Legal
Privacy Policy
Last updated: May 2025 · Effective upon app launch
1. Who We Are
TutorTrade is developed and operated by SkewSense. For privacy-related inquiries, contact us at: privacy@skewsense.com
2. Information We Collect
2.1 Information you provide directly:
- Email address (when joining the waitlist or creating an account)
- Portfolio data you manually enter (tickers, share quantities, average cost)
- Watchlist and preferences you configure within the app
2.2 Information collected automatically:
- Device information (model, OS version, app version)
- Usage data (features accessed, session duration, crash reports)
- IP address and approximate location (country/region level only)
2.3 Information we do NOT collect:
- We do not access your brokerage accounts or execute trades on your behalf
- We do not collect payment card details directly (handled by Apple In-App Purchase)
- We do not sell your personal data to third parties
3. How We Use Your Information
- To provide and improve the TutorTrade Service
- To send launch notifications and product updates (you may unsubscribe at any time)
- To personalise AI signals and alerts based on your tracked names
- To diagnose technical issues and improve app stability
- To comply with legal obligations
We do not use your portfolio data to train general-purpose AI models without your explicit consent.
4. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, we process your data under the following legal bases:
- Contract performance — to deliver the Service you signed up for
- Legitimate interests — to improve our product and prevent fraud
- Consent — for marketing communications (you may withdraw at any time)
- Legal obligation — where required by applicable law
5. Data Sharing
We share data only with trusted service providers that process it on our behalf:
- Cloud infrastructure — hosting and data storage (e.g. AWS or equivalent)
- Analytics — aggregated, anonymised usage metrics
- Payment processing — Apple In-App Purchase (Apple's privacy policy applies)
- Email delivery — to send launch and product updates
All processors are bound by data processing agreements and may not use your data for their own purposes.
6. Data Retention
We retain your data for as long as your account is active or as needed to provide the Service. If you delete your account, your personal data is deleted within 30 days, except where retention is required by law.
Waitlist email addresses are deleted upon your request or within 90 days of the app launch if you do not convert to a registered user.
7. Your Rights
Depending on your location, you may have the following rights:
- Access — request a copy of the personal data we hold about you
- Rectification — request correction of inaccurate data
- Erasure — request deletion of your personal data ("right to be forgotten")
- Portability — receive your data in a machine-readable format
- Objection — object to processing based on legitimate interests
- Withdrawal of consent — where processing is based on consent
To exercise any of these rights, email us at privacy@skewsense.com. We will respond within 30 days.
8. Children's Privacy
TutorTrade is not directed at children under the age of 17. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us immediately and we will delete it.
9. Data Security
We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit (TLS), encryption at rest, and access controls. However, no method of transmission over the internet is 100% secure.
10. International Transfers
Your data may be processed in countries outside your own. Where we transfer data from the EEA to a third country, we do so under Standard Contractual Clauses or other lawful transfer mechanisms as required by GDPR.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email (if provided) or through the app. Continued use of the Service after changes constitutes acceptance of the updated policy.
12. Contact
For any privacy-related questions or requests:
SkewSense
Email: privacy@skewsense.com
If you are located in the EU/EEA and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local supervisory authority.