Privacy Policy

1. WHO WE ARE AND WHAT THIS POLICY COVERS

1.1 Who We Are. Trading Coach LLC, a Florida limited liability company ("Trading Coach," "we," "us," or "our"), operates the website located at tradingcoach.com and its subdomains and the lessons, courses, videos, articles, blog posts, news content, note-taking tools, emails, and related services we provide (the "Services"). Trading Coach is responsible for the personal information described in this Privacy Policy and is the "controller" or "business" for that information under applicable privacy laws.

1.2 What This Policy Covers. This Privacy Policy explains how we collect, use, disclose, and protect personal information about you in connection with the Services, and the choices and rights you have. "Personal information" means information that identifies, relates to, or could reasonably be linked with you. This Privacy Policy does not cover information collected by Propfirm Compare LLC through its own platform, or by any other website or service that we do not operate, which are governed by their own privacy policies. Capitalized terms used but not defined here have the meanings given in our Terms of Service.

2. INFORMATION WE COLLECT

2.1 Information We Receive from Prop Firm Compare. You access the Services by signing in with an account provided by our affiliate Propfirm Compare LLC ("PFC"), which operates the Prop Firm Compare platform at propfirm.compare (a "PFC Account"). When you sign in, PFC shares with us information associated with your PFC Account that we need to create, maintain, and personalize your Trading Coach account, such as your name, username, email address, PFC account identifier, account status, and profile details you have chosen to include in your PFC Account (such as a profile photo), together with technical information needed to authenticate you. The specific information shared depends on the information in your PFC Account and PFC's sign-in settings. We do not receive your PFC Account password.

2.2 Information You Provide to Us. We collect information you provide directly, including:

(a) Notes — the content of personal notes you write and save in the Services;

(b) Communications — the content of messages you send us, such as support requests, feedback, and survey responses, and related contact details; and

(c) Preferences — your email preferences, content preferences, and other settings.

2.3 Information About Your Use of the Services. When you use the Services, we and our service providers automatically collect:

(a) Learning activity — the courses, lessons, videos, articles, and other Content you access, your progress and completion status, how much of a video you watch, and bookmarks or similar features you use;

(b) Device and log information — your IP address, browser type and settings, operating system, device type and identifiers, referring and exit pages, pages viewed, dates and times of access, and error and performance data;

(c) Approximate location — general location (such as city, region, or country) derived from your IP address; we do not collect precise geolocation; and

(d) Email engagement — whether you open our emails and which links you click.

2.4 Cookies and Similar Technologies. We collect some of the information described in Section 2.3 through cookies, pixels, and similar technologies, as described in Section 6.

2.5 Information from Our Affiliates and Other Sources. In addition to the sign-in information described in Section 2.1, we may receive information about you from our affiliated companies (as permitted by their privacy policies) and from service providers that help us operate, secure, and analyze the Services.

2.6 Inferences. We may derive inferences from the information described above, such as which trading topics interest you or your general level of experience, so that we can personalize the Services and our emails.

2.7 Sensitive Information. We do not intentionally collect sensitive personal information, such as government identification numbers, financial account numbers, health information, or precise geolocation. Please do not include sensitive information in your Notes or messages to us. If you do, we will use it only as necessary to store and display your Notes or respond to your message.

2.8 Payment Information. The Services are currently free, and we do not collect payment information. If we introduce paid offerings, payments will be processed by third-party payment processors, and we will update this Privacy Policy before collecting any payment information.

3. HOW WE USE INFORMATION

We use personal information for the following purposes:

(a) To provide the Services — to authenticate you through your PFC Account, create and maintain your Trading Coach account, deliver Content, save and display your Notes, track your learning progress, and remember your preferences;

(b) To personalize the Services — to recommend lessons and Content and to tailor our communications to your interests;

(c) To communicate with you — to send service communications (such as account, security, and policy notices) and to respond to your requests;

(d) For marketing — to send newsletters and information about Trading Coach and the products and services of our affiliated companies, subject to your choices under Section 7;

(e) For analytics and improvement — to understand how the Services are used and to develop and improve our Content, features, and courses;

(f) For security and integrity — to protect the Services and our users, and to detect, prevent, and investigate fraud, abuse, unauthorized access, account sharing, scraping, and violations of our Terms of Service;

(g) For legal and compliance purposes — to comply with legal obligations, respond to lawful requests and legal process, enforce our Terms of Service, and establish, exercise, or defend legal claims;

(h) In connection with business transfers — as described in Section 4.5; and

(i) With your consent — for any other purpose disclosed to you at the time we collect the information or for which you give consent.

We do not use the content of your Notes for marketing or advertising, and we do not use your Notes to train artificial intelligence models. We may create de-identified or aggregated information that does not reasonably identify you and use it for any lawful purpose. We will maintain such information in de-identified form and will not attempt to re-identify it, except as permitted by law.

