Privacy Policy
When you provide us with information through the logtolast.com website, we respect your privacy and do our best to protect and manage any personally identifiable information that you may share with us.
LogToLast LLC has adopted this Privacy Policy for the purpose of informing you about our policies regarding information collected from this website. We encourage you to read this Privacy Policy before using the website or submitting any information on it.
Data Controller Identity (GDPR Art. 13)
The Data Controller for personal data processed through this website and platform is:
LogToLast LLC
30 N Gould St, STE R, Sheridan, WY 82801, USA
Email: [email protected]
Support: [email protected]
LogToLast LLC does not currently meet the thresholds requiring a designated Data Protection Officer (DPO) under GDPR Article 37. However, all data protection inquiries, rights requests, and complaints are handled directly by our privacy team at the email address above. EU/UK residents may also lodge a complaint with their local Data Protection Authority (DPA).
Your Acceptance of Our Privacy Policy and Practices
Your use of this website constitutes your acceptance of this Privacy Policy and your consent to the related practices. We reserve the right to change our Privacy Policy and our terms and conditions at any time. We suggest that you periodically check for any updates to the Privacy Policy and terms and conditions.
Personally Identifiable Information
Personally Identifiable Information (PII): During registration, checkout, or account configuration, we collect information you voluntarily provide, which includes your name, email address, phone number, billing information (processed securely by our payment gateway), and discord username. We do not rent, share, or sell your information to any third party for any reason except as provided herein. Contact information that we collect may be used for our own internal tracking purposes and to provide you with information that you may be interested in.
Information that is not personal or associated with any personally identifiable data, such as questions, comments, ideas, and suggestions, shall be deemed to be non-confidential and we shall be free to disclose and use it for any purpose, without any obligation to you.
Data Collection, Usage, and Broker Integrations
To provide our services, you may provide us with API Tokens or credentials for third-party brokers (e.g., Tradovate, MetaTrader, NinjaTrader, Project X). We treat this data with the highest level of security:
- IP Addresses, Legal Consent, & Security: We capture and log your device's IP address during specific, critical actions on the platform. This includes when you accept our Terms of Service or Affiliate Agreements, serving as a legally binding digital signature of your consent. Furthermore, we temporarily log IP addresses to enforce rate-limiting (to protect our infrastructure from DDoS attacks) and permanently log them to run automated fraud-detection algorithms (e.g., preventing self-referral abuse in our Ambassador program).
- Google Single Sign-On (SSO): If you choose to register or log in using your Google account, we receive your Google User ID, email address, display name, and email verification status from Google's OpenID Connect service. We store your Google User ID to link your Google account to your LogToLast profile. We do not access your Google Drive, Calendar, Contacts, or any other Google service data.
- Pre-Launch & Marketing Lists: If you submit your email address via our "VIP List" or pre-launch subscription forms, we store your email address for the purpose of sending launch announcements and promotional communications. Your IP address is temporarily processed for anti-abuse rate-limiting but is not permanently stored alongside your subscription. You may unsubscribe at any time by contacting [email protected].
- Broker Integrations & OAuth: When connecting cloud-based brokers (e.g., Tradovate), we store industry-standard OAuth tokens. When using local terminals (e.g., MT5), your master broker passwords are NEVER transmitted to or stored on our cloud servers. They remain entirely on your local machine.
- Usage: These tokens are used strictly to execute trades and read account balances as directed by you. We do not use these tokens to withdraw funds or access unrelated personal data.
- Trading Activity (Live & Historical): We collect trade data including symbols, prices, timestamps, and profit/loss. This includes real-time trades executed via the platform and historical trade history fetched from your broker at your request. We use this data to populate your personal Trade Journal analytics and to calculate your ranking on the Leaderboard. The leaderboard uses a composite algorithmic score (referred to internally as a "trading performance score") to rank users. Participation in the Leaderboard is strictly opt-in. If you explicitly choose to enable this feature in your Account Settings, your anonymized performance metrics (stripped of your name, notes, and screenshots) may be displayed publicly on the Leaderboard.
- Identity & Account Ownership Verification: To verify ownership of connected brokerage accounts (e.g., for Prop Firm tracking or leaderboard eligibility), you may be asked to submit verification evidence. This data may include screenshots, account statements, or other proof documents stored as encrypted JSON metadata. Verification data is retained only as long as the associated account connection exists and is purged upon account deletion.
