Privacy Policy
In accordance with the GDPR and the Austrian Data Protection Act (DSG).
1. Controller
The controller responsible for data processing within the meaning of the GDPR is:
Wolf Company e.U.
Uferstraße 73, 2640 Gloggnitz, Austria
Email: support@tradepasscenter.com
VAT / UID number: ATU80496508
2. Subject and purpose of the app
TradePass Center is a SaaS platform for trading discipline and trade journaling. The app processes only data that the user manually enters or uploads, for account management and app functionality. There is no broker connection, no automatic broker import, no trade execution and no signal generation. No financial or investment advice is provided. Users manually enter or upload their own data and are fully responsible for their own trading decisions. Trading involves risk and can lead to financial losses.
3. Types of personal data processed
Categories of data processed:
- Account data: email address and name, password (encrypted)
- Login via email/password and Google login
- User-entered trading data, notes and journal entries
- Uploaded screenshots
- Psychology and emotion data
- Challenge data
- Weekly review data
- Language and display preferences
Legal bases: Art. 6 (1) (b) GDPR (contract performance), Art. 6 (1) (f) GDPR (legitimate interest in technical operation) and, where consent is obtained, Art. 6 (1) (a) GDPR.
4. System emails
System emails may be sent to registered users for account management (e.g. verification, password reset).
5. Hosting and external service providers
Hosting and data processing are provided via the Base44 platform (platform-as-a-service). Technically necessary service providers act as processors in accordance with Art. 28 GDPR.
6. Payment provider and Plausible Analytics
TradePass Center uses Stripe as its payment provider. Payments are processed via Stripe Checkout; TradePass Center does not store full credit card details. Stripe Tax may also be used for tax calculation. Customers must provide their billing country. Business customers may enter a VAT identification number. Depending on customer type and country, VAT may be included, charged, not charged, or treated under the reverse-charge mechanism. The final tax treatment is shown in Stripe Checkout and on the invoice. Displayed prices include VAT where applicable.
TradePass Center uses Plausible Analytics as its analytics provider to evaluate the use of the platform in a privacy-friendly way and to improve our service. This may include general page views and selected generic product or conversion events, such as registrations, pricing clicks, Pro button clicks, started trade checks, or created journal entries.
We do not send user-entered trading content, strategy names, screenshots, journal notes, emotion notes, account values, risk amounts, email addresses, or personally identifiable content to Plausible. Plausible is not used for financial profiling, not for advertising, and not for ad-network tracking.
Because TradePass Center has no broker connection, no broker data is collected either.
Analytics are used only to better understand usage, stability, and product improvement.
7. Cookies, local storage and session storage (TKG 2021)
Pursuant to Section 165 of the Austrian Telecommunications Act 2021 (TKG 2021), the app may use technically necessary cookies, local storage and session storage. These are used exclusively for login, authentication, security, language settings, session management and basic app functionality, and are required for operation.
Optional analytics, marketing cookies or tracking tools will only be activated once they are implemented and, where legally required, after appropriate consent pursuant to Section 165 TKG 2021.
8. Retention period
Data is stored for as long as the account is active. After deletion of the account, the associated data is permanently removed.
9. Your rights under the GDPR
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR)
- Withdrawal of consent given (Art. 7 (3) GDPR)
To exercise these rights, contact support@tradepasscenter.com.
10. Right to complain to the data protection authority
You have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde, DSB) if you believe that the processing of your data infringes the GDPR or the DSG.
11. Online dispute resolution and consumer information
Information on online dispute resolution and consumer notices will be added here, insofar as legally required.