Privacy Policy

Controller

The controller within the meaning of Art. 4(7) GDPR is:

MoTradeSystems, Moritz Engerer, c/o COCENTER, Koppoldstr. 1, 86551 Aichach, Germany

Email: support@motradesystems.com

No data protection officer has been appointed; the conditions of Art. 37 GDPR are not met.

Newsletter and free resources (double opt-in)

If you sign up for a free resource — such as the Field Guide — we process your email address together with technical tokens for confirmation and unsubscription, the confirmation status, the origin of the sign-up (which form) and the time of the sign-up. For each list you sign up for we also store the time of your confirmation and of the last email we sent for that list and, if you arrived through one of our campaign links, the campaign tag of that link (source, medium, campaign, content) and the page path.

Sign-up uses the double opt-in procedure: after you enter your address you receive an email containing a confirmation link. Consent is given only when you click that link; only then do we send the requested resource and any further emails. If you do not click, the entry remains unconfirmed and is deleted without anything being sent.

Each list needs its own confirmation: if your address is already confirmed for one list and you sign up for another, you receive a new confirmation link for that list, and we add you to it only after you click it.

The purpose of the sign-up depends on the form you use, and the origin of your sign-up decides which emails you receive. Free downloads (for example the checklist, the Field Guide or the trade-log files): after confirmation we send you the download links. MoTrade Pro founding list: after confirmation we send you a confirmation of your place and, when the doors open, the launch email. Rule Change Alerts: after confirmation we email you when one of the prop-firm rule pages we track changes. Pre-Flight: after confirmation we send you, by hand, the upload link and the payment link; nothing is charged before that. Indicator pre-registration (Prop Rule Kit, Dollar Ladder): after confirmation we note your interest; we write to you when the indicator is available or if we decide not to build it. TradingView Marketplace list (MoTrade - Macro Sentiment, MoTrade Risk Framework): after confirmation we note your interest; we write to you when the indicator is available on the TradingView Marketplace, or if it will not be. If you request a free download again with an address already confirmed for it, we send the links again, no more than once every 24 hours.

The legal basis is your consent pursuant to Art. 6(1)(a) GDPR.

You may withdraw your consent at any time with effect for the future — via the unsubscribe link in every email or informally to support@motradesystems.com. The lawfulness of processing carried out before withdrawal remains unaffected. After withdrawal we remove your address from the distribution list.

Providing your email address is neither required by law nor by contract. It is needed solely so that we can send you the requested resource; without it delivery is not possible. No automated decision-making including profiling within the meaning of Art. 22 GDPR takes place.

Purchase and payment processing

This processing is separate from the newsletter sign-up and concerns only customers who purchase a product.

When you purchase, we process your email address, your name and the country of your billing address (both provided by Stripe), your TradingView username, the language of the purchase page, the order and payment data (product, amount, currency, payment reference), the provisioning status and the record of the declarations you make at checkout (see below). The legal basis is Art. 6(1)(b) GDPR (performance of a contract); for retention under tax and commercial law, Art. 6(1)(c) GDPR.

Payments are processed via Stripe. Payment details are entered directly with Stripe; we do not receive full card details. Stripe also creates a customer record for you.

Activation of your TradingView access: we enter the TradingView username you gave at checkout by hand in the access management for invite-only scripts on TradingView. There is no automated interface, and our website does not transmit your username to TradingView. Where a refund or a withdrawal makes it necessary, we remove the access there in the same way. The purpose is to grant and, where necessary, withdraw your access; the legal basis is Art. 6(1)(b) GDPR. Further information on TradingView as a recipient, including the third-country transfer, is in the section 'Recipients, place of processing and third-country transfers'.

