This policy explains what personal data CleverTrade collects, why, and your rights. It applies to our public website www.clevertrade.ai, the app app.clevertrade.ai, api.clevertrade.ai, our emails and, once released, admin.clevertrade.ai.
Who we are
The data controller is CleverTrade Ltd, 25 Sveti Naum blvd, Sofia, Bulgaria, company registration number 111111111 ("CleverTrade", "we").
- Contact for privacy questions: contact@clevertrade.ai.
- Data protection officer: we haven't appointed a data protection officer. For any privacy question, contact us at contact@clevertrade.ai.
Current phase
CleverTrade is in an early-access phase:
- anyone aged 18 or over can create an account on
app.clevertrade.ai; - payments are simulated (mock): we never collect or charge real card details;
- market data and AI output are simulated test data.
We will update this policy before the service takes real payments.
Data we collect
| Category | What | Source |
|---|---|---|
| Account | Email address, name, phone number (optional), password (stored only as a secure hash), account status, role | You |
| Google sign-in | If you use "Continue with Google": your Google account ID, email, name and whether the email is verified. We don't get your Google password or contacts | |
| Subscription and (mock) payments | Plan, trial and billing dates, subscription history, simulated payment records: the card brand and last 4 digits you entered. No full card number or security code is stored | You, the service |
| Security and login records | Date and time, IP address, browser (user agent), sign-in method and result of each login attempt; session records | Your device |
| Activity | The days you used the service (one record per day, for usage statistics) | The service |
| Your content and settings | Favorite stocks, home layout, chart layouts, notification preferences, recent searches, Ask Clever conversations and feedback | You |
| Communications | Emails we send you and whether delivery failed (bounces and complaints) | Our email provider (Resend) |
| Analytics (only with consent) | Pages and features used, device and browser type, approximate country, linked to a pseudonymous ID that can't be traced back to you without our secret key. Never your name, email or what you type | Google Analytics, see the Cookie policy |
| Contact form and support | Your name, email address, phone number (optional) and message when you use the contact form on www.clevertrade.ai/contact, or what you write when you email us. We don't store your IP address or browser with a contact message |
You |
We don't knowingly collect data from people under 18.
Why we use it and our legal bases
| Purpose | Legal basis (EU/UK GDPR) |
|---|---|
| Create and run your account, provide the service, the trial and the subscription | Performance of a contract |
| Send service emails (verification, password reset, receipts, trial and billing notices, price changes) | Performance of a contract |
| Send "Important market news" emails | Your consent (opt-in in Notification settings; unsubscribe anytime) |
| Answer your contact-form messages and emails | Legitimate interests (answering your request), or steps you ask for before entering a contract |
| Keep the service secure: login records, rate limiting, spam protection of the contact form, abuse prevention | Legitimate interests (security) |
| Understand and improve the service with analytics | Your consent (cookie banner) |
| Business statistics from our own records (e.g. signups, active users) | Legitimate interests (running the business) |
| Comply with legal obligations and handle legal claims | Legal obligation / legitimate interests |
We don't sell your personal data and we don't use it for advertising. We make no decisions with legal or similarly significant effects based solely on automated processing.
AI features
Ask Clever (Pro) sends the messages of the current conversation, and the stock tickers it needs, to our AI module to generate an answer. We don't send your name, email or account ID with them. Conversations are stored in your account so you can see your history.
In this phase the AI module is our own simulated service. Before a third-party AI provider is connected, we will update this policy and name it.
Who we share data with
We use these service providers (processors), bound by data processing terms:
| Provider | Service | Location |
|---|---|---|
| Amazon Web Services (AWS) | Hosting and database | EU (Ireland, eu-west-1) |
| Resend (Resend, Inc.) | Sends our emails (account, billing and alert emails), delivers contact-form messages to our mailbox, and reports delivery failures | USA |
| Our mailbox hosting provider | Hosts the contact@clevertrade.ai mailbox that receives the messages you send us | Ask us at contact@clevertrade.ai |
| "Continue with Google" sign-in; Google Analytics (only with consent) | Global, including the USA |
We may also disclose data when the law requires it, or to protect our rights. If we sell or reorganise the business, data may pass to the new owner under this policy.
International transfers
Our hosting is in the EU. Google and Resend may process data in the USA.
- Transfer basis: the EU–US Data Privacy Framework where the provider is certified, and otherwise the European Commission's Standard Contractual Clauses.
- UK: the UK Extension / International Data Transfer Addendum.
- You can ask us for a copy of the safeguards we rely on at contact@clevertrade.ai.
How long we keep data
| Data | Retention |
|---|---|
| Account data, settings, favorites | While your account exists; deleted within 30 days after you ask us to delete the account |
| Subscription and (mock) payment records | While your account exists. Once real payments start, invoices and payment records are kept as long as Bulgarian tax and accounting law requires, even after the account is deleted |
| Login records incl. IP address | 12 months |
| Contact-form messages | 12 months, then deleted automatically |
| Contact-form rate limiting (IP address, in memory only) | Up to 24 hours |
| Daily activity records | 13 months, then only aggregated totals |
| Ask Clever conversations | 90 days, then deleted automatically |
| In-app notifications | 90 days |
| Server logs (including IP addresses) | Up to 30 days |
| Google Analytics event data | 2 months (cookies: 13 months) |
| Consent choice | 12 months |
| Backups | Database backups on our server: 7 days. Additional backups in our cloud provider's console are kept for a limited period and then deleted automatically |
Your rights
Depending on where you live, you have the right to:
- access your data and get a copy;
- correct it;
- delete it;
- restrict or object to processing (including to processing based on legitimate interests);
- data portability;
- withdraw consent at any time (for analytics in Cookie settings, linked in the footer of every page and at
www.clevertrade.ai/cookie-settings, for market-news emails in Notification settings or with the unsubscribe link). Withdrawing doesn't affect processing that happened before.
To exercise a right, email contact@clevertrade.ai from the address of your account. We answer within one month. In this phase, data export and account deletion are handled manually by our support team.
You can also complain to a data protection authority. Our lead authority is the Bulgarian Commission for Personal Data Protection (cpdp.bg); you can also contact the authority where you live.
California residents: you have the rights to know, delete, correct and opt out of "sale" or "sharing". We don't sell or share personal information as those terms are defined. Residents of other US states with similar laws have comparable rights; contact us to use them. We won't discriminate against you for using your rights.
Security
We protect your data with:
- encryption in transit (HTTPS);
- hashed passwords;
- short-lived sessions with secure cookies;
- network isolation of internal services;
- access limited to authorised staff.
No system is perfectly secure. If a breach affects you, we'll notify you as the law requires.
Changes to this policy
When we make material changes, we'll tell you by email or in the app before they take effect. The "Last updated" date shows the current version.
Contact
CleverTrade Ltd, 25 Sveti Naum blvd, Sofia, Bulgaria · contact@clevertrade.ai · contact form: www.clevertrade.ai/contact