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 a technical confirmation token, the confirmation status, the origin of the sign-up (which form) and the time of the sign-up.

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.

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 TradingView username, the order and payment data and the provisioning status. 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.

Trade exports and analysis report (Account Autopsy)

If you order the “Account Autopsy” analysis service, 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 analysis 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.

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) 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.

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.

Recipients, place of processing and third-country transfers

We use the following service providers as processors pursuant to Art. 28 GDPR. Data processing agreements are in place with each of them.

Hosting and operation of the website: 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.

Database (storage of newsletter and purchase data): Supabase Inc., 970 Toa Payoh North, Singapore, with the company domiciled in the USA. Data is stored in the eu-west-1 region (Ireland), i.e. within the EU. Here too, access from a third country cannot be ruled out; the transfer is safeguarded by the Standard Contractual Clauses.

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 purchase data only and is not involved in the newsletter procedure.

Newsletter distribution via Substack: our newsletter, The Risk Report, 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. Substack Inc. is certified under 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.

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

Audience measurement (web analytics)

This website uses Vercel Web Analytics and Vercel Speed Insights (provider: Vercel Inc., USA) to measure reach and performance. Measurement is cookieless: no cookies are set and no cross-device identifiable profile is created. For this reason, no consent banner is required.

Only aggregated, non-personal usage data is collected — such as pages viewed, referrer, approximate region, device type, and defined funnel events (use of the free tools, newsletter sign-up and confirmation, checkout start, and completed purchase).

These events expressly carry no personal attributes: for a newsletter sign-up only the origin of the form is transmitted, not the email address entered. Likewise, neither name, TradingView username nor purchase amounts are passed to analytics.

The legal basis is our legitimate interest in privacy-preserving, aggregated performance measurement and optimization of our offering (Art. 6(1)(f) GDPR). Vercel acts as a processor; any transfer to the USA is safeguarded by the Standard Contractual Clauses.

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.

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.

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.

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.