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Privacy Policy

Last updated: July 27, 2026

Data controller: TNA Traders Networking Allegiance Ltd — tna@tna.live

What We Collect

When you use TNA Traders Networking Allegiance Ltd, we collect and store:

  • Authentication Data: Email address, hashed password, name, and profile information. If you sign in via Google OAuth, we receive your Google email and display name — we do not store your Google password.
  • Profile Information: Username, bio, profile picture, and background image that you choose to provide or upload.
  • Payment & Subscription Data: Subscription tier, billing status, founding member status, and trial usage. Payment card details are handled entirely by our payment processor — we do not store your card numbers or bank details directly.
  • Per-Trader Subscription Data: Which individual traders you subscribe to, subscription status, and associated billing records for each per-trader subscription. This is a separate billing relationship from your platform-wide subscription tier — see "Per-Trader Subscriptions" below.
  • Microphone Audio (Fusion Voice Bridge): When you participate in a Fusion Room session, TNA accesses your microphone directly — not via OBS or your streaming platform — to enable real-time voice communication with other participating traders. Audio is transmitted live for the duration of the session and is not recorded or stored by TNA.
  • Content You Create: Livestream data (video IDs), community posts, comments, chat messages, Q&A session questions and answers, and — in Live Coaching and Mentor-Protégé Fusion sessions — owner-editable session notes (Key Notes, Indicators Used, Strategy, Strategy Revised, Protégé Notes).
  • Trading Execution Data: When you connect a Rithmic account, TNA captures and permanently stores your trade execution records (entry/exit prices, P&L, timestamps, instrument, direction). This data forms your Financial Identity Ledger and is subject to immutability controls — see below.
  • Trading Credentials: Rithmic username, password, system name, and gateway are stored encrypted using AES-256. Decrypted values are only used at connection time and are never returned to the client. There is no way to disconnect a Rithmic account other than archiving it, which permanently and immediately deletes these credentials — see "Data Retention Policy" below. The account's display name (e.g. "Apex 1") and its trade history are kept so your existing journal stays attributable.
  • Account Balance Snapshots: For connected Rithmic accounts, end-of-session account balance snapshots may be stored as received from the Rithmic data feed.
  • Social Interactions: Follows, likes, reactions, and other engagement with the platform.
  • Usage Data: Session information, access logs, and platform activity.
  • Preview Link Access: If you generate a time-limited preview link, we store the token, its expiry, and the associated stream. Access events are logged.

Legal Basis for Processing (GDPR)

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

  • Contract (Article 6(1)(b)): Processing your account data, subscription data, and authentication information is necessary to provide the platform services you signed up for.
  • Consent (Article 6(1)(a)): By connecting a Rithmic account, you explicitly consent to TNA capturing and permanently storing your trade execution data in the Financial Identity Ledger. You may withdraw consent by disconnecting your Rithmic account(s) at any time — this stops future capture but does not delete records already stored, as explained below. You also consent to profile picture and background image storage when you upload them. By joining a Fusion Room session, you consent to TNA accessing your microphone for the duration of that session.
  • Legitimate Interests (Article 6(1)(f)): We process usage data, logs, and session information to operate and improve the platform securely, detect abuse, and maintain platform integrity. We have assessed that these interests are not overridden by your privacy rights.
  • Legal Obligation (Article 6(1)(c)): We retain billing and payment records for 7 years to comply with UK tax law and financial regulations.

Financial Identity Ledger & Immutable Trade Records

TNA operates a Financial Identity Ledger — a permanent, tamper-resistant record of your trading executions sourced directly from connected Rithmic accounts. Key characteristics:

  • Immutability: Trade records cannot be deleted or altered once written. Database-level triggers enforce this — only personal annotations (sentiment tags and notes) may be updated.
  • Background Capture: Rithmic connections are persistent and per-user. Trades are captured continuously in the background regardless of whether you are actively streaming.
  • Multi-Account Support: Multiple Rithmic accounts may be connected simultaneously.
  • Account Archiving: Archived accounts are hidden from active analytics but their trade history is permanently preserved and cannot be deleted.
  • Purpose: This ledger exists to provide verified, trustworthy performance transparency. By connecting a Rithmic account, you consent to this permanent capture and storage of your execution data.
  • Retention after account deletion: Because the Financial Identity Ledger is immutable by design, trade execution records cannot be erased even upon account deletion or deactivation. The user_id and account references on those records are anonymised (set to NULL) upon account anonymisation, effectively de-identifying them.

