Privacy Policy
Last updated: April 4, 2026
1. Who We Are
MasterTrading.io ("MasterTrading," "we," "our," or "us") is operated by Reignite Ventures LTD, a company registered in England and Wales.
- Registered address: 167–169 Great Portland Street, 5th Floor, London, W1W 5PF
- Company number: 14288091
- Data controller: Reignite Ventures LTD
- Contact email: hello@mastertrading.io
We are the data controller for the personal data we collect through MasterTrading. This means we decide how and why your personal data is processed. This Privacy Policy explains what data we collect, why, how we use it, who we share it with, and what rights you have.
2. What Data We Collect
Account Information
When you create an account, we collect:
- Full name
- Email address
- Password (stored in hashed form — we never see your plain-text password)
Payment Information
Subscription payments are processed by Stripe. We do not store your full credit or debit card number. Stripe acts as both a data processor (on our instructions) and an independent data controller (for fraud prevention, anti-money laundering, and regulatory compliance). See Stripe's privacy policy for details.
Special Category Data (Sensitive Personal Data)
MasterTrading is an AI-powered trading psychology platform. AI analysis of your emotional and psychological data is fundamental to how the service works — it is not an optional add-on. To provide our core service, we process data that UK GDPR classifies as special category data under Article 9. This includes:
- Emotional and psychological state data — how you're feeling before, during, and after trading sessions
- Mood and sentiment records — tracked over time to identify patterns
- Journal entries — your personal reflections on trading psychology
- EMDR-inspired session records — bilateral stimulation exercises and emotional processing data
- Cognitive distortion assessments — patterns in thinking that affect your trading
- AI-generated psychological insights — personalised analysis produced by our AI system based on your data
We only process this data with your explicit consent, which you provide when you create your account. Because AI-powered analysis is integral to the MasterTrading service, this consent is required to use the platform. If you wish to withdraw your consent, you may do so at any time — however, as the service cannot function without this processing, withdrawal of consent will result in the closure of your account and deletion of your data within 30 days. See Section 9 for details on your rights.
Trading and Performance Data
If you use the trade analytics features of MasterTrading, we also collect:
- Trade execution records (entry price, exit price, P&L, timestamps)
- Imported trading data from CSV files
- Broker account identifiers you choose to enter
- Performance metrics, behaviour tags, and strategy labels
This is standard personal data — not special category data under UK GDPR. It is processed on the basis of contract performance (Article 6(1)(b)) as it is necessary to deliver the analytics features of the service.
Usage and Technical Data
We automatically collect certain technical data when you use MasterTrading:
- IP address
- Browser type and version
- Device type and operating system
- Pages visited and features used
- Session duration and interaction patterns
3. How and Why We Use Your Data (Lawful Bases)
Under UK GDPR, we must have a lawful basis for each type of processing. Here is how we use your data and the legal basis for each:
| Purpose | Lawful Basis |
|---|---|
| Creating and managing your account | Contract performance (Article 6(1)(b)) |
| Processing subscription payments via Stripe | Contract performance (Article 6(1)(b)) |
| Storing and analysing your trade records and performance data | Contract performance (Article 6(1)(b)) |
| Processing special category data and AI-powered analysis (emotional, psychological, journal, EMDR, AI insights) | Explicit consent (Article 6(1)(a) + Article 9(2)(a)) |
| Automated profiling and AI coaching | Explicit consent (Article 6(1)(a) + Article 22) |
| Improving the platform using anonymised and aggregated data | Legitimate interest (Article 6(1)(f)) |
| Sending essential service communications (security alerts, billing) | Contract performance (Article 6(1)(b)) |
| Analytics (understanding how users interact with the platform) | Consent via cookie banner (Article 6(1)(a)) |
| Preventing fraud and ensuring platform security | Legitimate interest (Article 6(1)(f)) |
| Complying with legal obligations (tax, accounting, law enforcement requests) | Legal obligation (Article 6(1)(c)) |
4. AI-Powered Analysis and Automated Profiling
MasterTrading uses artificial intelligence (powered by Anthropic's Claude) to analyse your journal entries, emotional patterns, and session data. This produces personalised psychological insights, coaching recommendations, and identifies cognitive distortions that may affect your trading. AI-powered analysis is the foundation of the MasterTrading service — it is not an optional feature.
Under UK GDPR Article 22, you have specific rights regarding automated profiling:
- Right to human review: You can request that a human reviews any AI-generated insight or recommendation by contacting us
- Right to understand: You can ask us to explain how any particular AI output was generated
- Right to withdraw consent: You can withdraw your consent to AI processing at any time. Because AI analysis is integral to the service, this will result in closure of your account and deletion of your data within 30 days
To exercise any of these rights, contact us at hello@mastertrading.io or use the consent withdrawal option in Settings → Privacy.
5. Who We Share Your Data With
We use a limited number of carefully chosen third-party service providers to operate MasterTrading. Each has a signed Data Processing Agreement (DPA) in place. We never sell your personal data.