Record of your declarations at checkout: before payment you confirm that you have taken note of the legal documents (GTC, Withdrawal Instructions, Licence Terms) and expressly request that we begin performance of the contract before the withdrawal period expires. To be able to show this later, we record together with the payment that both confirmations were given, the time (taken from your browser if plausible, otherwise our server time) and the version of the terms in force. This record is kept as metadata of the payment at Stripe and repeated in the contract confirmation we email you after payment; it is not stored additionally in our own database. The legal basis is Art. 6(1)(c) GDPR in conjunction with § 312f BGB (confirmation of the contract) and Art. 6(1)(f) GDPR; our legitimate interest is the establishment, exercise and defence of legal claims, in particular proof of which terms applied and of your request for immediate performance (§ 356(5) and (6) BGB). You may object to this under Art. 21 GDPR.

Until 30 September 2026 this website noted campaign parameters (utm_source, utm_medium, utm_campaign, utm_content) in your browser's session storage and passed them on with a purchase: as metadata of the payment at Stripe and in the purchase record in our database. This has been discontinued. Campaign fields from earlier purchases are erased from the purchase record and from the payment metadata at Stripe no later than 13 months after the purchase.

Trade exports and analysis reports (Account Autopsy, Payout Readiness Check)

If you order one of our analysis services — “Account Autopsy” or “Payout Readiness Check” — we additionally process the data you send us for the purpose of producing the report. The sole purpose of this processing is the production and delivery of the report you ordered.

Categories of data processed: the record of your already closed trades (“trade export”) and the details it contains (instrument, direction, size, entry and exit times, prices, result), the name of the prop firm and the account model, the account size, and the email address from which you send us the export and to which we deliver the report; for the Payout Readiness Check also the payout-related details you provide or your export contains (for example date and amount of earlier payouts).

The legal basis is Art. 6(1)(b) GDPR (performance of the contract concluded with you). Without the export we cannot produce the report (§ 5(3a) and (3b) of our GTC).

Recipients and place of processing: we accept the trade export by email only, at support@motradesystems.com. Please do not send it to us via messaging or social media services (e.g. Discord, Telegram, Instagram); on those services we can guarantee neither confidentiality nor the erasure we promise. If we nevertheless receive an export through such a service, we will point you to the email route and delete the message received there as far as this is technically possible for us. To receive and send our emails we use the mailbox of our domain at STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany (processing in Germany). We do the analysis ourselves, on a computer in Germany. This information concerns the trade export and the analysis report. For your purchase, payment processing and the operation of the website, the sections 'Purchase and payment processing' and 'Recipients, place of processing and third-country transfers' apply in addition; those sections also describe which data are transferred to recipients in the United States and on what basis. Your trade export itself is not transferred to those recipients.

We do not pass your trade export or your report on to any third party — in particular not to the prop firm you name, not to other customers, and not for advertising purposes. Whether you present the report to your prop firm is entirely your decision.

Account numbers and comparable account identifiers do not appear in the report. If your export contains such details, we remove them when preparing the report.

Erasure: we delete the trade export and any working files created during the evaluation no later than 30 days after delivery of the report. This erasure also covers the email in which you sent us the export and our reply containing the report, including the trash folder. Copies may still be present in routine backups until those are overwritten in the normal backup cycle; they are not processed further there. Excluded from this are invoicing and accounting records relating to your purchase, which we are required to retain for longer under statutory retention obligations (in particular § 147 AO and § 14b UStG); the retention period is currently eight years and starts at the end of the calendar year in which the invoice was issued (legal basis for that retention: Art. 6(1)(c) GDPR). Those records do not contain your trade export.

We retain the report delivered to you and the rule quotations used in it beyond the 30 days for as long as claims under this contract may still be asserted by or against us. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the establishment, exercise and defence of legal claims, in particular the ability to show which version of a rule we evaluated as at which date of retrieval. The retention period is based on the standard limitation period (§§ 195, 199 BGB) and ends no later than its expiry. Your trade export is not covered by this retention; it is deleted after 30 days. You may object to this retention under Art. 21 GDPR.

Anonymised extracts of your report are used as a sample report only with your separate consent, which you may withdraw at any time, under Art. 6(1)(a) GDPR (§ 7(5) of our GTC). Without such consent we use your report solely to perform the contract.

