Privacy Policy

1. Who the controller is

Tortuga Trades LLC, a limited liability company organised in New Mexico (United States), which operates Tortuga Trades. Address: 8206 Louisiana Blvd NE, Ste A #10993, Albuquerque, NM 87113 (United States). Contact: info@tortugatrades.app.

The data controller is not established in the European Union. This policy and the General Data Protection Regulation (GDPR) still apply to your data, because the service is offered to people located in the EU.

2. What data we process and where it comes from

Account data: your email address and name, plus your Google account identifier if you sign up with it. Handled by our authentication provider.

Your trading data: the trades, positions, cash movements, dividends, net asset value and notes you enter or import. It comes from you — you type it in, upload a CSV, or authorise us to download it from your broker using a read-only query token (IBKR Flex) that you generate yourself and can revoke at any time.

Billing data: if you subscribe on the web, our payment provider processes your payment method and billing address. We never see or store your card number. If you subscribe from the iPhone app, the payment is processed by Apple through your Apple ID and we only receive confirmation of your subscription status, never your payment method.

Technical data: IP address, browser type, pages visited and application errors, collected by our hosting and monitoring providers.

We do not ask for and do not want special categories of data (health, beliefs, biometrics). Please do not put them in your notes.

3. What we use it for, and on what legal basis

To provide the service — create your account, import and compute your trading activity, show you your results: legal basis is performance of the contract you accept when you register.

To charge your subscription and keep our accounts: performance of the contract and compliance with legal obligations.

To keep the service secure and working: detecting faults, preventing abuse and measuring usage in aggregate. Legal basis is our legitimate interest in a product that works and does not get abused.

To review and fix your data when you ask us to: occasionally, and always with your prior written consent (for example, by ticking the box in the suggestions form or by replying to the email or message in which we ask you), which is kept on record, an authorised administrator of Tortuga Trades may need to access the data you imported from your broker in order to implement an improvement you requested or suggested, or to correct synchronisation data (for example, re-importing a period or fixing a trade that came through wrong). Access is limited to your account and to what that purpose requires, and the data is not used for anything else. Legal basis is your consent, which you can refuse or withdraw at any time without affecting the rest of the service.

To send you operational alerts you switched on yourself (trade alerts, Telegram notifications): performance of the contract as to the feature you asked for.

To send you marketing or the newsletter: only with your consent, which you can withdraw at any time from the unsubscribe link in every email.

To generate AI analysis: only when you use that feature. At that moment the portfolio data needed to produce the analysis is sent.

To read the documents you import: if you upload a screenshot, PDF or Excel from your broker, we send it to our AI provider to transcribe your positions and trades. We do not keep the document: we only store what you confirm.

4. Who we share it with

We do not sell your data and we do not hand it to third parties for their own advertising. We share it only with the providers we need to run the service, and only with what each one needs:

Clerk, for authentication and account management. Supabase, as the database. Vercel, for web hosting and aggregate usage metrics. Railway, for server hosting. Stripe, for payments and subscriptions on the web. Apple, for purchases and subscriptions made from the iPhone app. Resend, for the emails we send you. Telegram, only if you enable notifications on that channel. Anthropic, to generate AI analysis and read the documents you import, when you use those features. Sentry, to log application errors.

All of them act as processors on our behalf and under contract, except Stripe, Apple and Telegram, which are also controllers for their own processing under their respective policies.

We may also disclose data to authorities where a law requires us to.

If you have a paid plan and connect an AI assistant you use (for example Claude or ChatGPT) to your account through the Tortuga Trades MCP connector, the account data that assistant reads (trades, portfolio, returns, calendar, dividends and journal, never other users' data) is sent to its provider (for example Anthropic or OpenAI) under your own account with them and subject to their terms and privacy policy. The connection only exists if you authorise it, is read-only, can be paused from the AI page of your dashboard and removed from your assistant.

5. International transfers

The controller is a company established in the United States. When you provide your data by using the service, we receive and process it in the United States, and we apply the GDPR to it as this policy explains.

Several of the providers listed above are in the United States. Those transfers rely on standard contractual clauses approved by the European Commission, or on the EU–US adequacy framework where the provider is certified.

6. How long we keep it

While your account is active, we keep your data so we can provide the service.

If you delete your account, we mark your data as deleted and stop using it. We keep a limited copy for as long as needed to handle claims and meet legal obligations — billing records, for instance, carry tax retention periods — and then it is erased.

If you want immediate and complete erasure, write to us and we will do it.

If your free trial ends and you do not subscribe, we automatically delete your account and all its data, credentials included, 30 days after the trial ends.

If you use the AI connector, we keep a log of each request for 30 days (which tool, with which parameters, when, whether it succeeded and how long it took), never the content of the responses, so you can review it on the AI page and so we can troubleshoot.

7. Your rights

You can ask us to access your data, rectify it, erase it, restrict its processing, object to it, and receive it in a portable format. You can also withdraw any consent you gave at any time, without affecting processing carried out beforehand.

To exercise them, write to info@tortugatrades.app. We will reply within one month. There is no charge.

If you believe we have got it wrong, you can lodge a complaint with the data protection supervisory authority of your country of residence. In Spain that is the Agencia Española de Protección de Datos (www.aepd.es).

8. Security

We encrypt communications, restrict access to data, and use providers that apply recognised security measures. The database is encrypted and backed up daily, and backups are kept for a limited time.

Your broker credentials. To import your trades automatically we store the credential you give us: the Interactive Brokers Flex token and query number, or the API key or authorised connection of other brokers. We store them encrypted with their own key, on top of the database encryption, and only the server decrypts them, at the moment it requests reports from your broker. We never show them to you in full again: in the app you only see their last characters.

These credentials are read-only: they exist to download reports and cannot trade or move money in your account. At Interactive Brokers, the token expires on the date you choose when you create it, at most one year later. You can revoke them from your broker whenever you want, and if you disconnect the broker in Tortuga Trades or delete your account, we erase them.

No system is infallible. Should a breach occur that poses a risk to your rights, we will tell you and notify the competent authority within the legal deadlines.

9. Minors

The service is not aimed at people under 18 and we do not knowingly process their data. If we find an account belonging to a minor, we will delete it.

10. Changes to this policy

If we change this policy, we will update the version date shown at the top. If the change is substantial, we will tell you by email or inside the app before it takes effect.