- Contact & Support Submissions: When you submit a message via our contact form or in-app feedback tool, we collect your name, email address, message content, and any optionally uploaded screenshots. This data is stored for customer support purposes and may be retained indefinitely for quality assurance and to track feature requests.
- AI Coach & Live Support System: We operate an integrated support system that handles both automated AI responses and human agent escalations within the same session. All support session transcripts โ whether handled entirely by AI, escalated to a human agent, or a combination of both โ are securely archived in our database for quality assurance, dispute resolution, and service improvement purposes. When a support session concludes, our AI system automatically analyzes the transcript to extract general technical Q&A pairs (question and its resolution) for inclusion in an internal Knowledge Base that improves future AI responses. This extracted knowledge is stored in anonymized, non-personally-identifiable form. The original transcript archive is linked to your account via your User ID and may be deleted upon a valid GDPR erasure request (see Your Rights section). AI Knowledge Base entries derived from your chat are general platform knowledge and do not contain personally identifiable information; their deletion is therefore not required under GDPR. By using the support system, you consent to the archiving of all support transcripts.
- Cloud Infrastructure Metadata: For users utilizing our cloud-hosted trading infrastructure, we may store technical identifiers such as virtual machine MAC addresses and proxy routing configurations. This data is used exclusively for infrastructure management and trade routing optimization and is not shared with third parties.
- Marketing Attribution Data (UTM Parameters): When you arrive at our website via a marketing link or advertisement (e.g., from Google Ads, social media, or a partner referral), we automatically capture and permanently store UTM parameters associated with your session (
utm_source,utm_medium,utm_campaign). This data is linked to your user account upon registration and is used to measure the effectiveness of our marketing campaigns. The lawful basis for this processing is our Legitimate Interest (GDPR Art. 6(1)(f)). - Behavioral Telemetry & Automated Persona Analysis: We collect and analyze your trading activity, journaling frequency, backtesting usage, Win Rate, and Profit & Loss history. This data is processed algorithmically on a regular schedule to assign an internal behavioral profile ("Behavioral Persona") to your account. Possible classifications include: Student (disciplined journaler), Gambler (high-frequency, low-discipline), Ghost (dormant/inactive), Titan (high-performer), and Cowboy (high-risk taker). This profiling is used strictly to power the AI Trading Coach's educational nudges and to trigger personalized retention communications (such as targeted discount codes). We also track: (a) account blowup events (the number of times a connected account has experienced significant capital loss, stored as
blowup_countandlast_blowup_at); and (b) your Journal Streak โ a running count of consecutive trading days on which every trade was accompanied by a journal entry. An unjournal'd trade day resets this streak to zero. The Journal Streak is used exclusively for gamification and is not shared externally. This data is used to provide contextual AI coaching, not shared externally. - Diagnostic Telemetry & Financial Syncing: To ensure platform stability, resolve technical execution errors, and maintain perfect Ledger synchronization, our systems generate local session logs and may periodically request automated transmissions of your raw historical trade data from your broker (e.g., MT5 deal history or Tradovate API responses). This data is processed dynamically to reconcile your dashboard PnL. Local session logs may be remotely fetched by our administration team for troubleshooting. These logs and data transmissions contain operational data, API responses, and strict trade execution sequences, but absolutely exclude master passwords or withdrawal credentials.
- Push Notification Tokens: To deliver real-time Risk Guard alerts, Watchdog synchronization warnings, and platform updates, we collect and store your Web Push API subscription tokens (
push_subscriptions_json). These tokens are device-specific identifiers that allow us to deliver browser push notifications directly to your device. We store your full notification preference settings, including any custom Quiet Hours window you configure (you may set any time range that suits you via Account Settings). You may opt out of non-critical notifications at any time via Account Settings. Certain critical operational alerts (billing notices, security breaches, platform synchronization failures) are classified as mandatory and cannot be disabled during the Beta phase, as they are required to protect the integrity of your connected broker accounts. - Win-Back & Re-engagement Marketing: If you cancel your subscription or your subscription expires and remains inactive for 14 or more days, our automated systems may include you in a re-engagement campaign. This involves automatically generating a single-use, time-limited personal discount code and sending you a targeted offer email via Resend. A re-engagement offer will not be resent within a 90-day cooling-off period. These communications are sent on the basis of our Legitimate Interest (GDPR Art. 6(1)(f)) in maintaining a business relationship. Each marketing email includes an unsubscribe link to opt out permanently.
