Privacy
Policy.

Eltrove ("Eltrove," "we," "our," or "us") operates the website located at https://eltrove.com and all related software, infrastructure, applications, APIs, and services (collectively, the "Platform"). This Privacy Policy governs the collection, use, disclosure, storage, processing, transfer, and protection of personal information and other data associated with access to or use of the Platform.

BY ACCESSING, REGISTERING FOR, CONNECTING ACCOUNTS TO, OR OTHERWISE USING THE PLATFORM IN ANY MANNER, YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND IRREVOCABLY AGREED TO THE TERMS SET FORTH IN THIS PRIVACY POLICY IN THEIR ENTIRETY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY CEASE ALL USE OF THE PLATFORM.

1. About Eltrove

Eltrove is a SaaS algorithmic trading platform that allows users to connect brokerage accounts using API credentials in order to automate, manage, monitor, or analyze trading strategies. Eltrove is a software platform only. Eltrove does not provide investment advice, broker-dealer services, registered investment advisory services, fiduciary services, portfolio management services, legal advice, tax advice, accounting advice, or financial planning services of any kind. Nothing on the Platform constitutes a recommendation to buy, sell, or hold any security or financial instrument.

2. Information We Collect

We collect information necessary to operate the Platform, provide services, improve functionality, maintain security, enforce our agreements, and comply with applicable legal and regulatory obligations.

A. Information You Provide Directly

• Full legal name
• Email address
• Account login credentials and authentication data
• Encrypted brokerage API keys and API secrets
• Payment and billing information (processed by Stripe; see Section 4)
• Identity verification information where required
• Customer support and communications records
• Any other information you voluntarily submit

B. Trading and Brokerage Data

• Trade history, orders, and execution records
• Open and closed positions
• Portfolio allocations and composition
• Account equity, balances, and margin information
• Strategy performance metrics and analytics
• Trading signals, decisions, and activity logs
• Risk parameters and configuration settings

C. Automatically Collected Technical Data

• IP address and approximate geolocation
• Device identifiers and hardware information
• Browser type, version, and configuration
• Operating system and platform
• Session identifiers and login event logs
• Usage logs, interaction records, and navigation data
• Error reports, crash diagnostics, and performance metrics
• Security events, authentication attempts, and access records

3. How We Use Your Information

• Provide, operate, maintain, and improve the Platform
• Authenticate users and enforce account security
• Process subscriptions, payments, and billing
• Connect, manage, and synchronize brokerage integrations
• Execute platform functionality and automations requested by users
• Detect, investigate, and prevent fraud, abuse, and unauthorized access
• Respond to user support requests and communications
• Send transactional, account-related, and operational communications
• Comply with applicable legal, regulatory, and contractual obligations
• Enforce our Terms of Service and other agreements

We do not sell, rent, lease, or otherwise transfer your personal information to third parties for monetary or other valuable consideration. We do not use your personal information for targeted advertising, behavioral profiling for advertising purposes, or sale to data brokers.

4. Third-Party Processors and Subprocessors

By accessing or using the Platform, you acknowledge and agree that certain personal information may be processed by third-party subprocessors subject to their respective privacy policies and data processing agreements.

• Stripe, Inc. — payment processing, subscription billing, fraud prevention. Payment card information is processed under Stripe's PCI-DSS Level 1 compliant infrastructure. Eltrove does not store full card numbers, CVV codes, or complete payment instrument details. Stripe Privacy Policy
• Supabase, Inc. — user authentication, database hosting, cloud infrastructure, and data storage. Supabase Privacy Policy
• Resend, Inc. — transactional email delivery, account notifications, and operational communications. Resend Privacy Policy
• Alpaca Securities LLC / Tradier Brokerage Inc. / Interactive Brokers LLC — brokerage connectivity, order routing, and trade execution. Governed independently by each provider's customer agreements and regulatory obligations. Eltrove is not responsible for brokerage provider data practices.

By connecting a brokerage account, you expressly acknowledge that you are independently entering into a relationship with that brokerage provider and are subject to their terms, disclosures, and regulatory agreements. You are solely responsible for reviewing and accepting all applicable third-party agreements prior to connecting any brokerage account.

5. Data Security

We implement commercially reasonable administrative, technical, physical, and organizational measures to protect your information from unauthorized access, disclosure, alteration, destruction, or misuse. Security measures include AES-256 encryption for sensitive data stored at rest, HTTPS/TLS encryption for all data transmitted in transit, encrypted storage of brokerage API credentials, role-based access controls, and continuous monitoring for unauthorized access attempts.

In the event of a personal data breach that poses a risk to user rights and freedoms, we will notify affected users and applicable regulatory authorities within the timeframes required by applicable law, including within seventy-two (72) hours where required under the GDPR.

No method of electronic storage or transmission is completely secure. We do not guarantee absolute security. YOUR USE OF THE PLATFORM AND TRANSMISSION OF INFORMATION TO US IS AT YOUR OWN RISK.

6. Data Retention

We retain personal data for as long as necessary to provide services, maintain business records, comply with legal obligations, resolve disputes, and enforce agreements. Unless otherwise required by applicable law, personal information will be retained for a period not to exceed two (2) years following account deletion or termination, after which such data will be securely deleted or rendered irreversibly anonymized. Certain transaction and compliance records may be subject to mandatory regulatory retention periods that supersede the foregoing.