4. HOW WE DISCLOSE INFORMATION

4.1 Prop Firm Compare and Our Other Affiliates. We disclose personal information to PFC and to other companies under common ownership or control with Trading Coach, including The Lab Trading US, LLC (together, our "Affiliates"), only for the following purposes: (a) to operate the PFC sign-in, keep your account information accurate and in sync, and provide customer support; (b) for security, fraud prevention, and legal compliance; and (c) to perform administrative, technical, and analytics services for us, on our behalf, under a written agreement with us. We do not disclose personal information to our Affiliates for their own marketing or other independent purposes. Trading Coach itself may send you information about our Affiliates' products and services, as described in Section 3(d). We do not disclose the content of your Notes or your Video Viewing Information (defined in Section 5) to our Affiliates, except that Affiliate personnel who operate or support the Services for us under clause (c) may access them only as needed to do so.

4.2 Service Providers. We disclose personal information to vendors that process it on our behalf to help us operate the Services, under contracts that require them to protect it and use it only to provide services to us. These include providers of hosting and cloud infrastructure, video hosting and streaming, email delivery and marketing (such as Klaviyo), website analytics (such as Google Analytics), customer support, security, and information technology services.

4.3 Legal Requirements and Protection. We may disclose personal information if we believe in good faith that doing so is necessary to (a) comply with applicable law, regulation, subpoena, court order, or other legal process, or with an enforceable government request; (b) enforce our Terms of Service or investigate potential violations; (c) detect, prevent, or address fraud, security, or technical issues; or (d) protect the rights, property, or safety of Trading Coach, our users, our Affiliates, or the public, as permitted by law.

4.4 With Your Consent or at Your Direction. We may disclose personal information to third parties when you direct us to do so or consent to the disclosure.

4.5 Business Transfers. We may disclose or transfer personal information in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or part of our business or assets, including during due diligence. Any acquirer will be required to handle the personal information it receives consistently with this Privacy Policy, unless you are notified otherwise and, where required by law, you consent.

4.6 De-identified and Aggregated Information. We may disclose de-identified or aggregated information that does not reasonably identify you for any lawful purpose.

4.7 No Sale of Personal Information; No Targeted Advertising. We do not sell personal information, for money or any other valuable consideration, and we do not share or process personal information for cross-context behavioral advertising or targeted advertising. We do not place advertising pixels on the Services. If this changes, we will update this Privacy Policy before the change takes effect and give you any opt-out rights required by law, including honoring Global Privacy Control signals.

5. VIDEO VIEWING INFORMATION

5.1 What It Is. "Video Viewing Information" means information that identifies you as having requested or obtained specific video content through the Services, such as the titles of the video lessons you have watched.

5.2 How We Protect It. We do not knowingly disclose Video Viewing Information to any third party, including our Affiliates, except: (a) to service providers as necessary to deliver video content you request and to process your requests; (b) as permitted by 18 U.S.C. § 2710(b)(2), including to a law enforcement agency under a warrant, grand jury subpoena, or qualifying court order, or under a court order in a civil proceeding after you receive notice and an opportunity to contest it; (c) in connection with a business transfer described in Section 4.5; or (d) with your informed, written consent, given separately from our Terms of Service and this Privacy Policy ("Video Sharing Consent"). Unless you have given Video Sharing Consent, we configure our analytics and email marketing tools so that they do not receive the titles, identifiers, or web addresses of specific videos you request or watch together with information that identifies you.

5.3 Lesson Topics in Our Emails. We may use the general subject matter of lessons you have watched (for example, "futures" or "options"), but not the titles of specific videos, to tailor marketing emails we send you about our own Services. You can turn this off at any time in your email preferences, where available, or by emailing privacy@tradingcoach.com.

5.4 Video Sharing Consent. If we ask for Video Sharing Consent, we will explain what will be shared, with whom, and why. Giving it is optional and is never a condition of using the Services. You may choose to give consent at the time a particular disclosure is sought, or in advance for a set period of no more than two years. Advance consent ends at the end of that period or when you withdraw it, whichever comes first. You may withdraw consent at any time, either for a particular disclosure or for all future disclosures, through your account settings or by emailing privacy@tradingcoach.com.

6. COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES

6.1 What We Use. We and our service providers use cookies, pixels, local storage, and similar technologies for the following purposes:

(a) Essential — to sign you in through your PFC Account, keep your session secure, remember your settings, and operate the Services. The Services will not work properly without these.

(b) Analytics — we use Google Analytics to understand how visitors use the Services, such as which pages are visited, how long visitors stay, and what device and browser they use. We configure Google Analytics so that it does not receive your name, email address, or account identifier, and we have not enabled Google Analytics advertising features or linked it to Google advertising products. You can learn how Google uses this information at policies.google.com/technologies/partner-sites, and you can opt out of Google Analytics by installing the browser add-on available at tools.google.com/dlpage/gaoptout.