- Funding Hub & Affiliates: If you use our Funding Hub, we may track outbound clicks on third-party prop firm links using cookies or similar tracking technologies for affiliate attribution. This allows us to earn commissions at no extra cost to you, ensuring our Fairness Score algorithm remains independent and free of sponsored rankings. If you participate in our Ambassador program, we collect necessary payout details (e.g., PayPal email address or Wise account details) and referral metrics to process your commissions. We do not support cryptocurrency payouts. Affiliate commission payouts are processed exclusively via PayPal or Wise (TransferWise).
- Account Portfolios (Personal Multi-Account Grouping): The platform allows you to create personal "Portfolios" โ a feature for grouping and viewing multiple of your own broker accounts together for consolidated performance analysis. Portfolios are strictly a personal organizational tool for accounts you own and control directly. This feature does not involve any form of third-party account management, copy-trading on behalf of others, or Managed Account (MAM/PAM) functionality. Portfolio groupings are stored in our database and are deleted upon account deletion.
- Discord Integration: If you link your Discord account via OAuth, we store only your Discord User ID (
discord_user_id). We do NOT store your Discord email, username, avatar, or any other Discord profile data. This data is used exclusively for: (a) synchronizing role-based access within our official Discord server (e.g., granting the "Pro" or "Elite" role to paid subscribers); and (b) sending automated platform status reports, prop firm milestone alerts, and performance summaries to designated Discord channels via our Discord Bot. Discord's own privacy policy governs their processing of data on their platform. - Passive Prop Firm Detection & Affiliate Tracking: When you connect a brokerage account, our system passively analyzes your broker account names and identifiers using pattern-matching logic to detect whether you are trading at a known Proprietary Trading Firm (e.g., detecting an account named "APEX-123456" as an Apex Trader Funding account). Once detected, the prop firm is permanently added to your
detected_prop_firmsprofile for affiliate attribution and personalized coaching purposes. We also track conversions (converted_prop_firms) and affiliate signal states. This passive tracking operates without requiring any manual action from you. The lawful basis is Legitimate Interest (GDPR Art. 6(1)(f)). - Affiliate Tax Form Verification (W-9 / W-8BEN): To authorize commission payouts to Affiliate Program participants, we use Track1099 (Avalara) to collect the necessary IRS tax documentation. The process is as follows: (1) We send you a secure email invite via Track1099 containing a link to their encrypted tax form portal; (2) you fill out your W-9 (US persons) or W-8BEN (non-US persons) directly on Track1099's platform โ LogToLast never sees, handles, or stores your tax identification numbers, SSN, or EIN at any point; (3) Track1099 notifies us of your completion status; (4) a LogToLast administrator manually reviews and approves your affiliate payout eligibility on our platform. We store only your verification status (
identity_verification_status: unverified/pending/verified/rejected) and your approved public affiliate handle (verified_identity_handle). All underlying tax document data is stored exclusively by Track1099/Avalara, subject to their own privacy policy. - Automated Profiling & Behavioral Telemetry: We collect and analyze your interaction data, trading frequency, Win Rate, and historical Profit & Loss (PnL). This data is processed algorithmically to assign behavioral profiles (e.g., assessing if an account exhibits high-risk or dormant trading patterns). We use this automated profiling strictly to power the AI Trading Assistant's educational coaching nudges, to optimize platform stability, and to deliver personalized promotional offers or retention communications (such as targeted discount codes). By using the platform, you explicitly consent to this automated behavioral analysis.
- Administrative & Support Access (Impersonation): To provide rapid technical support, resolve complex execution routing errors, and maintain platform integrity, authorized LogToLast administrators possess the ability to access your account data and simulate your user session ("Impersonation"). This access is strictly logged, audited, and utilized exclusively for troubleshooting, forensic trade reconstruction, and enforcing platform Terms of Service.
- Prop Firm Mathematical Synchronization: To track evaluation metrics without violating third-party anti-scraping rules, LogToLast relies exclusively on read-only Broker API tokens (e.g., Tradovate, MT5) combined with internal mathematical models. We do not require, store, or utilize your Prop Firm website portal credentials.