Why We Collect It

We use your data to:

  • Provide and operate the TNA platform
  • Enable you to share livestreams, track trades, and interact with other traders
  • Maintain your verified trading identity and performance record
  • Protect against abuse and maintain platform security
  • Improve the platform and develop new features
  • Communicate with you about platform updates
  • Comply with legal and tax obligations

Data Security

We implement industry-standard security measures:

  • All data is encrypted in transit (HTTPS/TLS 1.2/1.3)
  • Database encryption at rest (AES-256)
  • Rithmic trading credentials encrypted at rest using AES-256 — decrypted only at connection time, never returned to the client
  • Passwords hashed using bcrypt — plaintext passwords are never stored
  • Secure session management with HttpOnly cookies
  • Input sanitization to prevent XSS and injection attacks
  • Rate limiting on authentication and sensitive endpoints
  • Role-based access control and server-side authorisation on all API routes
  • Database-level immutability triggers on trade records

Sub-Processors & Third-Party Services

We do not sell your personal data. TNA acts as the data controller. To operate the platform, we work with a limited number of trusted service providers across the following categories: cloud infrastructure and hosting, database storage, file storage, session management, payment processing, real-time communication, transactional email, authentication, video verification, and live trading data feeds.

Each provider is bound by appropriate data processing agreements and applicable data protection law. A full list of our current sub-processors is available on request — contact tna@tna.live.

Some embedded features (video playback, GIF search) may set their own cookies according to their respective privacy policies.

Fusion Traders & Collaborative Sessions

Fusion Rooms support up to six traders across five session types (Classic Merge, Trade Battle, Strategy Face Room, Live Coaching Room, and Mentor-Protégé Room). In a Fusion session:

  • Participating traders' real-time trading statistics are displayed in a combined view
  • Chat messages from all participating streams are merged and attributed per trader
  • Participation requires explicit acceptance of a Fusion invite — you will not be included without consent
  • Each trader independently controls their own account display mode and data visibility
  • Voice communication uses direct microphone access — see "Microphone Audio" above
  • In Live Coaching and Mentor-Protégé sessions, the session owner (mentor) can add notes (Key Notes, Indicators Used, Strategy, or Strategy Revised) that become visible to participants and, once populated, to the audience. In Mentor-Protégé sessions, the protégé can add their own improvement notes, always visible to participants.
  • Live Coaching and Mentor-Protégé sessions are only accessible to a student/protégé who holds an active per-trader subscription to that specific mentor

Per-Trader Subscriptions

TNA offers per-trader subscriptions — a standalone add-on, separate from your platform-wide subscription tier, that lets you subscribe directly to an individual trader.

  • We store which traders you are subscribed to, your subscription status for each, and associated billing records
  • Per-trader subscriptions are billed and processed through the same payment processor as platform subscriptions
  • A per-trader subscription grants access to that trader's VIP Room streams and, where applicable, their Live Coaching and Mentor-Protégé Fusion sessions — it does not grant access to trading analytics or stats, which separately require a Viewer or Bundle platform tier
  • You may cancel a per-trader subscription at any time through the payment processor's billing portal

VIP Room Streams

Traders may designate an individual livestream as a "VIP Room." Access to a VIP Room stream requires an active per-trader subscription to that specific trader, verified server-side each time the stream is accessed. Non-subscribers see a prompt to subscribe rather than the stream itself.

TNA World & Affiliate Links

  • Affiliate Links: TNA World pages contain affiliate links. When you click and sign up or purchase, TNA may receive a referral commission at no additional cost to you.
  • No Personal Data via Affiliate Links: We do not collect personal data when you click affiliate links. Affiliate tracking parameters identify TNA as the referrer — they do not contain your personal information.
  • Discount Codes: Provided by third-party partners. We do not guarantee validity or availability.
  • Third-Party Cookies: Third-party websites accessed through affiliate links may set their own cookies. TNA has no control over these practices.

Cookies and Session Data

We use cookies, session storage, and similar technologies in two categories:

  • Strictly necessary (always on, no consent required): maintaining your login session (HttpOnly secure cookies), remembering your preferences and settings, and authenticating real-time connections for live chat.
  • Analytics (only after you consent): we use PostHog, an EU-hosted analytics provider, to understand product usage. PostHog only loads and begins recording after you accept analytics cookies in our cookie consent banner — see below. We do not use advertising cookies.

Session cookies expire after 30 days of inactivity or when you log out. You can change your cookie consent choice at any time from the "Cookies" link in the site footer. Third-party embeds may set their own cookies independently.

Account Deactivation & Anonymisation

When you deactivate your account:

  • Your subscription is cancelled immediately.
  • Your account enters a 90-day grace period during which you can reactivate it at any time by logging back in.
  • After the 90-day grace period, if you have not reactivated, your account is anonymised: email address, name, username, phone, address, city, state, postal code, country, profile picture, bio, and Google ID are permanently set to NULL.
  • Any Rithmic accounts on your profile are archived and their credentials (username, password, system name, gateway, Rithmic account ID) are permanently deleted — the same wipe that happens when you archive an account yourself. Trading account display names (e.g. "Apex 1") are kept.
  • Trade records in the Financial Identity Ledger are de-identified (user_id and account references set to NULL) but the execution data is retained in accordance with our immutability policy.
  • Community posts and chat messages are de-identified (user_id set to NULL) but may remain visible as anonymous content.

This anonymisation process runs automatically each day via a scheduled background task. It is irreversible — once anonymised, your account cannot be recovered.

