Privacy Policy
Last updated: 4 April 2026
1. Who We Are
EasySwing.trading is operated by easyswing.trading, a sole proprietorship registered in the Netherlands under Dutch law ("we", "us", "our"). We are the data controller responsible for your personal data.
Contact us at: privacy@easyswing.trading
2. What Personal Data We Collect
We collect the following categories of personal data:
| Category | Examples | Source |
|---|---|---|
| Account data | Email address, name, profile photo | You, via Clerk authentication |
| Usage data | Pages visited, features used, timestamps | Automatically collected |
| Behavioral analytics | Clicks, scrolls, mouse movements, session recordings, heatmaps | Microsoft Clarity |
| Technical data | IP address, browser type, device info | Automatically collected |
| Preferences | Scanner settings, watchlist, journal entries | You |
| Payment data | Subscription plan, billing status | Clerk Billing (we do not store card numbers) |
| Waitlist data | Email address, interest category | Clerk (authentication provider) |
3. Legal Basis for Processing
We process your personal data on the following legal grounds under GDPR Article 6:
| Processing activity | Legal basis |
|---|---|
| Account creation and authentication | Performance of a contract (Art. 6(1)(b)) |
| Providing the screener service | Performance of a contract (Art. 6(1)(b)) |
| Billing and subscription management | Performance of a contract (Art. 6(1)(b)) |
| Telegram alerts (opt-in) | Consent (Art. 6(1)(a)) |
| Waitlist email communications | Consent (Art. 6(1)(a)) |
| Security logging and fraud prevention | Legitimate interest (Art. 6(1)(f)) |
| Analytics and product improvement | Legitimate interest (Art. 6(1)(f)) |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
4. How We Use Your Data
- To create and manage your account
- To provide the EasySwing stock screening and execution service
- To process payments and manage your subscription
- To send Telegram notifications you have opted into
- To manage waitlist access (with your consent)
- To improve the platform based on aggregate usage analytics
- To detect and prevent security issues and abuse
- To comply with legal obligations
5. Third Parties We Share Data With
We share personal data with the following third-party service providers, each acting as a data processor or joint controller:
| Provider | Purpose | Location | Safeguard |
|---|---|---|---|
| Clerk, Inc. | Authentication, user management, billing | United States | Standard Contractual Clauses (SCCs) |
| Cloudflare, Inc. | Infrastructure, CDN, Workers, D1 database | United States / Global edge | SCCs + Cloudflare DPA |
| Alpaca Securities LLC | Market data, brokerage order execution (user-linked only) | United States | SCCs; user connects their own Alpaca account |
| Financial Modeling Prep | Market data and financial data | United States | SCCs; no personal data transferred |
| Telegram Messenger | Alert delivery (opt-in only) | United States / Dubai | User-initiated, consent-based |
| Microsoft Corporation (Clarity) | Behavioral analytics — session recordings, heatmaps, user interaction insights | United States | SCCs + Microsoft DPA; see Microsoft Privacy Statement |
| Google LLC (Google Tag Manager) | Tag management — loads analytics and measurement tags | United States | SCCs + Google DPA; see Google Privacy Policy |
We do not sell your personal data to any third party. We do not share your data with advertisers.
Microsoft Clarity: We partner with Microsoft Clarity to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve our products and services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of features and online activity. Additionally, we use this information for site optimisation and fraud/security purposes. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
Google Tag Manager: We use Google Tag Manager to manage analytics tags on our website. GTM may set cookies and collect anonymised usage data to help us understand site performance. For more information, visit the Google Privacy Policy.
Cross-border transfers: Some of the above providers are based in the United States. Transfers to the US are protected by Standard Contractual Clauses (SCCs) adopted by the European Commission, or by the recipient's certification under the EU–US Data Privacy Framework where applicable.
6. Data Retention
| Data category | Retention period |
|---|---|
| Account data | For the duration of your account + 90 days after deletion request |
| Journal and trade records | For the duration of your account + 90 days |
| Server logs | 30 days (rolling) |
| Waitlist signups | Managed by Clerk — see their privacy policy |
| Billing records | 7 years (Dutch tax law requirement) |
7. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights:
- Right of access (Art. 15): Request a copy of the personal data we hold about you.
- Right to rectification (Art. 16): Request correction of inaccurate data.
- Right to erasure (Art. 17): Request deletion of your personal data ("right to be forgotten").
- Right to restriction (Art. 18): Request that we restrict processing in certain circumstances.
- Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
- Right to object (Art. 21): Object to processing based on legitimate interest, including profiling.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting prior processing.
To exercise any of these rights, email us at privacy@easyswing.trading. We will respond within 30 days. We may ask you to verify your identity before processing your request.
Right to lodge a complaint: You have the right to file a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens (AP), if you believe your data has been processed unlawfully.
8. Cookies
We use cookies and similar tracking technologies. Functional cookies are required for the service to operate (e.g., Clerk authentication session). Analytics and preference cookies are optional and require your consent.
See our Cookie Policy for full details on which cookies we use and how to manage them.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. All data is transmitted over HTTPS. Our Cloudflare Workers infrastructure provides DDoS protection and edge-level security.
No system is 100% secure. If you discover a security issue, please report it responsibly to privacy@easyswing.trading.
10. Children
EasySwing is not intended for children under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify registered users by email of material changes. Continued use of EasySwing after the effective date constitutes acceptance of the updated policy. The date at the top of this page reflects the most recent update.
12. Contact
For any privacy-related queries:
easyswing.trading
Amsterdam, Netherlands
privacy@easyswing.trading