DRAFT 2 — not yet in force. Prepared on 19 October 2026 for the US & Canada edition. It has not been reviewed by a lawyer. A privacy policy that describes a control the product does not have is itself a violation, so every control described here must work before this is published — see the pre-publication checklist in docs/legal/CHANGES-2026-10.md. The Hebrew privacy policy remains in force for customers in Israel.

Privacy Policy

Trader Machine · US & Canada edition · Version 2.0 (DRAFT 2) · Effective date: not yet in force — set on publication · Last updated: 19 October 2026

The short version.

  • We collect what we need to run your account, bill you through Whop, support you and keep the Service secure — plus advertising and attribution data (§4).
  • We do not sell personal information for money. Our use of the Meta Pixel and Conversions API can count as “sharing” or “targeted advertising”. You can opt out through Your Privacy Choices, and we honour Global Privacy Control.
  • We never see your full card number (Whop handles it), your brokerage login or your brokerage account.
  • AI QUANT — an AI — and the support agent send what you type to Anthropic, never your name, email or payment details (§5).
  • Wherever you live in the United States or Canada, you can see, correct, export or delete your data, and appeal a refusal (§9, §10).
  • Marketing email only if you tick the box for it; unsubscribe any time (§11).

1. Who we are and what this covers

This policy explains how [OWNER DECISION: legal name and postal address of the business. Recommended default: the same name, registration number and mailing address as Terms §1.1.], an Israeli business owned by Shaked Asher and trading as Trader Machine (“we”), handles personal information of visitors and customers of the US & Canada edition: our websites, web application, emails, live sessions, Direct Access, support chat and affiliate program. We decide why and how this information is used. The person responsible for personal information at our business (our privacy officer) is Shaked Asher, founder and owner, reachable at support@tradermachine.com. This policy forms part of our Terms of Service.

2. What we collect

CategoryExamplesWhere it comes from
Account and identifiersName, email, phone number if you give it, account ID, region, and your password (stored only as a hash by our sign-in provider)You
BillingPlan, amount, currency, tax, payment date and status, renewal date, cancellation date, country or province, and Whop's membership and payment references. We never receive your full card number; Whop and its payment partners do. You, through Whop
Consent recordsTime, IP address, browser, the exact wording of each box you ticked (sign-up, checkout, automation, marketing email), and the versions of the documents you acceptedSign-up, checkout and the application
Product useFeatures used, symbols viewed, watchlists, strategies, backtests, AI QUANT requests, runs and results, settingsYour use of the Service
Support and communicationsSupport chat messages (including the AI agent's replies), emails with us, and your name or handle and anything you say if you speak or write in a recorded live sessionYou
Direct AccessWhat you tell us when you apply (how you trade, what you want to improve), scheduling details, and our written agenda and notes from calls. Calls are not recorded.You
AutomationYour SignalStack webhook address (stored encrypted), which strategies send alerts, and the delivery result of each alertYou, if you turn automation on
Device and log dataIP address, approximate location derived from it, browser and device type, time zone, timestamps, session identifiers, error logsYour browser and our servers
Marketing attributionCampaign tags (UTM), ad-click identifiers (such as fbclid or gclid), referring page, first landing page, affiliate referral codeThe link you arrived through, recorded at your first visit
Cookies and similar technologiesStorage for sign-in and preferences, the first-visit and affiliate records, your privacy choice, and the cookies set by the Meta Pixel and our video player (§4) Your browser
Affiliates onlyPayout details and tax forms (which can include a taxpayer ID) Affiliates

Sensitive information. The only items above that privacy laws treat as sensitive are your account login and, for affiliates, a taxpayer ID. We use them only to provide and secure the Service and to meet tax obligations, never to infer anything about you. We do not collect precise geolocation, government ID (other than an affiliate's taxpayer ID), health or biometric data, and we have no access to your brokerage account. Your webhook address is not legally “sensitive”, but it works like a key, so we protect it like one (§12).

3. How we use it

We do not use your information to make decisions about you that have legal or similarly significant effects, and we do not build profiles of you for anyone else.

4. Cookies, pixels and analytics

ToolWhat it doesCan you turn it off?
Sign-in and preference storage (our own browser storage)Keeps you signed in and remembers settings such as language and themeNo — the Service needs it
Attribution capture (first-party: the browser-storage entries tm_touch and tm_vid, and the tm_ref cookie, which lasts 60 days)Records how you first reached us — campaign tags (UTM), ad-click identifiers, the referring and first landing page — and any affiliate code, with a random visitor ID that connects an affiliate link click to the sign-up that follows. Set by us, read by us; not a third-party toolYes, for advertising use (§8); affiliate credit is part of the Service
Your privacy choice (the tm_privacy_optout cookie, which lasts a year, and browser-storage entry)Remembers that this browser opted out (§8)It is the opt-out; opting back in removes it
Meta Pixel (browser) and Meta Conversions API (server)Tells Meta which ads bring visitors who sign up and subscribe. The Pixel sets Meta's own cookiesYes (§8)
Vimeo playerPlays lessons and recordings; may set its own cookiesThrough your browser settings

We do not use Google Analytics. The only advertising tools we use are the Meta Pixel and the Conversions API above.

Meta Pixel and Conversions API. The two carry a shared event ID so the same action is not counted twice. The events we send are page views and key steps — signing up, starting checkout and purchasing. An event can include its name and time, the page address, your IP address and browser details, Meta's own browser identifiers and ad-click identifier, and, for server events, your email address hashed (SHA-256) before it leaves our server. Hashing hides the address in transit, but it is not anonymity: Meta uses the hash to match the event to a Meta account if one exists. Meta uses this data for measurement and for its own advertising purposes under its own policies. We send nothing to Meta after you opt out or while your browser sends Global Privacy Control.

