DRAFT — owner must reviewThis is a template draft, not legal advice. It is not in force until the owner has reviewed and published it.

Privacy Policy

Draft of 3 October 2026

This policy explains what personal data BTG Vision (“Vision”) collects, why, and the rights you have under the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Acts.

1. Who is responsible

The data controller is [controller legal name and registered address]. Contact for privacy questions and requests: [privacy contact email].

2. What we collect

• Sign-in identity. When you sign in with Apple, Google or Discord, the account identifier, email address and, where the provider shares it, display name and profile picture. With email sign-in, your email address and a one-way hash of your password (never the password itself).
• Access records. Whether your account has access, and any invitation used.
• Session data. A session cookie and session record that keep you signed in, and security records such as sign-in times.
• Your workspace content. Drawings, workspaces, layouts, alerts, saved scripts and settings you create.
• Feedback you choose to send us.
• Pseudonymous usage milestones — for example selecting a market or timeframe, adding a study or drawing, saving a workspace, and returning. These record no symbols, prices, chart content or drawing content, and are deleted after 90 days.
• Technical data such as IP address, browser type and error reports, used to secure and run the service.

We do not collect payment details, exchange account keys or trading balances. Vision never executes trades.

3. Why we use it, and our legal basis

• To provide your account and the service you asked for — performance of a contract (GDPR Art. 6(1)(b)).
• To keep the service secure, prevent abuse and fix faults — our legitimate interests (Art. 6(1)(f)).
• To improve Vision from pseudonymous usage milestones — our legitimate interests (Art. 6(1)(f)).
• To meet legal obligations — legal obligation (Art. 6(1)(c)).

We do not sell your personal data, and we do not use it for advertising.

4. Who we share it with

Only service providers that process data for us under contract: hosting [hosting provider], email delivery [email provider], and the sign-in provider you choose (Apple, Google or Discord), which handles your sign-in under its own privacy policy. We may disclose data where the law requires it.

5. International transfers

Where data is transferred outside the European Economic Area, we rely on an adequacy decision or the European Commission’s Standard Contractual Clauses. [owner to list transfers]

6. How long we keep it

Account and workspace data: while your account is open, and deleted within [period] of closure. Usage milestones: 90 days. Security logs: [period].

7. Your rights

You have the right to:

• access the personal data we hold about you and get a copy of it;
• have inaccurate data corrected;
• have your data erased;
• restrict or object to our processing, including processing based on legitimate interests;
• data portability — receive your data in a machine-readable format;
• lodge a complaint with the Data Protection Commission (Ireland), dataprotection.ie, or your local supervisory authority.

To use any of these rights, write to [privacy contact email]. We reply within one month.

8. Cookies

Vision uses only cookies and browser storage needed to sign you in, keep you signed in, protect forms, and remember your own settings on this device. We use no advertising or cross-site tracking cookies.

9. Children

Vision is not for anyone under 18.

10. Changes

We will post any change on this page with a new date, and tell you of material changes. See also the Terms of Use.

Informational only — not financial advice · Data may be wrong or delayed