Your rights of access, rectification, erasure, restriction, data portability and objection, as well as your right to lodge a complaint with a supervisory authority, apply to this processing too; details and the competent supervisory authority are set out in the section 'Your rights'.

Contact enquiries

If you write to us via the contact form at /support or by email to support@motradesystems.com, we process the email address you provide, your name — where you choose to give it, the field is optional — and the content of your message.

The sole purpose is handling and answering your enquiry. The legal basis is Art. 6(1)(b) GDPR where the enquiry serves to initiate or perform a contract, and otherwise our legitimate interest in answering incoming enquiries pursuant to Art. 6(1)(f) GDPR.

Messages sent via the form are not stored in a database. They are delivered solely by email to our support mailbox; the only service provider technically involved is STRATO AG, already named above. No additional recipient is introduced.

To protect the form against misuse, we count requests per IP address in the working memory of the server function for a short time only (Art. 6(1)(f) GDPR).

We retain the correspondence until your enquiry is fully resolved, and no longer than 12 months after the last contact. Where the enquiry concerns a purchase and the correspondence is subject to commercial or tax retention obligations, those periods apply instead.

Electronic withdrawal function

If you declare your withdrawal via the form on /widerruf/erklaeren (our electronic withdrawal function under § 356a BGB), we process your name, the order or contract reference, the email address of the order and — where you choose to give it — a message, as well as the date and time of receipt. The sole purpose is to record, confirm and act on your withdrawal. The legal basis is Art. 6(1)(b) GDPR (winding down the contract) together with Art. 6(1)(c) GDPR (our statutory duty under § 356a BGB to enable and confirm withdrawal). Name, reference and email address are required for the function to work; you can also declare your withdrawal informally by email to support@motradesystems.com instead.

On submission two emails are sent: an internal record to our mailbox and a confirmation of receipt, with date and time, to the address you gave. Your declaration is delivered by email and is not stored in a database. The only service provider technically involved is STRATO AG, already named above; no additional recipient is introduced, and no third-party captcha is used.

To protect the function against misuse we count requests per IP address (up to five within ten minutes) and per mailbox, using a normalised form of the email address (up to three within 24 hours). The counters exist only in the working memory of the server function for the periods mentioned; they are not stored in a database and not used for any other purpose. The legal basis is our legitimate interest in preventing misuse of the function as a mail relay (Art. 6(1)(f) GDPR).

We retain your withdrawal declaration, our confirmation of receipt and related correspondence for six years as business correspondence (§ 147(1) nos. 2 and 3 and (3) AO; § 257(1) nos. 2 and 3 and (4) HGB, where applicable). Where the withdrawal leads to a refund, the records of that refund are accounting vouchers and are retained for eight years (§ 147(1) no. 4 and (3) AO). The periods start at the end of the calendar year in which the document was sent, received or created; they do not expire while the documents remain relevant for taxes whose assessment period has not yet expired (§ 147(3) sentence 5 AO). We then delete them.

Recipients, place of processing and third-country transfers

We use the following service providers as processors pursuant to Art. 28 GDPR and have concluded data processing agreements with each of them: Vercel, Supabase and STRATO, and Stripe to the extent it processes data on our behalf (see below). TradingView and Substack are not our processors; they act as independent controllers (see below).

Hosting and operation of the website, including, with your consent, visitor statistics and performance measurement (Web Analytics, Speed Insights) and the counting of key actions on our server: Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. The server functions of this website run in the Frankfurt am Main region (fra1), i.e. within the EU. As this is a US company, access from the USA cannot be ruled out; the transfer is safeguarded by the European Commission's Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Vercel states that it also participates in the EU-U.S. Data Privacy Framework; our transfer basis is the Standard Contractual Clauses.

Database (storage of newsletter and purchase data): Supabase Pte. Ltd., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513. Data is stored in the eu-west-1 region (Ireland), i.e. within the EU. Supabase and its sub-processors may access it from third countries, in particular Singapore and the United States; for Singapore there is no adequacy decision. These transfers are safeguarded by the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Email delivery: STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany. Processing takes place exclusively within Germany; no third-country transfer occurs.

