Privacy Policy
Last updated: May 1, 2025
Thorn Fondwell Inc. ("Thorn Fondwell", "we", "us" or "our") is dedicated to safeguarding your privacy. This Privacy Policy describes how we collect, use, disclose, and protect your information when you visit our website thornfondwell-ca.live and use our AI trading platform (collectively, the "Service"). Please read this policy carefully. If you disagree with its terms, please stop using the Service.
1. Information We Collect
1.1 Data You Provide Directly
When you create an account or interact with our service, we may collect the following:
- Identity details: full name, date of birth.
- Contact information: email address, phone number, residential address.
- Financial data: broker API keys (read-only/execute), investment preferences, risk tolerance settings. We never store your full broker credentials or payment card numbers.
- Profile details: username, trading strategy preferences, notification settings.
- Communications: messages sent via support channels or email.
1.2 Automatically Collected Information
When using the service, we automatically gather certain technical details:
- IP address, browser type and version, operating system.
- Pages visited, features used, time spent, clickstream data.
- Device identifiers and mobile advertising IDs (where applicable).
- Cookie and tracking technology data (see our Cookie Policy).
1.3 Third-Party Information
We may obtain information about you from third parties such as identity verification providers, fraud prevention services, and analytics partners. We combine this with our data to improve accuracy and security.
2. How We Use Your Data
We utilize collected information to:
- Create and manage your account and deliver the service.
- Process and execute trading signals and automated orders on linked brokers.
- Personalize your experience and provide relevant market insights.
- Send transactional emails (account confirmations, trade notifications, security alerts).
- Send marketing communications where you have consented or where permitted by law.
- Detect, investigate, and prevent fraudulent or unauthorized activities.
- Comply with legal and regulatory obligations.
- Improve, test, and develop new service features using aggregated and anonymized data.
3. Legal Basis for Processing (EEA/UK Users)
If you are located in the European Economic Area or United Kingdom, we process your personal data based on the following legal grounds:
- Contract performance: to provide the service you subscribed to.
- Legitimate interests: fraud prevention, security, product enhancement.
- Legal obligation: compliance with financial regulations and tax laws.
- Consent: marketing communications and non-essential cookies (which you may withdraw anytime).
4. Sharing Your Information
We do not sell your personal data. We may share it with:
- Service providers: cloud hosting, email delivery, analytics, and customer support providers bound by confidentiality agreements.
- Connected brokers and exchanges: only the minimum API instructions needed to execute your configured strategy.
- Legal authorities: when required by law, court order, or to protect our rights.
- Business transfers: in connection with mergers, acquisitions, or asset sales, provided the acquirer honors this policy.
5. International Data Transfers
Thorn Fondwell operates globally. Your data may be transferred and processed in countries different from your own, including the United States and European Union member states. Where required, we use European Commission-approved Standard Contractual Clauses to secure cross-border data transfers.
6. Data Retention
We retain your personal data while your account is active or as necessary to provide the service. After account closure, some data is kept up to seven years to meet financial regulatory requirements. Aggregated and anonymized analytics data may be stored indefinitely.
7. Your Rights
Depending on your jurisdiction, you may have rights to:
- Access a copy of your personal data we hold.
- Correct inaccurate or incomplete data.
- Request deletion of your data ("right to be forgotten").
- Object to or restrict certain processing activities.
- Data portability — receive your data in a structured, machine-readable format.
- Withdraw consent at any time without affecting prior processing.
To exercise any of these rights, contact us at . We will respond within 30 days.
8. Security
We implement industry-standard security measures including TLS 1.3 encryption in transit, AES-256 encryption at rest, multi-factor authentication, role-based access controls, and annual third-party penetration testing. Despite these safeguards, no system is entirely secure. We encourage use of strong, unique passwords and enabling two-factor authentication.
9. Cookies
We use cookies and similar tracking technologies to operate and enhance the service. For full details, please review our Cookie Policy.
10. Children’s Privacy
Our service is not directed at individuals under 18 years old. We do not knowingly collect personal data from minors. If you believe a minor has provided us personal data, please contact us and we will promptly remove it.
11. Changes to This Policy
We may update this Privacy Policy periodically. Significant changes will be communicated via website notices or email. Continued use of the service after updates indicates acceptance of the revised policy.