Privacy Commitment

TurtleTrading.ai is operated by Turtle Trading Limited, a company incorporated in the Hong Kong Special Administrative Region (Company No. 80420464) (TurtleTrading.ai, we, us). This Privacy Commitment applies when you visit turtletrading.ai, order or use the Turtle AI software, use the VPS we provide, or contact our team.

We follow the Hong Kong Personal Data (Privacy) Ordinance (PDPO). If you live in the European Union, the United Kingdom or another place with its own privacy law, we also respect the rights that law gives you - including those under the GDPR and UK GDPR.

This document forms part of our Service Terms & Conditions. Words in bold have the same meaning in both documents.

Contact and account details

Your name, email address, phone number, WhatsApp or Telegram handle, country and preferred language. We collect these when you contact us, start a trial or place an order.

Order and payment information

The products you ordered, prices, dates, invoices and payment status. Payment card details are collected and stored by our payment processor only. We receive a confirmation, the card type and the last four digits - never the full card number or security code.

Trading account details

Your broker's name and server, and your MetaTrader account number. The account number is used to lock your licence to your account - this is how we prevent unauthorised copies. We may see your account currency and balance on screen during setup or support, but we do not record them.

If you give us a MetaTrader investor or master password for setup, we use it only for that task and delete it from our records when the task is complete.

VPS data

Logs, settings, MetaTrader files and trade history created while the Software runs on your VPS. This data lives on your server, not on ours. See Your VPS Data for exactly how we treat it.

Support conversations

Emails, chat messages, screenshots and notes from calls that you share with us when you ask for help. Please do not send us passwords or card details in chat.

Website data

Standard server logs (IP address, browser type, pages visited, referring site and time of visit). The website currently sets no analytics or marketing cookies; if that changes, we will update this document first.

What we do not collect

• Identity documents, unless a payment provider or the law specifically requires them.
• Bank account numbers or full payment card numbers.
• Data about children. Our services are for adults aged 18 and over.
• Any data from your trading account that is not needed to license, install or support the Software.

To deliver the Services you ordered

Setting up your licence and VPS, installing the Software, processing your payment, and sending service messages such as installation confirmations, payment reminders, VPS renewal notices and security alerts. You cannot opt out of service messages while you are a customer, because we need them to run the Services.

To support you

Answering your questions, troubleshooting the Software and VPS, re-issuing your licence after a permitted account change and helping you install updates.

To keep the Services secure

Verifying payment cards, detecting fraud, detecting unauthorised copies of the Software (one licence file per trading account) and protecting our servers against unauthorised access.

To improve the product

We may use aggregated, anonymised information - for example which settings are commonly used or which errors occur most often - to improve the Software and our documentation. This never identifies you or your individual trades.

To meet legal and accounting obligations

Keeping records of sales and invoices as required by Hong Kong company and tax law, responding to lawful requests from authorities, and establishing or defending legal claims.

Marketing - only with your consent

We send product news, updates and offers by email only if you have agreed to receive them. Every marketing email contains an unsubscribe link, and you can also opt out by writing to us. We never give or sell your details to other companies for their marketing.

Legal basis (for customers in the EU and UK)

• Contract: delivering the Software, VPS and support you ordered.
• Legitimate interests: securing our systems, preventing licence abuse and improving the product.
• Consent: marketing emails and non-essential cookies.
• Legal obligation: accounting, tax and lawful requests from authorities.

Data residency

All data generated or stored on your VPS - trading logs, configuration files, MetaTrader history and anything else you place there - remains strictly within that server environment. It is not transmitted to our systems and we do not keep a copy of it.

Who can access your VPS

Access is restricted to authorised TurtleTrading.ai team members, and only for installation, essential technical support, security updates and system maintenance. Each access is logged, and we tell you what we did whenever we have logged in to resolve a request from you.

What we never do

• Place, modify or close trades on your account, unless you ask us to in writing during a support call.
• Change your Software settings without your agreement.
• Export, copy or move your logs or trade history off your VPS, unless you ask us to or the law requires it.
• Give anyone outside TurtleTrading.ai access to your VPS, including brokers, signal services or other customers.