Payment and Billing Information
We use industry-standard, PCI-DSS compliant third-party payment processors (such as Stripe) to handle all financial transactions. Regarding your payment data:
- No Credit Card Storage: LogToLast LLC does not collect, store, or process your full credit card numbers, CVV codes, or secure bank account details on our servers. When you enter your payment information, it is transmitted directly to our secure payment processors.
- Retained Billing Data: We only store the necessary billing metadata required to manage your account and provide receipts. This includes your subscription status, billing history, invoice records, and a secure reference to your payment method (e.g., "Visa ending in 4242").
Institutional-Grade Data Security
Cryptographic Protection: All sensitive credentials, API keys, webhook tokens, OAuth refresh tokens, and broker authentication data (including Rithmic usernames, system names, and passwords) are encrypted at rest in our databases using AES-256-GCM cryptography with unique per-value nonces. Data in transit is secured via TLS/SSL and routed through enterprise-grade Cloudflare protection. Furthermore, we support and encourage Two-Factor Authentication (2FA) to secure your account access. This ensures that even in the unlikely event of a database breach, your connection credentials remain mathematically unreadable.
User-Generated Content (Notes, Tags & Images)
You may enrich your data by adding manual logs, strategy notes, custom tags, and screenshots to any trade type (Live, Historical, or Backtest). regarding this content:
- Confidentiality: Unlike raw performance data (e.g., "Win Rate"), your specific text notes, tags, and uploaded screenshots (including daily PnL cards) are treated as confidential. We do not display your journal notes or screenshots on any public platform unless you explicitly share a specific trade or certificate.
- Data Processing: We process this content algorithmically to provide you with behavioral insights (e.g., "Performance by Tag"). This processing is automated and performed solely to provide the Service to you.
- Image Storage: Screenshots uploaded via the Desktop App are stored on our secure servers. We do not scan image content for sensitive information. You are advised not to capture sensitive personal information (such as passwords or bank details) in your trading screenshots.
- Data Processing, AI Insights & Meta-Learning: We process your trading metrics, tags, and AI Coach chat transcripts algorithmically to provide behavioral insights. To generate these insights, we may transmit specific trading data and chat history to enterprise third-party AI service providers via secure APIs. Crucially, we exclusively partner with AI providers under strict "Zero-Data-Retention" and "No-Training" agreements. This means your data is processed momentarily to generate your personal insights and is never stored, sold, or used to train their public Large Language Models (LLMs). However, we do analyze your anonymized coaching interactions internally (via our "Meta-Learning" systems) to generate dynamic coaching rules and improve the effectiveness of our proprietary AI algorithms.
Data Ownership Guarantee
We believe that strong privacy means absolute data sovereignty. In stark contrast to many financial data brokers, your trade data remains entirely yours.
- No Intellectual Property Harvesting: We do not claim ownership over the trading strategies, risk algorithms, or behavioral patterns you log on our platform. We strictly will never use your proprietary trade setups to execute real capital trades for our corporate accounts (no internal front-running).
- No Data Monetization: We will never package, sell, rent, or lease your trading history, PnL statistics, or email address to third-party hedge funds, prop firms, or competing algorithmic firms.
Data Retention and Account Deletion
Account Deletion:
You have the right to request the deletion of your account from your Account Settings at any time. Upon deletion:
- Your account is immediately deactivated and all active broker connections are severed.
- Your personally identifiable information (PII) is flagged for permanent removal. We retain deactivated account data for up to 30 days in a "soft-deleted" state to allow for accidental deletion recovery and to fulfill legal obligations (e.g., resolving pending billing disputes or fraud investigations).
- After 30 days, all PII, trade history, broker tokens, uploaded files, and any aggregated statistical data associated with your account are permanently and irreversibly purged from our systems. Exceptions to Erasure (Tax & Legal): Financial transaction records (Subscription Payments, Commissions) and Affiliate IDs are retained but converted into "orphaned" records (user ID is nulled and all PII stripped) to comply with IRS and international tax accounting laws. We do retain anonymized AI coach chat logs and QA data for quality assurance and support improvement purposes after account deletion, but this data is fully stripped of any PII. Basic billing profiles and transaction records held by Stripe may be retained for a longer statutory period to comply with tax laws, anti-money laundering regulations, and chargeback dispute resolution.