7. Cookies and Session Data

Eltrove uses essential session cookies only, strictly necessary for Platform operation. We do not use advertising cookies, behavioral tracking cookies, cross-site tracking technologies, or third-party ad networks. You may configure your browser to refuse cookies; however, certain features of the Platform may not function properly without them.

8. User Rights and Data Requests

Subject to applicable law, you may request access to, correction of, export of, restriction of processing of, or deletion of your personal data by contacting [email protected].

We will respond within thirty (30) days for EEA/UK users (GDPR) or forty-five (45) days for California residents (CCPA/CPRA), or within the timeframe otherwise required by applicable law. We may require verification of your identity before processing data requests.

9. GDPR Compliance — EEA, United Kingdom, and Switzerland

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have rights under the GDPR including: right of access (Article 15), right to rectification (Article 16), right to erasure (Article 17), right to restriction of processing (Article 18), right to data portability (Article 20), right to object (Article 21), and right to withdraw consent. You may also lodge a complaint with a competent supervisory authority.

Our legal bases for processing include performance of a contract, compliance with legal obligations, legitimate business interests, and consent where separately obtained.

International Transfers: Where personal data is transferred outside the EEA or United Kingdom, such transfers are conducted pursuant to Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally recognized transfer mechanisms. We do not rely solely on user consent as the legal basis for international transfers.

Eltrove has executed or will execute Data Processing Agreements with applicable subprocessors as required under GDPR Article 28. To exercise GDPR rights: [email protected]

10. California Privacy Rights — CCPA and CPRA

California residents have rights under the CCPA/CPRA including: right to know what personal information we collect, use, and disclose; right to delete; right to correct; right to opt out of sale or sharing (Eltrove does not sell personal information); right to limit use of sensitive personal information; and right to non-discrimination for exercising privacy rights.

To submit California privacy requests: [email protected]

11. Communications and Opt-Out

We send transactional and operational emails including account confirmations, security alerts, billing notifications, and service updates. These are necessary for Platform operation and may not be opted out of while your account remains active. Where we send optional communications, we provide an unsubscribe mechanism in each such message. You may also opt out by contacting [email protected].

12. Disclaimer of Warranties; Limitation of Liability; Risk Disclosure

ALL SERVICES, SOFTWARE, DATA, MARKET INFORMATION, SIGNALS, ANALYTICS, AUTOMATIONS, EXECUTIONS, ALERTS, AND PLATFORM FUNCTIONALITY ARE PROVIDED ON AN "AS IS," "AS AVAILABLE," AND "WITH ALL FAULTS" BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, ELTROVE EXPRESSLY DISCLAIMS ALL WARRANTIES INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, ACCURACY OR COMPLETENESS OF DATA, CONTINUOUS AVAILABILITY, ERROR-FREE OPERATION, AND SUITABILITY FOR FINANCIAL OR TRADING PURPOSES.

Eltrove does not provide investment advice, broker-dealer services, portfolio management, or fiduciary services. No platform output shall constitute an investment recommendation, solicitation, or guarantee of profitability.

USERS RETAIN SOLE AND EXCLUSIVE RESPONSIBILITY FOR ALL TRADING DECISIONS, BROKERAGE ACCOUNT ACTIVITY, RISK MANAGEMENT, TAX OBLIGATIONS, AND ALL FINANCIAL OUTCOMES ARISING FROM USE OF THE PLATFORM.

Trading involves substantial risk of loss including potential loss of all capital deployed. Past performance does not guarantee future results. Algorithmic systems are subject to software defects, infrastructure outages, brokerage failures, market volatility, cybersecurity incidents, and other risks.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, ELTROVE AND ITS AFFILIATES, OWNERS, OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AND AGENTS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, OR ECONOMIC DAMAGES ARISING FROM TRADING LOSSES, LOST PROFITS, LOSS OF DATA, EXECUTION FAILURES, SYSTEM DOWNTIME, THIRD-PARTY ACTIONS, REGULATORY ACTIONS, OR FINANCIAL LOSSES OF ANY KIND, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

13. Regulatory and Compliance Statement

Eltrove is a software technology provider. Eltrove is not registered with the SEC as a broker-dealer or registered investment adviser, is not a FINRA or SIPC member, does not custody customer assets, does not hold customer funds, and does not provide discretionary investment management. Users are solely responsible for ensuring their use of the Platform complies with all applicable laws, regulations, tax obligations, securities laws, and regulatory requirements within their jurisdiction.

14. Children's Privacy

The Platform is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from minors. If we become aware that information has been collected from an individual under eighteen, we will promptly delete such information. Contact [email protected] immediately if you believe we have inadvertently collected information from a minor.

15. International Data Transfers

Your information may be processed and stored in countries outside your jurisdiction, including the United States. Where required by applicable law, international transfers are conducted pursuant to Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally recognized transfer safeguards.

16. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated to registered users via email or prominent notice on the Platform prior to the effective date. Continued use of the Platform following the effective date of any revised Privacy Policy constitutes irrevocable acceptance of the updated terms. If you do not agree to any modification, you must immediately cease use of the Platform.

17. Contact Information

For questions, data requests, or privacy-related inquiries:

Eltrove
Website: https://eltrove.com
Email: [email protected]