Privacy Policy

This privacy notice for Infradev Consulting Inc., operating as Premo Trading (“Premo,” “we,” “us,” or “our”), describes how and why we collect, store, use and share (“process”) your information when you use our services (“Services”), for example when you:

• visit our website at https://premotrading.com, or any website of ours that links to this notice;
• create an account, subscribe to a plan or use the Premo Trading platform;
• request membership, contact support, or otherwise engage with us.

Questions or concerns? Reading this notice will help you understand your privacy rights and choices. If you do not agree with our practices, please do not use our Services. If you still have questions, contact us at dev@infradevconsulting.com or 514-437-1864.

Summary of key points

• What do we collect? Account and contact details, the trading data you import or enter, information about your subscription, limited technical data needed to run and secure the Services, and, only if you accept analytics cookies, statistics about how you use our website.
• Do we collect card numbers? No. Payments are handled by Stripe. We never see or store your full card number.
• Do we process sensitive personal information? Only if you choose to record it. Mindset check-ins (for example energy, focus, stress and sleep scores) are optional, self-reported journal entries. Because they can reveal personal details about your wellbeing, we treat them as sensitive: they are visible only to you, used only to show you your own statistics, and never shared except with the hosting provider that stores them. Recording a check-in is your consent to this use, and you can ask us at dev@infradevconsulting.com to delete your check-ins at any time.
• Do we sell your information, or use it for anything else? No. We use your information only to provide the Services to you. We do not sell or rent it, share it for advertising, analyse your trading data for our own purposes, or use your trading data to train AI models.
• Who do we share it with? Only the service providers that help us run the Services (Amazon Web Services, Stripe, OpenAI and Cloudflare) and, if you accept analytics cookies on our website, Google, as listed in section 4.
• How do we keep it safe? Encryption in transit, access controls, account isolation and secure hosting. No system is perfectly secure, so we cannot guarantee absolute security.
• What are your rights? Depending on where you live, you can ask to access, correct, export or delete your information. See section 9.

1. What information do we collect?

Information you give us

• Account information: your name, email address and password. Passwords are stored only as secure hashes.
• Trading data: trade files you import (for example TradeZero or TradingView CSV exports), the positions and fills they contain, account labels, notes, monthly objectives, and mindset check-ins.
• Subscription information: your plan, billing interval, subscription status and renewal date, and Stripe’s reference numbers for your customer record and subscription. Your card details are entered on Stripe’s hosted checkout and billing portal and never reach our servers. We do not store card numbers, expiry dates or security codes.
• Membership requests and messages: what you tell us when you request membership or contact us, such as your trading experience and the markets you trade.

Information collected automatically

• Technical and security data: IP address, browser and device type, the pages and features you request, and timestamps, recorded in server logs to operate and secure the Services and to prevent abuse.
• Usage of AI features: the AI requests made from your account and the number of tokens they use, so we can operate fair-use limits and understand costs.
• Website analytics, only with your consent: if you accept analytics cookies on our marketing website (premotrading.com), Google Analytics collects information about your visit, such as the pages you view, the site that referred you, your approximate location, your device and browser type, and an online identifier stored in a cookie. We use it only to understand and improve the website. It is not linked to your platform account. If you decline, it is not collected.

Our website uses no advertising trackers. See our Cookie Policy.

Information from third parties

• Stripe tells us whether a payment succeeded and the status of your subscription.
• We do not buy personal information or receive it from data brokers.

2. How do we use your information?

We process your information to:

• create and manage your account, and authenticate you when you sign in;
• provide the Services, including importing your trades, calculating positions and analytics, and running the AI features you use;
• process subscriptions, payments, renewals, cancellations and refunds;
• review membership requests and manage memberships;
• send service messages, such as account set-up links, receipts, renewal notices and important changes;
• respond to your questions and support requests;
• protect the Services, detect and prevent fraud and abuse, and enforce our Terms of Service;
• comply with our legal, tax and accounting obligations.

We use your information only for these purposes. We do not sell or rent it, share it for advertising, build profiles of you, analyse your trading data for our own purposes, or use your trading data to train AI models.

We send marketing emails only where you have agreed to receive them, and every marketing email includes a way to unsubscribe.

3. What legal bases do we rely on?

We process personal information only when we have a valid reason to under applicable law.

If you are in Canada, we rely on your consent, which may be express or implied depending on the circumstances. You can withdraw consent at any time, subject to legal or contractual restrictions, but this may mean we can no longer provide some or all of the Services. In limited cases the law allows us to process information without consent, for example to investigate fraud, to comply with a subpoena, warrant or court order, or where the information is publicly available as specified by regulation.

If you are in the European Economic Area or the United Kingdom, we rely on: performance of our contract with you (providing the Services and processing payments); our legitimate interests (securing the Services and preventing fraud); legal obligations (tax and accounting records); and your consent (marketing emails and website analytics cookies).