General Browsing & Server Logs
We may use technology known as โcookiesโ or any other technology that tracks your travel through our site. Most browsers are set up to accept cookies. You may reset your browser so that these cookies are not accepted; however, if you do so, some of the functions of the website may be impaired.
Data gathered through cookies and general web server logs may include information such as the date and time of visits, the pages viewed, time spent at the site, your computerโs operating system, and browser software. For unregistered visitors, this data is analyzed in the aggregate and is not used to determine individual identity. However, when you log into your LogToLast account or perform legally binding actions (such as accepting terms or processing payments), this network telemetry (including your IP address) is explicitly linked to your user profile for security, fraud prevention, and legal compliance as outlined above.
Cookies and Web Technologies
A โcookieโ is a small text file that identifies your computer or device. When you visit our website, unique cookies are placed on your browser. A web beacon is a technology with a unique identifier that is typically contained in a small graphic file in a web page or in an email. We may use cookies and web beacons to identify that you have logged into the website, to hold selected products in your shopping cart when you navigate away from the order page, and to suggest content and products that may be of interest to you, and to monitor the aggregate usage of our website. We also use these technologies to measure the effectiveness of our advertising campaigns and to improve our website by recognizing which pages are visited and whether those visits result in purchases.
Session Cookies: When you log into your LogToLast account, we set a persistent session cookie with a maximum lifetime of 30 days. This cookie maintains your authenticated session and is HttpOnly (not accessible to JavaScript). You can clear this cookie by logging out or clearing your browser data.
Interest-Based Advertising
We work with advertising partners who may use technologies such as cookies to gather browsing information about you when you visit the website for the purpose of targeting our advertising to individualsโ unique interests. Our advertising partners may also gather information about your visits to other websites to gather information about your individual interests. We, as well as our advertising partners, may use this information to advertise our products to you on other websites that you visit or in emails that we send to you.
Analytics and Third-Party Tracking
We use third-party analytics services, including Google Analytics and Google Search Console, to collect and analyze information regarding visitor behavior, demographics, and website performance.
Google Analytics: We use Google Analytics to measure website traffic and usage. Google collects data via cookies (like IP address and browser type). For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google's processing of data by visiting http://tools.google.com/dlpage/gaoptout.
Activation and Consent: On our public-facing web pages and within the authenticated sections of our platform (e.g., the user dashboard), strictly necessary and functional tools required for security and fraud prevention run automatically. However, analytics and marketing cookies will only run if you have provided explicit consent via the Cookie Consent Banner.
Surveys, Sweepstakes, and Promotions
On this website, you may be able to participate in surveys, sweepstakes, and other promotions on our website. If you choose to participate, we may ask you to provide information such as your name, email address, postal address, and telephone number. We use this information to administer our contests, sweepstakes, and other promotions. We also may use the information to communicate with you about our products, services, and promotions.
Children's Privacy (COPPA)
LogToLast LLC is directed exclusively to adults aged 18 and over. Trading financial instruments is a complex adult activity, and our Terms of Service require users to be at least 18 years of age. We do not knowingly collect, solicit, or maintain any personal information from children under the age of 13 (or under 16 for users in the European Economic Area, as per GDPR Article 8).
If we become aware that we have inadvertently collected personal information from a child under the applicable minimum age without verifiable parental consent, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected] and we will investigate and remediate within 7 business days.
Legally Required Disclosure of Information
Although we strive to preserve the privacy of our visitors, we may be compelled to disclose personal information when required by law in situations where we have a good-faith belief that such action is legally required to comply with a judicial proceeding, court order, or other legal matter.
Third-Party Sub-Processors
This Policy only applies to information collected by our organization through this website and does not extend to any third-party websites. The following is a list of all third-party service providers (sub-processors) who process personal data on our behalf. Where GDPR applies, we have Data Processing Agreements in place with these processors.
