How FirmGated handles your data.

Last updated: July 2, 2026

Please read this Privacy Policy carefully to understand how FirmGated treats your personal information and what choices and rights you may have. If you do not agree with this Policy, do not access or use the Site or Platform.

Introduction

FirmGated ("FirmGated," "we," "us," or "our") respects the sensitive nature of personal information you provide. We are committed to protecting the privacy and security of information we collect, use, share, and otherwise process. This Policy, together with our Terms of Service and any documents referenced therein, describes how we treat information for visitors to firmgated.com (the "Site") and users of our Platform.

When does this Policy apply? This Policy describes our online information collection, storage, and disclosure practices and the choices you have regarding your personal information. By accessing or using the Site or Platform, or by otherwise signaling agreement when presented with that option, you consent to the practices described here. This Policy governs the Site and Platform only and does not govern offline collection. Materials submitted through the Site and your use of the Platform are also subject to our Terms of Service.

Residents of the EU/EEA. If you are located in the European Economic Area, please review the "Rights of EEA Residents" and "International Data Transfers" sections below.

How Do We Collect and Process Your Information?

We collect, receive, and process personal information for the purposes described below and in the "Other Processing Activities" section. If you are in the EU or EEA, FirmGated acts as a data controller for this information. We collect information from you via the Site and may also receive information from third parties, business partners, Affiliates, or publicly available sources.

Is entry of personal information required? You may choose not to provide personal information and may still access portions of the Site. However, you will not be able to use features that require registration, broker connections, billing, or authenticated workspace access.

• Contact Information. When you visit the Site, request services, or contact us, we may collect your name, mailing address, telephone number, and email address. We use this information to provide the Site and Platform, honor contracts, secure our services, maintain databases and backups, manage relationships, communicate with you, and keep records. The legal basis is consent or, where applicable, legitimate interests in operating our business and performing a contract with you.
• Account Information. When you register, we collect your email address, display name, username, password hash, authentication metadata, and related account settings. We use this information to provide services, secure accounts, manage relationships, and communicate with you. The legal basis is consent or legitimate interests and contract performance.
• Payment Information. If you purchase a paid subscription, our payment processor collects billing address and payment card details. By submitting payment information, you consent to sharing it with payment processors and related service providers, including fraud detection vendors. FirmGated does not store full payment card numbers on its own systems.
• Broker Tokens and Connection Data. If you connect broker or prop firm accounts, we may process OAuth tokens, API keys, account identifiers, provider names, account types, usernames, connection status, and related authorization metadata. Some integrations briefly process credentials to obtain tokens from the broker. We retain tokens needed to maintain authorized connections but do not retain raw brokerage passwords beyond what is necessary for the approved connection workflow. Broker credentials are encrypted before storage and kept separate from other account data where applicable.
• Trade and Workflow Records. We collect strategy names, webhook payloads, tickers, actions, quantities, timestamps, execution results, safeguard events, market regime states, subscription settings, and administrative workflow history needed to operate your workspace and provide support.
• Social Network Information. If you connect through a third-party social network, we may receive profile information such as your name, username, and email address from that network. Social sharing features may allow information to flow between the Site and third-party networks. Review each network's privacy policy before using such features.
• Cookies and Similar Technologies. When you visit the Site, we use cookies and similar technologies as described below. Disabling certain cookies may limit Site functionality.
• Usage Data. We automatically collect browser and device information, including date and time of visit, approximate location derived from IP address, IP address, device identifiers, device type, browser type, domain, access times, and pages viewed. We use this to operate the Site, analyze usage, improve services, detect abuse, and enhance security.
• Your Communications and Feedback. If you contact us, we collect the content of your message and information needed to respond. If you receive email from us, we may use tools to capture open, click, and delivery metadata, including your email address, message identifiers, timestamps, and destination pages.

