Privacy Policy

1. Introduction

SIWAI ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our web-based trading terminal service (the "Service").

By using our Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, do not use our Service.

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

• Email address
• Password (encrypted and hashed)
• Subscription plan information

2.2 Brokerage API Keys

Your API keys for Interactive Brokers and Hyperliquid are encrypted and stored locally in your browser. They never leave your device and are never transmitted to our servers. We operate a zero-knowledge architecture where we cannot access your trading credentials.

2.3 Usage Data

We may collect information about how you access and use the Service, including:

• Feature usage patterns
• Time spent in the logged-in app, last session length, in-app tabs opened, and how many charts are opened, stored on your account
• Time spent and last session length on the landing page, stored on the landing-visit record
• How far you scrolled on the landing page (0% hero only, 100% footer)
• How much of the landing demo video played while on screen (0–100%)
• Whether the pricing section came into view, and which signup CTAs you clicked
• Each visit to the pricing page while signed in, with trial status at that moment (trialing, expired, subscribed, or none), stored on your account
• When you first opened a chart in the app
• Error logs and performance data
• Browser type and version
• The referring website (when the browser provides it), landing-page URL, IP address, approximate location, device and browser details, and email if you later create an account. We keep signup IP on the account to help detect repeated free trials

2.4 Browser Storage (localStorage and sessionStorage)

We use your browser's localStorage and sessionStorage to store data locally on your device, including:

• User preferences (theme, active view, portfolio view)
• Watchlist, portfolio, and broker account configurations
• Cache data for faster loading (screener assets, patterns, news, price data)
• Session timestamps for analytics on the landing page
• First-visit landing URL and referring website for landing-page analytics; the referring website is also saved on your account at signup

This data remains on your device and is not transmitted to our servers except where necessary for the Service (e.g., syncing portfolio with your account). You can clear it via your browser settings.

2.5 Payment Information

Payment processing is handled by Stripe. We do not store your credit card information. Stripe processes payments in accordance with their privacy policy and PCI-DSS compliance standards.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process your subscription and manage your account
• Send you service-related communications
• Respond to your inquiries and provide customer support
• Detect and prevent fraud or abuse
• Understand which websites send visitors to SIWAI
• Comply with legal obligations

4. Data Storage and Processing

4.1 Service Providers

We use the following third-party services:

• Supabase: User authentication and database storage (hosted in compliance with GDPR)
• Stripe: Payment processing and affiliate payouts (Connect)
• Vercel: Web hosting, API infrastructure, and analytics (page views, web vitals)
• Google Tag Manager (GTM): Tag management and analytics on our landing page (video engagement, time on page, session duration)

These services are contractually obligated to protect your data and comply with applicable privacy laws.

4.2 Data Location

Your data is stored on servers operated by our service providers. Supabase data is stored in regions that comply with GDPR requirements. We do not transfer your personal data outside the European Economic Area (EEA) without appropriate safeguards.

5. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

• Contract: To provide the Service you have subscribed to
• Consent: For analytics and non-essential cookies (where applicable)
• Legitimate interests: To improve the Service, prevent fraud, and ensure security
• Legal obligation: To comply with applicable laws

6. Your Rights (GDPR)

If you are located in the EEA or UK, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: Lodge a complaint with your supervisory authority (e.g., your local data protection authority)

To exercise these rights, contact us at contact@siwai.app.

7. Your Rights (CCPA – California Residents)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request disclosure of the personal information we collect, use, and disclose
• Right to Delete: Request deletion of your personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

We do not sell your personal information. SIWAI does not sell, rent, or share your personal data to third parties for monetary or other valuable consideration.

To exercise these rights, contact us at contact@siwai.app.

8. Data Retention

We retain your personal data only for as long as necessary to provide the Service and fulfill the purposes outlined in this policy. When you delete your account, we will delete or anonymize your personal data within 30 days, except where we are required to retain it for legal compliance.

9. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of sensitive data at rest
• Regular security assessments
• Access controls and authentication

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

10. Cookies and Tracking

We use essential cookies to maintain your session and provide the Service. We use a referral cookie for 30 days so we can credit an affiliate if you later subscribe via their link. Stripe Connect is used to pay affiliates. We use Vercel Analytics to collect anonymous page views and web performance metrics. We use Google Tag Manager (GTM) on our landing page to collect analytics data such as video play/pause/progress events, time spent on page, and session duration. GTM is a Google service that may set cookies and transmit data to Google in accordance with Google's Privacy Policy. We do not use advertising cookies or sell your data to third parties. You can control cookies through your browser settings.

11. Children's Privacy

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. Your continued use of the Service after such changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at contact@siwai.app.