| Service | Purpose | Data Processed | Location |
|---|---|---|---|
| Stripe | Payment processing & subscriptions | Billing info, subscription status | USA / EU |
| Google Gemini (Paid API โ model dynamically configured) | AI Coach language model | Your username, trading performance stats, last 60 trades incl. trade notes (free text), tags | USA (Zero-Data-Retention per Google Paid API Terms) |
| Google OAuth | Social authentication | Google User ID, email address, display name | USA |
| Google Analytics | Web traffic analytics | IP address, page views, device info (consent-gated) | USA |
| Discord OAuth & Bot | Social auth, role sync, platform alerts | Discord User ID, email, role assignments | USA |
| Resend | Transactional & marketing email delivery | Email address, name, email content | USA |
| Sentry | Application error tracking and crash reporting | IP addresses, error stack traces, browser metadata | USA |
| Cloudflare (CDN / WAF) | DDoS mitigation, SSL/TLS, Web Application Firewall | IP addresses, HTTP request metadata | USA / EU |
| Cloudflare R2 | Object storage for certificates & images | Generated PNG certificates, performance images | USA |
| Vultr | VPS hosting & cloud infrastructure | All server-side data | USA |
| Webshare | Dedicated IP proxy network for MT5/broker routing | Broker API requests (no user PII) | USA |
| Track1099 / Avalara | IRS 1099-NEC tax compliance | Affiliate name, email, compensation amount (SSN/TIN bypasses our servers) | USA |
| Wise (TransferWise) | Affiliate payout processing | Affiliate name, email, payout amount & banking details | UK / EU |
| ProjectX | Broker API integration | Account data, trade data | USA |
| Tradovate | Broker API integration | Account data, OAuth tokens, trade data | USA |
| Rithmic | Broker API integration | Account credentials (encrypted), trade data | USA |
| Forex Factory | Economic news calendar (scraping) | No user PII | USA |
| Google Ads (if applicable) | Conversion tracking for paid advertising | Anonymized conversion events (consent-gated) | USA |
* This list is updated regularly. For the most current version, email [email protected].
Tax Compliance Providers (Zero-Knowledge Collection): To facilitate affiliate payouts and comply with U.S. tax regulations (e.g., IRS Form 1099-NEC), we utilize Track1099 / Avalara. When you submit tax documentation (e.g., W-9, W-8BEN), you are securely redirected to their encrypted portal. We do not collect, process, transmit, or store your Social Security Number (SSN), EIN, or TIN on our servers at any time. We only receive a cryptographic status token to authorize payouts.
Artificial Intelligence & Automated Processing
Third-Party AI & Data Privacy: Our AI Coach feature uses Google Gemini via a paid API plan. The specific model used is dynamically configured by our team (you may contact [email protected] to request information about the currently active model). When you initiate an AI Coach session, the following data is transmitted to Google's API: your username (as a session context identifier), your aggregated trading statistics (total trades, Win Rate, Profit Factor, Expectancy), performance by session/time, journaling and tagging rates, your last 60 individual trades (including symbol, outcome, tags, and any free-text notes you have written), and a tilt warning flag if applicable. Under Google's Paid API Terms of Service, data submitted via the API is not used to train Google's models and is not retained beyond the duration of the API request. This is a contractual data protection guarantee, not a technical restriction enforced per-request.
Data Minimization & User-Triggered Activation: Our AI features do not actively scan, monitor, or process your trading data in the background. The AI Coach is strictly "user-triggered." It only activates and reads the specific context (e.g., recent trades or statistics) necessary for the session when you explicitly initiate a conversation by sending a message.
Ephemeral Sessions (Right to Erasure): We respect your right to be forgotten. Chat sessions with the AI Coach are ephemeral. By clicking "New Session" or exiting the chat interface, the active conversation history is cleared from our active memory, ensuring your raw conversational data is not perpetually stored.
EU AI Act (Article 50) Transparency & Logging: In compliance with the transparency obligations of the European Union Artificial Intelligence Act (EU AI Act, Article 50), we maintain an immutable, anonymized generation log of all AI interactions. When you consent to use our AI systems, we record the timestamp, the specific AI model version used, your input prompt, and the exact output generated. This log is maintained strictly for regulatory auditing, proving what the AI generated and when, and does not retain your Personally Identifiable Information (PII) beyond the necessary context. This data is not used for profiling or automated decision-making with legal effects.
Opt-In/Opt-Out Mechanism: The use of the AI Coach and the Backtest Lab CSV AI Mapper is entirely optional. You consent to the processing of your data by these tools only when you actively engage with them (e.g., by sending a chat message or clicking the "Auto-Map with AI" button). If you do not wish to use these features, you may simply abstain from interacting with the AI interface or choose to map your CSV columns manually, effectively opting out of automated processing.