Other Processing Activities

Where permitted by law, we may also process personal information when required by law; to create, use, retain, or disclose de-identified or aggregated data; or when necessary for:

• The establishment, exercise, or defense of legal claims;
• Obtaining or maintaining insurance coverage, managing risk, or obtaining professional advice; and
• Purposes consistent with, related to, or ancillary to the purposes described in this Policy.

We may rely on one or more of the following legal grounds:

• Performance of services you requested or contractual obligations between you and us;
• Compliance with legal obligations and recordkeeping;
• Legitimate interests that are not overridden by your rights and freedoms;
• Information you choose to publish in public areas of the Site;
• Protection of vital interests;
• Performance of a task in the public interest; or
• Your express consent.

We do not use personal information to make automated decisions affecting you or to create profiles except as described in this Policy.

Cookies and Similar Technologies

A "cookie" is a small file stored on your device for use during a browsing session or across future sessions. Session cookies expire when you close your browser. Persistent cookies remain until they expire or are deleted. First-party cookies are set by firmgated.com. Third-party cookies are set by other parties.

We may also use web beacons, pixels, log files, server logs, social widgets, and UTM tracking parameters to understand browsing activity and campaign attribution.

What cookies and similar technologies do we use?

• Strictly necessary cookies used for authentication, session management, and security;
• Preference cookies that remember settings you choose;
• Analytics cookies that help us understand how the Site is used; and
• Third-party technologies deployed by service providers for hosting, analytics, payment processing, or communications, subject to their own policies.

Most browsers accept cookies by default. You may refuse cookies through browser settings or any consent banner we provide, but some features may not function properly. Adjusting cookie settings may not delete cookies already stored; you may need to clear them in your browser. Browser help pages for Chrome, Firefox, Safari, and Edge contain instructions for managing cookies.

How and When Is Your Information Shared?

We may share information in the contexts below. We do not sell personal information for third-party marketing purposes.

• Corporate Affiliates. We may share information with subsidiaries and Affiliates and their officers, directors, employees, accountants, attorneys, and agents.
• Service Providers. We engage third parties for hosting, databases, caching, email, payment processing, fraud detection, analytics, customer support, and other operational functions. Information is shared only to the extent necessary for them to perform services for us.
• Legal Obligations and Rights. We may disclose information to law enforcement or government agencies when required by law or to limit fraud. We may also disclose information when we believe disclosure is necessary to protect our rights, comply with legal process, investigate claims, protect safety, or prevent illegal activity or violations of our Terms of Service.
• Acquisitions and Similar Transactions. We may share information in connection with a merger, acquisition, reorganization, asset sale, or bankruptcy.
• Disclosures with Consent. We may share information with other third parties when you consent.
• De-identified or Aggregated Data. We may disclose aggregated or de-identified information that does not reasonably identify an individual.

Trade Data and Intellectual Property

FirmGated treats your trade records, strategy configuration, and workflow history as your data. We do not monitor, observe, or use your trade data for proprietary strategy development except as needed to operate the Platform, provide support you request, secure the service, or as described in our Terms of Service regarding de-identified and aggregated usage data.

When you open a support request, authorized personnel may temporarily access relevant account and trade data to troubleshoot the issue. Access is limited to active support sessions.

How Long Do We Store and Process Your Information?

We retain personal information for as long as you use our services or as necessary to fulfill the purposes for which it was collected, provide services, resolve disputes, establish legal defenses, conduct audits, enforce agreements, and comply with applicable law.

We delete personal information when we have a legal obligation to do so, no longer have a legitimate purpose for retention, or you request deletion unless retention is required for legal, regulatory, contractual, or dispute-resolution obligations. Deleted information may remain in backups or archives when immediate deletion is not practical.

We may retain anonymous or aggregated information for reporting, benchmarking, analytics, and product improvement where permitted by law.

How Do We Protect Your Personal Information?