(c) Email engagement — our email service provider, Klaviyo, uses pixels and tracked links in our emails to tell us whether an email was opened and which links were clicked, which helps us measure and improve our communications. Klaviyo's tracking technologies do not operate on video lesson pages. As described in Section 5, these tools are configured not to receive Video Viewing Information that identifies you unless you have given Video Sharing Consent.

(d) Video delivery — our video hosting and streaming providers may use cookies or similar technologies as needed to deliver video and measure playback performance.

6.2 Your Choices. Most browsers let you block or delete cookies through their settings. If you block essential cookies, you may not be able to sign in or use the Services. You can limit email engagement tracking by disabling automatic image loading in your email client. Where required by law (for example, for visitors in the European Economic Area or the United Kingdom), we will ask for your consent before placing non-essential cookies.

6.3 Do Not Track and Global Privacy Control. Some browsers send "Do Not Track" signals. Because there is no common industry standard for these signals, the Services do not currently respond to them. Because we do not sell personal information or share it for targeted advertising, there is currently nothing for a Global Privacy Control or similar opt-out preference signal to opt you out of; if that changes, we will honor such signals as required by law.

6.4 Tracking Across Other Sites. Other than the service providers described in this Section 6, we do not knowingly permit third parties to collect personal information about your online activities over time and across different websites when you use the Services.

7. YOUR CHOICES

7.1 Marketing Emails. You can unsubscribe from our marketing emails at any time by using the unsubscribe link in any marketing email or by emailing privacy@tradingcoach.com. We will continue to send you service communications while you have an account.

7.2 Affiliate Marketing. We do not disclose your personal information to our Affiliates for their own marketing. Emails about our Affiliates' products and services come from Trading Coach and are marketing emails that you can stop as described in Section 7.1.

7.3 Video Sharing Consent and Lesson Topics. You can withdraw any Video Sharing Consent at any time, as described in Section 5.4, and can stop us from using lesson topics to tailor our emails, as described in Section 5.3.

7.4 Your Notes and Account. You can edit or delete your Notes in the Services. You can ask us to delete your Trading Coach account and associated information by emailing privacy@tradingcoach.com. Deleting your Trading Coach account does not delete your PFC Account; to delete your PFC Account, contact PFC as described in its privacy policy. Deleting your PFC Account will end your access to the Services but does not by itself delete the information we hold, so please also contact us if you want that information deleted.

8. YOUR PRIVACY RIGHTS

8.1 Your Rights. Depending on where you live, and subject to exceptions provided by law, you may have the right to:

(a) know whether we process your personal information and access it;

(b) correct inaccuracies in your personal information;

(c) delete your personal information;

(d) obtain a copy of your personal information in a portable format;

(e) opt out of the sale of personal information, targeted advertising, and certain profiling (we do not engage in these activities);

(f) withdraw consent you have given; and

(g) not be discriminated against for exercising your privacy rights.

Even if the law where you live does not give you these rights, you may contact us to request access to or deletion of your personal information, and we will consider your request.

8.2 How to Submit a Request. To submit a request, email privacy@tradingcoach.com with the subject line "Privacy Request." To protect your information, we will verify your request, usually by confirming that it comes from, or can be confirmed through, the email address associated with your account. We may ask for additional information if needed to verify your identity. You may use an authorized agent to submit a request on your behalf where permitted by law; we may require the agent to provide your signed permission and may require you to verify your identity directly with us. We will respond within the time required by applicable law (generally 45 days, which may be extended where permitted).

8.3 Appeals. If we decline to act on your request, you may appeal by emailing privacy@tradingcoach.com with the subject line "Privacy Request Appeal" within a reasonable time after receiving our decision. We will respond to your appeal within the time required by applicable law. If we deny your appeal, you may contact the attorney general or privacy regulator in your state.

8.4 California Residents. This Section 8.4 applies to California residents to the extent the California Consumer Privacy Act, as amended ("CCPA"), applies to us.

(a) Categories of personal information. In the past 12 months, we have collected the following categories of personal information described in the CCPA, from the sources described in Section 2, for the purposes described in Section 3, and have disclosed them for business purposes to the categories of recipients shown:

(b) Sale and sharing. We have not sold personal information or shared it for cross-context behavioral advertising in the past 12 months, and we have no actual knowledge of selling or sharing the personal information of consumers under 16 years of age.

(c) Sensitive personal information. We do not intentionally collect sensitive personal information. If you choose to include sensitive personal information in your Notes or messages, we use it only to provide the Services you request, as permitted by the CCPA, and not to infer characteristics about you.

(d) Retention. We retain each category of personal information as described in Section 9.

