Privacy Policy

Last updated: January 1, 2026

This Privacy Policy explains how Sprouted collects, uses, and handles your personal data. By using the Platform you agree to the practices described below. This policy should be read alongside our Terms of Service.

1. Scope and Controller

This Privacy Policy describes how Sprouted Trade Ltd ("Sprouted," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data when you access or use the Sprouted platform ("Platform"). By using the Platform you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must not use the Platform.

2. Data We Collect

We collect and process the following categories of data: (a) Account data: name, email address, username, and password hash; (b) Payment data: billing address and masked payment card details processed by our third-party payment processor — we do not store full card numbers; (c) Usage data: trade journal entries, paper trading activity, AI query history, signal interactions, feature usage, and session logs; (d) Technical data: IP address, browser type, device identifiers, operating system, referring URLs, and cookie data; (e) Communications: any messages, feedback, or support requests you send us.

3. How We Use Your Data

We use your personal data to: (a) provide, operate, maintain, and improve the Platform; (b) process payments and manage subscriptions; (c) personalise your experience and AI outputs; (d) send you transactional emails (account activity, billing, security alerts); (e) send marketing communications where you have opted in; (f) detect, investigate, and prevent fraud, abuse, and security incidents; (g) comply with legal and regulatory obligations; (h) enforce these Terms and our rights. We reserve the right to use aggregated, anonymised, or de-identified data derived from your usage for any purpose, including product improvement, research, and commercial purposes, without restriction.

4. Data Sharing and Disclosure

We may share your personal data with: (a) service providers and sub-processors who assist in operating the Platform (cloud hosting, payment processing, analytics, email delivery, fraud detection) under appropriate data processing agreements; (b) professional advisers including lawyers, accountants, and insurers; (c) law enforcement, regulators, or courts where disclosure is required by applicable law, court order, or to protect our rights; (d) a successor entity in connection with a merger, acquisition, restructuring, or sale of all or substantially all of our assets — in which case your data may be transferred without your separate consent. We do not sell your personal data to data brokers or third-party advertisers.

5. Data We Do Not Guarantee to Protect

While we implement reasonable technical and organisational security measures, NO SECURITY SYSTEM IS IMPENETRABLE. We cannot guarantee the absolute security of your data and accept no liability for unauthorised access, disclosure, alteration, or destruction of your personal data resulting from a security breach beyond our reasonable control. You use the Platform and transmit data at your own risk. We strongly encourage you to use a strong, unique password and enable any multi-factor authentication options available.

6. Retention

We retain your personal data for as long as your account is active and for a period of up to seven (7) years thereafter to comply with legal obligations (including financial and tax record-keeping requirements), resolve disputes, and enforce our agreements. After this period, data will be deleted or anonymised. We are not obligated to retain data for any minimum period and may delete data earlier at our discretion.

7. Your Rights

Subject to applicable law, you may have certain rights regarding your personal data, including the right to access, correct, delete, restrict, or object to processing, and the right to data portability. To exercise these rights, contact us at privacy@sproutedtrade.com. We will respond within the timeframe required by applicable law. Note that some rights are subject to exceptions — for example, we may retain data where we have legitimate legal or contractual obligations to do so. Exercising your rights will not entitle you to any refund of subscription fees.

8. Cookies and Tracking

We use cookies and similar tracking technologies to operate the Platform and to analyse usage. Essential cookies are required for the Platform to function; disabling them may prevent you from using core features. Analytics and performance cookies help us understand how the Platform is used. You may manage cookie preferences via your browser settings, but we do not guarantee that all functionality will remain available if you disable non-essential cookies. By using the Platform, you consent to our use of cookies as described.

9. Third-Party Links and Services

The Platform may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices or content of those third parties. This Privacy Policy applies solely to data collected by Sprouted. We encourage you to review the privacy policies of any third-party services you access.

10. International Data Transfers

Your data may be transferred to, stored in, and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your jurisdiction. By using the Platform, you consent to such international transfers. Where required, we implement appropriate safeguards such as standard contractual clauses.

11. Children

The Platform is not directed at individuals under 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware that a user is under 18, we will terminate the account and delete associated data without refund.

12. No Warranty Regarding Data Use

WE MAKE NO WARRANTIES, EXPRESS OR IMPLIED, AS TO THE PRIVACY, SECURITY, OR CONFIDENTIALITY OF ANY DATA TRANSMITTED THROUGH THE PLATFORM. ALL DATA IS PROVIDED AND STORED "AS IS." TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL LIABILITY FOR ANY LOSS, DISCLOSURE, OR MISUSE OF YOUR DATA REGARDLESS OF CAUSE.

13. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page with a revised effective date. Where changes are material, we will make reasonable efforts to notify you by email. Your continued use of the Platform following any change constitutes acceptance of the revised policy.

14. Contact

For privacy-related questions, contact: privacy@sproutedtrade.com. Response times are not guaranteed and responses do not constitute legal advice.