Payment processing: Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Dublin 2, Ireland, for its parent company Stripe, Inc., USA. Processing takes place within the EU; the Standard Contractual Clauses apply to transfers to the parent company. Stripe receives the data needed to process the payment and, as metadata of the payment, your TradingView username, the product and the record of your declarations at checkout. Stripe processes payment data partly on our behalf and partly as an independent controller (for example for fraud prevention and compliance with financial regulation) under its own privacy policy: https://stripe.com/privacy. Stripe is not involved in the newsletter procedure.

Access provisioning via TradingView: TradingView, Inc., 1330 Avenue of the Americas, 23rd Floor, New York, NY 10019, USA (its privacy policy names an EEA representative under Art. 27 GDPR). TradingView is not our processor. Our indicators run on TradingView, and we enter your TradingView username by hand in TradingView's access management for invite-only scripts (and remove it there after a refund or withdrawal). TradingView already knows the username as the name of your own account and processes your account data as an independent controller under its own privacy policy; through our entry it additionally learns that this account is licensed for our scripts. As TradingView is a US company, this is a transfer to a third country. It takes place to perform the contract with you (Art. 49(1)(b) GDPR), because the licence can only be provided on TradingView.

Newsletter distribution via Substack: our newsletter, The Funded Brief, is published on Substack (Substack Inc., United States). If you follow a link to our Substack page and subscribe there, you enter into a relationship with Substack directly: Substack collects your email address and processes it on its own systems as an independent controller under its own privacy policy — not as a processor acting on our behalf. According to its own statements, Substack Inc. participates in the EU-US Data Privacy Framework. We can see subscriber data in the Substack dashboard and use it to send the newsletter, but we do not import it into our own systems.

Copy of the safeguards: for the transfers to Vercel, Supabase and Stripe that are based on the Standard Contractual Clauses, you can obtain a copy of the clauses from us at support@motradesystems.com.

Your data is not passed on to third parties for advertising purposes.

Visitor statistics and performance measurement (only with your consent)

With your consent, this website uses Vercel Web Analytics and Vercel Speed Insights (provider: Vercel Inc., USA). Without your consent, neither service is loaded and no data is sent to Vercel for this purpose. On your first visit, a small notice at the bottom of the page asks for your choice. "Allow" and "Decline" are equal options; nothing is pre-selected.

If you allow it, the scripts run in your browser and send Vercel the pages you view, the referrer, browser, operating system and device type, your approximate country and loading-time measurements (loading time, responsiveness, visual stability). They also send the interactions we count as events (for example the use of a calculator, a newsletter sign-up, the start of checkout, a click on the newsletter link), each with a non-identifying label such as the tool, product or form — never your email address or TradingView username. According to Vercel, it forms a daily-changing, hashed identifier from technical request data for this and sets no cookies.

The purpose is to understand how the website is used and to find and fix slow pages. The legal basis is your consent under Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act), because the scripts access information on your device.

You can withdraw your consent at any time with effect for the future: click "Privacy settings" in the footer of any page and choose "Decline". The page then reloads without the scripts. Withdrawal is as easy as giving consent and does not affect the lawfulness of processing carried out before it.

Storing your choice: so that we do not ask again on every page, we store your choice (allowed or declined) and its date in your browser's local storage (key "mt-consent-v1"). The entry stays in your browser; we do not receive it. A declined choice is kept for six months, an allowed one for twelve months; after that we ask again. This storage is strictly necessary to provide the function you requested — honouring your choice — and is based on § 25(2) no. 2 TDDDG. You can delete the entry at any time in your browser settings.

Vercel acts as our processor (Art. 28 GDPR). Any transfer to the USA is safeguarded by the Standard Contractual Clauses (Art. 46(2)(c) GDPR); see "Recipients, place of processing and third-country transfers".

Apart from this and the campaign test described below, we do not use any other web analytics or campaign tracking, and the website does not note campaign parameters in your browser.