Your access and control

You receive full login details for your VPS and can see everything on it at any time. You may change the VPS password. If you do, please tell us the new one or accept that our ability to support you may be limited until you do.

How we keep it safe

Firewalled servers at established data-centre providers, strong unique passwords, regular security patches, and two-factor authentication on our administration accounts. For your MetaTrader account we recommend sharing only the read-only investor password with anyone, including us, unless a task genuinely needs more.

When your VPS ends

When your hosting period ends or you cancel, the VPS is switched off and all data on it is permanently deleted 30 days later. Before that date you can download anything you want to keep, or ask us to send you a copy of your MetaTrader files. After deletion the data cannot be recovered.

Who we share data with

We share personal data only with service providers that help us run the Services, and only the data each one needs:

• Data-centre and VPS providers - to host your server.
• Payment processors - to verify your card and collect the licence fee.
• Email, messaging and website hosting providers - to communicate with you and run turtletrading.ai.
• Accountants and legal advisers - to meet our legal obligations.
• Authorities or courts - only where the law requires it or to protect our legal rights.

Each provider is bound by contract or confidentiality obligations and may not use your data for its own purposes. We never sell, rent or trade your data, and we never share it with brokers, signal services or marketers.

International transfers

We are based in Hong Kong. Our servers and providers may be located in other countries, chosen for reliability and low latency to broker servers. Wherever your data is processed we protect it with the contractual and technical safeguards described here, and - for EU and UK customers - with recognised transfer mechanisms such as standard contractual clauses.

How long we keep data

Type of data	How long we keep it
Order, invoice and payment records	7 years (Hong Kong company and tax law)
Contact and licence details	While you are a customer, then 2 years
Support conversations	2 years after the last message
Website server logs	90 days
Data on your VPS	Deleted 30 days after hosting ends
Card verification details	Held by the payment processor only

Security measures

Encryption in transit (HTTPS) on our website and in our tools, access limited to team members who need it, two-factor authentication on administration accounts, regular backups of our own business records (never of your VPS data), and prompt security patching. No system is perfectly secure, but we take reasonable and proportionate steps to protect your data.

If something goes wrong

If a security incident affects your personal data, we will tell you and any relevant regulator without undue delay and explain what happened, what we are doing about it and what you can do.

What you can ask us to do

• Access: receive a copy of the personal data we hold about you.
• Correction: fix data that is wrong or out of date.
• Deletion: erase your data, unless we must keep it by law (for example invoices) or to defend a legal claim.
• Opt out of marketing: at any time, with immediate effect.
• Restriction or objection: ask us to limit how we use your data in certain situations.
• Portability (EU/UK): receive your data in a common machine-readable format.
• Withdraw consent: where we rely on consent, you can withdraw it at any time without affecting earlier processing.

How to make a request

Email contact@turtletrading.ai with the subject line "Privacy request" and tell us what you would like us to do. We may ask you to confirm your identity so that we do not release data to the wrong person. We respond within 30 days and in any case within the time required by law. Requests are free unless they are clearly excessive or repetitive.

Making a complaint

If you are unhappy with how we have handled your data, please contact us first and we will do our best to put it right. You also have the right to complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (pcpd.org.hk) or to the data-protection authority in your own country.

Children

Our website and services are intended for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, please tell us and we will delete it.

Business changes

If TurtleTrading.ai is sold, merged or restructured, your data may be transferred to the new owner so that the Services can continue. The new owner must respect this Privacy Commitment, and we will tell you before the transfer takes place.

Changes to this document

We may update this Privacy Commitment from time to time. The current version is always available at turtletrading.ai. For material changes we email you before they take effect.

Questions about your data, or a request to see, correct or delete it? One email is all it takes.

contact@turtletrading.ai - subject line "Privacy request"

This Privacy Commitment describes how we handle personal data. It does not change the risk warnings in our Service Terms & Conditions: trading foreign exchange on margin carries a high level of risk, and TurtleTrading.ai provides software, not investment advice.