We take commercially reasonable steps to protect personal information against unauthorized disclosure, use, access, alteration, or loss. Broker credentials are encrypted before storage where applicable and kept separate from other account data. We review security practices periodically as technology evolves.

No security system is perfect, and no Internet transmission is guaranteed to be fully secure. You transmit information at your own risk. We cannot promise absolute security in all circumstances.

You are responsible for maintaining the confidentiality of your account credentials and restricting access to your devices. Notify us immediately at support@firmgated.com if you believe your information is being misused.

If a security breach compromises your data, we will notify you and applicable regulators when required by law.

Your Rights and Choices Regarding Personal Information

Contact us using the details at the end of this Policy to exercise applicable rights.

• Communication Preferences. You may opt out of promotional emails by using the unsubscribe link or contacting us with your name, mailing address, phone number, and email address. Legal, security, and account-related communications may not be opt-outable.
• Cookies. You may manage cookies through browser settings or our consent tools where available.
• Online Tracking Signals. We do not currently respond to "Do Not Track" browser signals.
• Accuracy and Updates. Keep your account information current. Contact us to correct inaccurate information. You represent that information you provide is true and relates to you, not another person.
• Complaints. If you believe your privacy rights have been violated, contact us using the details below.

California Residents

Under California Civil Code Section 1798.83, California residents may request information about certain sharing with third parties for direct marketing purposes. At present, we do not share personal information with third parties for their direct marketing purposes. California users may update their information by contacting support@firmgated.com.

If you are a California resident, you may also have rights under the California Consumer Privacy Act and California Privacy Rights Act, including rights to know, delete, correct, and opt out of certain processing. Submit verified requests to legal@firmgated.com.

Nevada Residents

Nevada residents may submit a verified request asking us not to sell covered information as defined under Nevada law. Include your name and contact information. We will respond in accordance with Nevada law.

Rights of EEA Residents

If you are located in the EU or EEA, you may have the following rights under the GDPR, subject to applicable law:

• Right of access to confirmation of processing and a copy of your personal data;
• Right of rectification of inaccurate data;
• Right to erasure in certain circumstances;
• Right to restrict processing in certain circumstances;
• Right to object to processing based on legitimate interests or for direct marketing;
• Right to withdraw consent where processing is based on consent; and
• Right to lodge a complaint with a supervisory authority.

Submit requests to legal@firmgated.com. A list of EU supervisory authorities is available at edpb.europa.eu/about-edpb/board/members_en.

International Data Transfers

FirmGated is established in the United States. Your personal information may be transferred to, stored in, or processed in the United States and other countries where we or our service providers operate. Laws in those countries may differ from the laws of your jurisdiction.

By using the Site or Platform, you understand and consent to international transfer of your information for the purposes described in this Policy. Where required, we rely on appropriate safeguards such as standard contractual clauses or your consent.

Links to Other Sites

This Policy applies only to the Site and Platform. The Site may contain links to third-party websites, brokers, exchanges, signal providers, or embedded media. We do not control third-party privacy practices and are not responsible for their content, security, or policies. Personal information collected by a third party is governed by that party's privacy policy.

Children Under 18

The Site and Platform are intended for adults eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we collected information from a child under 18 without appropriate consent, we will delete it as quickly as possible. Parents or guardians who believe a child provided information to us should contact legal@firmgated.com.

For more information about COPPA, visit the FTC's COPPA page.

Updates and Changes to This Policy

We may update this Policy at any time to reflect changes in our practices or legal requirements. When we do, we will revise the "Last updated" date and post the revised Policy on this page. Material changes may also be communicated by email or a notice on the Site.

You are responsible for reviewing this Policy periodically. Continued use after the updated date indicates acceptance of the revised Policy. If you do not agree, stop using the Site and Platform.

Contact Us

For questions about this Policy, to exercise your rights, or to lodge a complaint, contact us at:

• Email: support@firmgated.com
• Legal and privacy requests: legal@firmgated.com