(e) Shine the Light. We do not disclose personal information to third parties, including our Affiliates, for their direct marketing purposes. California residents may send requests under Civil Code Section 1798.83 to privacy@tradingcoach.com.

(f) No financial incentives. We do not offer financial incentives or price or service differences in exchange for personal information.

8.5 Residents of Other U.S. States. Residents of states with comprehensive consumer privacy laws (including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) may have the rights described in Section 8.1, to the extent those laws apply to us. We do not sell personal data, process personal data for targeted advertising, or engage in profiling in furtherance of decisions that produce legal or similarly significant effects. We do not process sensitive data without consent where consent is required by law.

8.6 Nevada Residents. We do not sell covered information as defined in Nevada Revised Statutes Chapter 603A. Nevada residents may submit a request directing us not to sell covered information by emailing privacy@tradingcoach.com.

8.7 European Economic Area, United Kingdom, and Switzerland. If you are located in the European Economic Area, the United Kingdom, or Switzerland, the following also applies:

(a) Controller. Trading Coach LLC is the controller of your personal information. You can contact us using the details in Section 15.

(b) Legal bases. We process your personal information (i) to perform our contract with you, including providing the Services, your account, and your Notes; (ii) for our legitimate interests in operating, securing, analyzing, and improving the Services, operating the PFC sign-in with our Affiliates, sending marketing to existing users where permitted, and establishing, exercising, or defending legal claims, where those interests are not overridden by your rights; (iii) with your consent, including for marketing where consent is required, non-essential cookies, and Video Sharing Consent; and (iv) to comply with our legal obligations.

(c) Your rights. You have the right to access, rectify, erase, restrict, and object to the processing of your personal information, the right to data portability, and the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. You have an absolute right to object to direct marketing. You may also lodge a complaint with your local data protection authority (in the United Kingdom, the Information Commissioner's Office; in Switzerland, the Federal Data Protection and Information Commissioner). We will respond to requests within one month, which may be extended by two further months where permitted.

(d) International transfers. We are based in the United States and process personal information there. When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to countries that have not been found to provide an adequate level of protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (with the UK Addendum or Swiss amendments, as applicable), or on a recipient's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where available. You may request more information about these safeguards by contacting us.

(e) Right to object; other information. You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests, including personalization of the Services and our emails, and you may object at any time to direct marketing. Your PFC Account information is required to create your account and use the Services; other information is optional. We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you.

9. HOW LONG WE KEEP INFORMATION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, considering the amount, nature, and sensitivity of the information, the risk of harm from unauthorized use or disclosure, the purposes for which we process it, and our legal obligations. In general:

(a) Account information is kept while your account is active and for a reasonable period afterward to handle any questions, disputes, or legal obligations;

(b) Notes are kept until you delete them or your account is deleted. Deleted Notes are removed from our active systems promptly and from backups in the ordinary course of our backup cycle;

(c) Learning activity and log information is kept for as long as needed to provide, secure, and improve the Services. Information that identifies you as having requested or watched specific videos is deleted or de-identified as soon as practicable, and no later than one year after it is no longer needed for the purpose for which it was collected (for example, one year after your account is deleted), unless there is a pending request or order for access to it. Google Analytics is configured to delete user-level and event-level data 14 months after collection; aggregated reports that do not identify you may be kept longer;

(d) Marketing records, including unsubscribe requests, are kept as long as needed to honor your choices; and

(e) Communications with us are kept as long as needed to respond and to maintain records of our interactions.

We may keep information longer where required by law or to establish, exercise, or defend legal claims.

10. SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption of information in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee the security of your information. You are responsible for keeping your PFC Account credentials confidential. If we learn of a security incident affecting your personal information, we will notify you and others as required by applicable law.

11. CHILDREN

The Services are intended only for adults aged 18 and older and are not directed to children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will delete it. If you believe that a minor has provided us with personal information, please contact us at privacy@tradingcoach.com.

12. INTERNATIONAL USERS

The Services are operated from the United States. If you use the Services from outside the United States, your information will be transferred to, stored, and processed in the United States and other countries where our service providers operate, whose data protection laws may differ from those where you live.

13. THIRD-PARTY SERVICES

The Services may link to or mention third-party websites and services, including PFC, prop firms, brokers, and trading platforms. This Privacy Policy does not apply to them, and we are not responsible for their privacy practices. Please review their privacy policies before providing them with information.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we do, we will post the updated version in the Services and change the "Last Updated" date above. If we make a material change, we will notify you by email to the address associated with your account or by a notice in the Services before the change takes effect. If a change materially expands how we use or disclose personal information we have already collected, we will obtain your consent where required by law.

15. CONTACT US

If you have questions about this Privacy Policy or our privacy practices, or want to exercise your rights, contact us at:

Trading Coach LLC

Attn: Privacy

7901 4th St N, Ste 300

St. Petersburg, FL 33702

privacy@tradingcoach.com