What we never send to Meta: payment details, your strategies or backtests, the symbols you look at, your AI or support conversations, Direct Access information, or the titles of lessons, recordings or live sessions you watch.

Tracking across sites. Because of the Meta Pixel, Meta may collect information about your online activity over time and across different websites, including ours. You can limit this with Your Privacy Choices and with these tools: your Meta ad preferences, the DAA opt-out page (US) and YourAdChoices (Canada). Tracking for advertising is never a condition of using the Service.

5. AI features and support chat

AI QUANT is an AI: it and the support agent use large language models from Anthropic, PBC, which processes the data as our service provider.

Sent to AnthropicNever sent
AI QUANTYour written request; your answers to its questions (such as how often you want to trade); the symbol and timeframe; statistics about that symbol's past prices; and summaries of your own earlier AI QUANT runsYour name, email, account ID, payment details, password, SignalStack webhook address, and anything from a brokerage account (we have no access to one)
Support chatThe messages you write in the chat and the help material the agent needs to answer them

6. Who we disclose it to

Service providers. These companies process personal information on our behalf and only for the purposes we set:

ProviderWhat they do for us
WhopCheckout, payment processing, tax calculation and collection, and subscription billing, renewal and cancellation. You give your payment details to Whop directly.
SupabaseDatabase, sign-in and authentication
RenderHosting of our application and servers
ResendSending account, billing, reminder and (if you agreed) marketing emails
AnthropicAI QUANT and the AI support agent (§5)
AlpacaMarket data. Alpaca receives requests for symbols from our servers, not personal information about you.
VimeoHosting and playing lessons and session recordings
LiveKitReal-time video and audio for live sessions inside the application
ZoomBooked calls and Direct Access calls
Our affiliate payout provider (named in the Affiliate Terms, §4)Sending commission payouts to affiliates

We also disclose information:

We do not sell personal information for money. In the last 12 months we have not sold personal information. We have “shared” identifiers and internet activity (device and browser details, page views, ad-click identifiers and hashed email) with Meta for cross-context behavioural advertising, as described in §4.

7. How long we keep it

DataKept for
Account, product use, strategies, AI QUANT runsWhile your account exists; deleted or de-identified within 90 days after you delete it
Consent records from sign-up, checkout and automationAt least three years, or one year after your subscription ends, whichever is later
Marketing-email consentWhile we send you marketing email, and three years after you withdraw it
Billing records and receiptsSeven years, for tax and accounting law
Support chat transcripts and support email24 months after the last message
Direct Access applications, agendas and call notesWhile you are a member, and 12 months after
Automation settings / alert delivery logsWhile automation is on / 24 months
Security and server logs12 months
Marketing attribution and referral codeAs long as an affiliate commission can be owed on the account, then deleted
Live-session recordingsAs long as they are in the library
Affiliate payout and tax recordsSeven years after the last payout

We keep information longer only where the law requires it or to resolve a dispute.

8. Your Privacy Choices

Opt out of “sale”, “sharing” and targeted advertising

We do not sell personal information for money. Our use of the Meta Pixel and Conversions API may be “sharing” for cross-context behavioural advertising under California law, and “targeted advertising” under other states' laws. To opt out, use any of these:

After you opt out, we stop loading the Meta Pixel for you and stop sending your events to Meta — from your browser and from our server, including a purchase. Nothing changes in the Service itself.

Do Not Track

Browsers' “Do Not Track” setting has no agreed meaning, so we do not respond to it. We do honour Global Privacy Control, as described above.

Marketing email

Use the unsubscribe link in any marketing email, or tell us (§11).

9. Your rights in the United States

Several U.S. states give their residents privacy rights, and some of those laws may not apply to a business of our size. We give these rights to everyone in the United States, wherever you live. You can ask us to:

How to ask. Email us from the address on your account (§16), with the subject “Privacy request”. We verify the request by confirming it with that address. You may use an authorised agent, who must show your signed permission; we may still confirm the request with you. We reply within 45 days; if we need more time (up to another 45 days), we tell you why.

Appeals. If we refuse a request, reply to our answer with the word “Appeal”. We will respond within the time your state's law sets, and explain our decision. If you are still not satisfied, you may contact your state attorney general.

No discrimination. We will not charge you more, give you a worse service, or treat you differently for using these rights.

California notice at collection. The categories we collect, their sources and purposes, and how long we keep them are in §2, §3 and §7. We disclose them only as §6 describes. We do not use or disclose sensitive personal information for any purpose that would give you a right to limit it.

10. Your rights in Canada

If you live in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies to how we handle your personal information. In particular:

We do not sell the Service to residents of Québec (Terms §2.2).

11. Email and marketing consent

12. Security

Connections to the Service are encrypted in transit. Your SignalStack webhook address is encrypted at rest. Database access is restricted so that customer data is reached only through our server, and only people who need access have it. Card details are handled by Whop and its payment partners and never stored by us. No system is perfectly secure; if a breach affects your personal information, we will notify you and the authorities as the law requires.

13. Children

The Service is for adults only. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us information, contact us and we will delete it.

14. Where your data is processed

Our business operates from Israel, and our service providers — including Whop, Supabase, Render, Resend and Anthropic, which are based in the United States — process data in the United States and in other countries where they operate. Your information may therefore be stored and processed outside your state or province, and may be accessible to courts and authorities in those countries under their laws. We use providers that protect it under contract.

15. Changes to this policy

We will post any change here with a new effective date. If a change is material, we will also email you before it takes effect. We will not use information already collected in a materially different way without your consent where the law requires it.

16. Contact

Privacy requests and questions: support@tradermachine.com — subject line “Privacy request”.
Privacy officer: Shaked Asher, founder and owner.
Post: the business named in §1, at the address given there.