Counting of key actions on our server

When you sign up for a free resource, start checkout or complete a purchase, our server counts one event via Vercel Web Analytics: the name of the action, the product or the origin of the sign-up, the language and the time. This happens on our server after the action has succeeded. It involves no access to your device (no script, cookie or local storage) and is independent of your choice above. We do not pass on your email address, your name or your TradingView username for it, and we do not forward your IP address, browser identifier or cookies to Vercel for it.

The purpose is to measure how well our offer performs (how many sign-ups, checkouts and purchases there are). The legal basis is our legitimate interest in measuring the success of our offer (Art. 6(1)(f) GDPR). You may object at any time (see "Right to object").

Campaign test: counting visits from campaign links

If you open one of our pages through a link carrying our campaign tag (utm_campaign=pos-2610, for example from a post), our server counts that visit and a few actions on it in our own database: the type of action (page opened, button clicked, calculator started, TradingView link clicked, form submitted), the campaign tag of the link (source, medium, campaign, content), the page path, a random visit code that our server assigns when you open the landing page, a yes/no flag whether the request looks automated (judged from technical request headers, which we do not store), and the time.

The visit code and the campaign tag travel in the web address of our own links; a click on a TradingView link from these pages passes through our server, which counts it and forwards you. We place nothing on your device (no cookie, no local or session storage), and the visit code is not used to recognise you later. We do not store your IP address, your browser identifier, your email address or anything you type; to limit abuse, the server function keeps only a salted short code derived from your IP address in its working memory, for about two minutes at most; the IP address itself is not kept.

The purpose is to compare two versions of a landing page. The legal basis is our legitimate interest in measuring which version works better (Art. 6(1)(f) GDPR). You may object at any time (see "Right to object").

Server log files

When the website is accessed, technically necessary access data is processed (IP address, time, resource requested, referrer, browser and operating system identifier). The legal basis is our legitimate interest in secure and trouble-free operation pursuant to Art. 6(1)(f) GDPR. This data is not merged with other data sources. In the event of errors, the logs of our server functions may also contain your email address and TradingView username for troubleshooting; they are deleted automatically after no more than 30 days.

Retention and erasure

Newsletter sign-up with consent given: until withdrawal. After withdrawal the address is deleted.

Unconfirmed newsletter sign-up: if confirmation is not given, the entry is deleted no later than 30 days after it was received.

Unconfirmed sign-up for a further list (address already confirmed for another list): deleted no later than 30 days after it was received.

Campaign test counts: deleted or reduced to totals without the visit code after the evaluation, no later than 31 December 2026.

Rate-limit counters of the sign-up form and of the campaign counting: only as a salted short code derived from the IP address, in the working memory of the server function, for about two minutes at most.

Purchase and invoice data: currently eight years, starting at the end of the calendar year in which the invoice was issued (§ 147 AO, § 14b UStG). Until that period expires, this data is exempt from erasure and restricted in processing.

Record of your declarations at checkout: retained together with the payment record, which is an accounting voucher, for eight years (§ 147(1) no. 4 and (3) AO).

Campaign parameters of purchases made before 30 September 2026 (function discontinued): in the purchase record and in the payment metadata at Stripe for no longer than 13 months after the purchase.

Withdrawal declarations, confirmations of receipt and related correspondence: six years (§ 147(1) nos. 2 and 3 and (3) AO; § 257(1) nos. 2 and 3 and (4) HGB, where applicable); records of a refund resulting from a withdrawal: eight years (§ 147(1) no. 4 and (3) AO). The periods start at the end of the calendar year in which the document was sent, received or created; we then delete the documents.

Rate-limit counters of the withdrawal function: in the working memory of the server function only, for ten minutes (IP address) or 24 hours (email address).

Server log files: no longer than 30 days.

Irrespective of the above, data is erased on your request unless a statutory retention obligation prevents it.

Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21).

You may withdraw consent at any time with effect for the future (Art. 7(3) GDPR) without affecting the lawfulness of processing carried out beforehand.

An informal message to support@motradesystems.com is sufficient to exercise these rights.

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent authority is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht), Promenade 18, 91522 Ansbach, Germany.