4. When and with whom do we share your information?

We share personal information only with service providers that process it on our behalf, under contracts that require them to protect it and use it only for the services they provide to us:

Market data in the platform comes from Massive (massive.com). Requests to it contain only the instrument requested, never personal information.

We may also disclose information:

• for business transfers, in connection with a merger, financing, acquisition or sale of all or part of our business, in which case the information remains subject to this notice;
• to comply with law, such as in response to a valid court order or a request from a lawful authority, or to protect the rights, property or safety of our users, the public or us.

We do not sell personal information and we do not share it for cross-context behavioural advertising.

5. Do we transfer information outside your country?

We are based in Quebec, Canada. Our service providers may store and process information in other countries, including the United States. Where we transfer personal information outside Quebec or Canada, we assess the risks of the transfer and use contractual and other safeguards so that it receives protection comparable to what the law in your jurisdiction requires.

6. Do we use cookies?

Our marketing website sets Google Analytics cookies only if you accept them in the cookie banner. You can change your choice at any time with the Cookie settings link at the bottom of every page. The Premo Trading platform uses only strictly necessary cookies to keep you signed in and to protect forms. Details are in our Cookie Policy.

7. How long do we keep your information?

We keep personal information only for as long as we need it for the purposes in this notice, unless the law requires or permits a longer period:

• Account and trading data: while your subscription is active. If your subscription ends and you do not renew, we keep your account and trading data for 6 months so you can come back and continue where you left off, and then delete it. If you want it deleted sooner, ask us at dev@infradevconsulting.com and we will delete it once we have confirmed the request comes from you.
• Billing records: for as long as tax and accounting laws require, generally up to seven years.
• Server and security logs: for a limited period, typically no more than 12 months.
• Website analytics data: 14 months in Google Analytics, after which it is deleted.

When we no longer have a legitimate need, we delete or anonymize the information. If that is not immediately possible, for example because it is in backup archives, we store it securely and isolate it from further processing until it can be deleted.

8. How do we keep your information safe?

We use organizational and technical measures designed to protect your information, including:

• Encryption in transit: all connections to the website and platform use TLS (HTTPS).
• Account isolation: each account’s journal data is kept separate and is visible only to that account.
• Access controls: access to production systems and data is limited to authorized personnel who need it.
• Secure credentials: passwords are hashed, and application secrets are kept in a managed secrets store, not in code.
• Secure payments: card details are entered on Stripe’s hosted checkout and never touch our servers.

However, no electronic transmission or storage technology can be guaranteed to be 100% secure, so we cannot promise that unauthorized third parties will never be able to defeat our security. If a breach occurs that creates a risk of serious harm, we will notify you and the relevant authorities as the law requires.

9. What are your privacy rights?

Depending on where you live, you may have the right to:

• access the personal information we hold about you and get a copy of it;
• correct inaccurate or incomplete information;
• ask us to delete your information;
• receive your information in a structured, commonly used format (data portability);
• withdraw your consent, where we rely on it;
• object to or restrict certain processing.

To exercise these rights, contact us at dev@infradevconsulting.com. We may need to verify your identity before acting on a request. We will respond within the time the law requires, generally within 30 days. If you are not satisfied with our response, you may complain to your privacy regulator, such as the Commission d’accès à l’information du Québec or the Office of the Privacy Commissioner of Canada.

Marketing emails: you can unsubscribe at any time using the link in the email. We will still send service messages that are necessary to run your account.

Analytics cookies: you can withdraw your consent at any time with the Cookie settings link at the bottom of every page of our website.

10. Do-Not-Track signals

Most browsers include a Do-Not-Track (“DNT”) setting. Because there is no agreed standard for recognizing DNT signals, we do not currently respond to them. Our website does not track you across other sites in any case.

11. Do United States residents have specific privacy rights?

If you live in a US state with a consumer privacy law, such as California, you have the right to know what personal information we collect, to access it, correct it and delete it, and to opt out of its sale or sharing. We do not sell or share personal information as those laws define it.

In the past 12 months we have collected these categories of personal information:

You will not be discriminated against for exercising your rights. To make a request, contact us at dev@infradevconsulting.com.

12. Information about minors

The Services are not intended for anyone under 18, and we do not knowingly collect information from minors. If we learn that we have, we will close the account and delete the information. If you believe a minor has given us information, please contact us.

13. Updates to this notice

We may update this notice from time to time. The updated version will be marked with a new “Last updated” date. If we make material changes, we will notify you by email or in the platform before they take effect.

14. How to contact us

Our Privacy Officer, who is our person in charge of the protection of personal information, can be reached at:

Infradev Consulting Inc. (Premo Trading) 4-186 Pl. Sutton, Beaconsfield, QC H9W 5S3, Canada Email: dev@infradevconsulting.com Phone: 514-437-1864

This Privacy Policy is governed by the laws of the Province of Quebec and the federal laws of Canada applicable therein.