signal such as the Global Privacy Control (GPC), which we honor where required, or by contacting us at support@path2trade.com.

Sensitive data. We do not use or disclose sensitive personal data for purposes that would require offering a "right to limit" beyond what is described here. We do not knowingly process the personal data of consumers we know to be under 16 for sale or sharing without authorization.

How to exercise your rights. Submit a request to support@path2trade.com. We will verify your request using the information associated with your account and respond within the timeframes required by law.

Categories collected and disclosed. In the preceding 12 months, we have collected the categories of personal data described in Section 2 (such as identifiers, account and commercial information, internet/usage activity, approximate location, and Learning Activity Data) and disclosed categories of that data to the types of recipients described in Section 5 for the business and commercial purposes described in Section 3. Disclosures that may be considered "sharing" relate to advertising and analytics partners as described in Section 6.

California "Shine the Light." California residents may request information about disclosures of personal information to third parties for their direct-marketing purposes. We do not disclose personal information for those purposes in a manner that would require such a response, but you may contact us at support@path2trade.com with questions.

12. Children's Privacy

The Service is intended only for adults who are at least 18 years old, consistent with Section 10 of the Terms of Use. The Service is not directed to children, and we do not knowingly collect personal data from children. If you are a parent or guardian and believe that a child has provided us with personal data, please contact us at support@path2trade.com and we will take appropriate steps to delete it. We do not knowingly "sell" or "share" the personal data of minors.

13. Third-Party Links and Services

The Service may contain links to, or integrations with, third-party websites, brokers, exchanges, data providers, advertisers, or services that we do not own or control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. If you access a third-party website or service from the Service, you do so at your own risk, and we encourage you to review the privacy policy of every third party you interact with. This mirrors Section 16 of the Terms of Use.

14. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will post the updated Policy on the Service and update the effective date above, and — where required by law or where the change materially affects your rights — we will provide additional notice, such as by email or an in-product notice. Any changes become effective when posted unless stated otherwise or unless a later date is required by law. The updated Policy will apply from the effective date shown at the top of the Policy. Where required by law, we will seek your consent before applying changes to processing activities that require consent.

15. How to Contact Us

If you have questions, requests, or complaints about this Policy or our handling of personal data, you can contact us as follows:

• General and consumer support: support@path2trade.com
• Legal notices: support@path2trade.com

Last revised: 25.07.2026.

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