Processors That Handle Special Category Data
| Provider | Purpose | Location |
|---|---|---|
| Supabase | Database hosting — stores all user data including journals, emotional records, and session data | United States (EU SCCs + UK Addendum in place) |
| Anthropic | AI engine — processes journal entries and emotional data to generate insights and coaching | United States (EU SCCs + UK Addendum in place) |
Processors That Handle Standard Personal Data Only
| Provider | Purpose | Location |
|---|---|---|
| Stripe | Payment processing (also acts as independent controller for fraud/AML) | United States (Data Privacy Framework certified) |
| Vercel | Website hosting and content delivery | United States (EU SCCs + UK IDTA in place) |
| PostHog | Product analytics (no special category data — subject to your cookie consent) | United States (EU SCCs + UK SCCs in place) |
| Resend | Transactional email delivery | United States (EU SCCs + UK SCCs in place) |
| Sentry | Error monitoring and application stability (no special category data) | United States (Data Privacy Framework + EU SCCs + UK Addendum) |
Vercel and Sentry are contractually prohibited from processing special category data. Our architecture is designed so that sensitive data (journals, emotional records, session data) flows directly from your browser to Supabase and never passes through Vercel's servers or Sentry's error tracking.
6. International Data Transfers
Reignite Ventures LTD is based in the United Kingdom. Several of our processors are based in the United States, which means your personal data is transferred outside the UK. To ensure your data remains protected, we rely on the following safeguards:
- EU Standard Contractual Clauses (SCCs) — Commission Implementing Decision 2021/914, Module 2 (controller-to-processor)
- UK International Data Transfer Addendum (IDTA) — ICO's approved addendum (B1.0) applied on top of the EU SCCs
- EU-US Data Privacy Framework — where our processor is certified (Stripe, Sentry)
- UK Extension to the EU-US Data Privacy Framework — where applicable
7. Data Retention
We keep your data only as long as necessary:
- Active account: Your data is retained for as long as your account is active
- After account deletion or consent withdrawal: Personal data and special category data are permanently deleted within 30 days
- Consent records: Audit logs of when you granted or withdrew consent are retained for 6 years after your last interaction (as evidence of lawful processing)
- Financial records: Payment and billing data is retained for 7 years as required by UK tax law (HMRC)
- Anonymised analytics: Aggregated, non-identifiable data may be retained indefinitely for platform improvement
Because AI-powered analysis is integral to the service, withdrawing consent for special category data processing triggers account closure. Your data will be deleted within 30 days of withdrawal.
8. Data Security
We implement appropriate technical and organisational measures to protect your data:
- All data is encrypted in transit using TLS 1.2+
- Data is encrypted at rest using AES-256
- Passwords are hashed using bcrypt — we never store plain-text passwords
- Row-level security (RLS) on our database ensures only you can access your data
- Access to production systems is restricted to essential personnel only
- Our processors maintain SOC 2 Type 2, PCI DSS Level 1, and/or equivalent certifications
While we implement strong security measures, no system can guarantee 100% security. You are responsible for keeping your login credentials confidential.
9. Your Rights Under UK GDPR
You have the following rights in relation to your personal data. You can exercise most of these directly from your account settings, or by contacting us at hello@mastertrading.io .
- Right of access (Article 15) — Request a copy of all personal data we hold about you
- Right to rectification (Article 16) — Correct any inaccurate data we hold about you
- Right to erasure (Article 17) — Request deletion of your personal data (you can delete your account from Settings)
- Right to restriction (Article 18) — Ask us to temporarily stop processing your data
- Right to data portability (Article 20) — Receive your data in a structured, machine-readable format
- Right to object (Article 21) — Object to processing based on legitimate interests
- Right to withdraw consent (Article 7(3)) — Withdraw your consent for data processing at any time via Settings → Privacy. Because AI-powered analysis is integral to the service, consent withdrawal will result in account closure and data deletion within 30 days. Withdrawal does not affect the lawfulness of processing that occurred before you withdrew.
- Right to human review of automated decisions (Article 22) — Request that a human reviews any AI-generated insight or recommendation
- Right to lodge a complaint — If you're unhappy with how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO)
We will respond to all rights requests within one month. In complex cases, we may extend this by a further two months, and we'll let you know if that's the case.
10. Cookies
We use essential cookies to keep you logged in and maintain your session. We also use analytics cookies with your consent. You can manage your cookie preferences at any time using the cookie banner or by visiting our Cookie Policy for full details on each cookie we use.
11. Children's Privacy
MasterTrading is not intended for anyone under 18 years of age. We do not knowingly collect personal data from minors. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.
12. Data Breaches
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to you, we will also notify you directly without undue delay, explaining what happened, what data was affected, and what steps we are taking.
13. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes — particularly to how we process special category data or to the processors we use — we will notify you via email and/or an in-app notification at least 30 days before the changes take effect. Continued use of MasterTrading after notification constitutes acceptance of the updated policy.
14. Contact Us and Complaints
If you have any questions about this Privacy Policy, want to exercise your rights, or have a concern about how we handle your data:
Email: hello@mastertrading.io
Post: Reignite Ventures LTD, 167–169 Great Portland Street, 5th Floor, London, W1W 5PF
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office:
Information Commissioner's Office (ICO)
Website:
ico.org.uk/make-a-complaint
Telephone: 0303 123 1113