Backtest Lab CSV AI Mapping: When importing files, you may opt to use our AI tool to recognize column headers. This tool only reads the first few rows (headers) of your file to assist with formatting. This process is ephemeral, and no file data is retained after the mapping is complete.
Anonymized Meta-Learning (Supervisor AI & QA Bot): To improve our services and support knowledge base, we utilize background Supervisor AI systems. These systems evaluate interactions to extract generalized patterns, rules (e.g., assessing AI response quality), and generic Q&A pairs. All Personally Identifiable Information (PII) is stripped during this process. The resulting abstract rules and questions are 100% anonymized and aggregated. As these insights can no longer be linked to any specific individual, they fall outside the scope of personal data deletion requirements under GDPR.
Traditional Algorithms vs. AI: Please note that certain automated features on our platform, such as the "Watchdog" alert system, the "Active Enforcer" Playbook rules engine, and standard statistical calculations, are driven by traditional, hard-coded software algorithms (rules engines). These are not Generative AI systems and do not utilize machine learning models to process your data.
Your California Privacy Rights (CCPA / CPRA)
This privacy notice for California residents supplements the information contained in this Privacy Statement of LogToLast LLC and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA"), and other California privacy laws. Any terms defined in the CCPA/CPRA have the same meaning when used in this notice.
a. The CCPA/CPRA provides consumers the following rights: (i) right to know what personal information is collected, used, shared, or sold; (ii) right to delete personal information; (iii) right to correct inaccurate personal information; (iv) right to opt out of the sale or sharing of personal information; (v) right to limit use of sensitive personal information; (vi) right to opt out of automated decision-making and profiling; and (vii) right to non-discrimination for exercising any CCPA/CPRA rights.
b. California consumers may request a report of their personal information no more than twice per 12-month period at no charge. Requests may be sent to: [email protected]. We respond within 45 days (extendable by an additional 45 days with notice).
c. Although we do not sell personal information for monetary consideration, sharing personal data with advertising partners for cross-context behavioral advertising may constitute a "sale" or "sharing" under CPRA. You may opt out at any time by emailing "Do Not Sell or Share My Personal Information" to [email protected].
d. We will not discriminate against you for exercising any of your CCPA/CPRA rights.
Global Privacy Control (GPC) โ Automatic Opt-Out
We recognize and honor the Global Privacy Control (GPC) signal as required under the CPRA (California) and Colorado CPA. If you have GPC enabled in your browser, our Consent Management Platform will automatically treat your visit as an opt-out from the "sale" and "sharing" of your personal data. No manual opt-out step is required. This applies even without a cookie banner interaction.
GPC is supported by browsers such as Brave and via browser extensions. For more information, visit globalprivacycontrol.org.
Your Canadian Privacy Rights
As defined under Canadian law, Personal Information means information about an identifiable individual (โPersonal Informationโ). The disclosures mentioned herein are meant to transparently convey the methods of collecting, managing, storing, using, protecting, and sharing Personal Information by users (โPrivacy Policyโ). Users grant their consent to this Privacy Policy through it being readily available for viewing in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA").
Your European Privacy Rights (GDPR / UK GDPR)
We undertake to respect the confidentiality of your personal data and to guarantee that you can exercise your related privacy rights. You have the right under this Privacy Policy, and by law if you are located in the EU or UK, to:
- Right of Access (Art. 15 GDPR): Request a copy of all personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
- Right to Erasure / “Right to be Forgotten” (Art. 17): Request deletion of your personal data, subject to legal retention obligations.
- Right to Restrict Processing (Art. 18): Request that we limit how we use your data under certain circumstances.
- Right to Object (Art. 21): Object to our processing of your personal data where we rely on legitimate interests.
- Right to Data Portability (Art. 20): Receive your personal data in a structured, machine-readable format and transfer it to another controller.
- Rights related to automated decision-making (Art. 22): Not be subject to solely automated decisions that have significant legal or similar effects. Our AI Coach provides educational suggestions only; all trading decisions remain entirely with you.
GDPR Lawful Basis (Article 6) โ How We Process Your Data
We process personal data only when we have a valid lawful basis under GDPR Article 6. The following table summarizes our key processing activities and their lawful basis:
| Processing Activity | Lawful Basis |
|---|---|
| Account registration & authentication | Contract (Art. 6(1)(b)) |
| Broker API token storage & trade routing | Contract (Art. 6(1)(b)) |
| Billing & subscription management | Contract (Art. 6(1)(b)) |
| Trade journal & analytics | Contract (Art. 6(1)(b)) |
| AI Coach interactions | Consent (Art. 6(1)(a)) โ user-triggered |
| Marketing emails & newsletters | Consent (Art. 6(1)(a)) |
| Fraud detection & security | Legitimate Interest (Art. 6(1)(f)) |
| Affiliate program management & tax compliance | Legal Obligation (Art. 6(1)(c)) + Contract |
| Data breach notification to authorities | Legal Obligation (Art. 6(1)(c)) |
| UTM / marketing attribution tracking | Legitimate Interest (Art. 6(1)(f)) |
| Behavioral profiling (persona engine) | Legitimate Interest (Art. 6(1)(f)) + Consent |
| Push notification delivery | Consent (Art. 6(1)(a)) โ opt-in |
| Win-back & re-engagement marketing | Legitimate Interest (Art. 6(1)(f)) |
| Discord role sync & bot alerts | Consent (Art. 6(1)(a)) โ user links account |
| Passive prop firm detection (affiliate attribution) | Legitimate Interest (Art. 6(1)(f)) |
Data Export: To exercise your right to data portability, contact us at [email protected] to request a machine-readable export of your personal data, including trade history, journal notes, tags, and backtest sessions. We will fulfill such requests within 30 days (GDPR) / 30 days (UK GDPR).
You may exercise your GDPR rights by contacting us at [email protected]. We may ask for verification of your identity before responding. We will respond as soon as possible and within the legally required timeframe.
You have the right to file a complaint with a Data Protection Authority (DPA). For EU residents: contact your local DPA (list available at edpb.europa.eu). For UK residents: the Information Commissioner's Office (ICO) at ico.org.uk.
al Data Protection Authority for more information.Your Australian Privacy Rights
We may collect, hold, use and disclose personal information to carry out our functions or activities in compliance with the Privacy Act 1988 (Privacy Act) and in particular the Australian Privacy Principles (APPs) found in that Act.
Collection of personal information: Personal information (including sensitive information) about you may be collected by use from you, from your agent, or from a third party.
We may also collect personal information through our website and social networking services such as Facebook, YouTube and Twitter. We use this information to help us communicate with you and the public.
Use and disclosure of personal information: We may use and disclose collected information, including personal information, for the primary purpose for which it was collected. Finance may also use and disclose your personal information for a secondary purpose where an exception in the APPs applies.
Access to and correction of personal information: Under the Privacy Act you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information.
You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect.
How to make a complaint: You can complain to us in writing about how we have handled your personal information. We will respond to the complaint within 30 days.
If you have questions and/or concerns about our Privacy Policy, our customer service department can be reached via email at [email protected].
Partnership Allocations and Tracking
To provide users with personalized institutional allocations and platform recommendations, LogToLast analyzes aggregate trading metrics. We may partner with third-party evaluation firms to secure preferred rates. When you utilize a partnership link, we may receive compensation at no additional cost to you. This enables us to maintain our analytics infrastructure.
Automated Analytics and Personalized Recommendations: We process broker state data (including account balances, longevity, high water marks, and payout frequency) to provide "Automated Analytics and Personalized Platform Recommendations". For example, users demonstrating consistent profitability or multiple payouts may be algorithmically routed through our Ascension Pipeline and recommended Live Brokers (e.g., Blueberry Markets) to trade their own capital.
China & PIPL Notice
LogToLast does not actively market its services within the People's Republic of China and does not maintain data processing infrastructure subject to China's Personal Information Protection Law (PIPL). If you access the Service from within China, you do so at your own risk and without warranty of availability. We do not represent that this Privacy Policy satisfies PIPL requirements for cross-border data transfer. We reserve the right to restrict or terminate access for users in China at any time.
Data Breach Notification
In the event of a confirmed data breach that compromises your personally identifiable information, LogToLast LLC will notify affected users via email within 72 hours of becoming aware of the breach, in compliance with GDPR Article 33 and other applicable regulations. We will also notify the relevant Data Protection Authority where required by law.
Leaderboard Visibility
Participation in the public leaderboard and searchable profiles is strictly opt-in. Your performance data will not appear in public rankings or search results unless you explicitly choose to enable this feature in your Account Settings. You may revoke this consent and opt out at any time.
Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Email: [email protected]