Data Retention Policy

This section sets out how long TNA retains different categories of personal data, why we retain it for those periods, and what happens to it afterwards. It reflects our compliance posture under UK GDPR and EU GDPR.

Data CategoryRetention PeriodLegal BasisAction at Expiry
Account & Profile DataDuration of active account + 90-day grace period after deactivationContract (Art. 6(1)(b)); Legitimate interestsAnonymised — email, name, username, profile picture, bio, Google ID set to NULL
Authentication CredentialsDuration of active account + 90-day grace periodContract (Art. 6(1)(b))Deleted / set to NULL on anonymisation
Rithmic Trading CredentialsUntil account is archived (the only way to disconnect it) or the user account is anonymisedConsent (Art. 6(1)(a))Username, password, system name, gateway, and Rithmic account ID are deleted immediately on archiving or account anonymisation. The account's display name and trade history are kept.
Trade Execution Records (Financial Identity Ledger)Permanent — immutable by designConsent (Art. 6(1)(a)); Legitimate interests (platform integrity)De-identified on account anonymisation — user_id and account references set to NULL. Execution data retained anonymously.
Account Balance SnapshotsPermanent — tied to Financial Identity LedgerConsent (Art. 6(1)(a))De-identified on account anonymisation
Community Posts & CommentsUntil deleted by user, or until account anonymisationContract (Art. 6(1)(b))user_id set to NULL on account anonymisation — content may remain visible as anonymous
Chat MessagesRetained for stream replay and audit; anonymised with accountContract; Legitimate interestsuser_id set to NULL on account anonymisation
Livestream DataDuration of active accountContract (Art. 6(1)(b))Stream records retained; user association anonymised on account anonymisation
Session Data30 days from last activity, or until logoutContract (Art. 6(1)(b))Automatically purged on expiry or logout
Payment & Billing Records7 years from transaction dateLegal obligation (Art. 6(1)(c)) — UK tax law, HMRC requirementsSecurely deleted after 7 years
Preview Link TokensUntil link expiry dateContract (Art. 6(1)(b))Automatically cleared after expiry
Access & Security Logs90 daysLegitimate interests (security, fraud prevention)Automatically deleted after 90 days
Email Verification Tokens24 hours from issuanceContract (Art. 6(1)(b))Automatically invalidated after 24 hours
Password Reset Tokens1 hour from issuanceContract (Art. 6(1)(b))Automatically invalidated after 1 hour
Q&A Session RecordsDuration of associated stream recordContract (Art. 6(1)(b))Anonymised (user_id set to NULL) on account anonymisation
Profile Pictures & Background ImagesUntil replaced or account anonymisedConsent (Art. 6(1)(a))Deleted from file storage on account anonymisation

The 90-Day Deactivation Grace Period

When a user deactivates their account, we do not immediately delete or anonymise their data. Instead, a 90-day grace period begins. During this window:

  • The account is inaccessible and the subscription is cancelled.
  • The user can reactivate at any time by logging back in — all data is restored.
  • After 90 days without reactivation, an automated daily background task identifies expired accounts and irreversibly anonymises them.

Financial Identity Ledger — Special Consideration

Trade execution records are subject to database-level immutability controls: records cannot be deleted or altered once written, even by administrators. This is enforced via database triggers.

This immutability is a core feature of TNA's verified performance transparency model, and users explicitly consent to it when connecting a Rithmic account. We consider this a legitimate purpose under Article 6(1)(a) (consent) and Article 6(1)(f) (legitimate interests — platform integrity).

To satisfy the right to erasure to the maximum extent possible, upon account anonymisation all personal identifiers associated with trade records (user_id, account references) are set to NULL, effectively de-identifying them. We believe this is consistent with Recital 26 of the GDPR, which states that data protection principles do not apply to anonymous information.

Sub-Processor Retention

Our service providers maintain their own data retention policies in accordance with applicable data protection law. Key considerations:

  • Our payment processor retains transaction records in accordance with financial regulations (typically 7+ years).
  • Our database provider retains data for as long as our database exists — deletion from our schema cascades to the provider.
  • Session data is TTL-controlled at our application level (30 days maximum).
  • Uploaded files are retained until deleted by our application — deletion is triggered by our anonymisation process.
  • Real-time messages are not persistently stored by our messaging provider beyond what is needed for delivery.
  • Email delivery logs may be retained by our email provider in accordance with their own policies.

This retention schedule is reviewed whenever significant changes are made to the platform's data architecture or when applicable law changes.

Your Rights

Under UK GDPR and EU GDPR, you have the following rights:

  • Right of Access (Article 15): You can request a copy of the personal data we hold about you.
  • Right to Rectification (Article 16): You can correct inaccurate data via your profile settings, or by contacting us.
  • Right to Erasure (Article 17): You can request deletion of your account and personal data. This right is limited with respect to the Financial Identity Ledger — trade execution records are immutable by design and cannot be erased. Upon account anonymisation, your personal identifiers are removed and your trade records are de-identified. See the Account Deactivation section above.
  • Right to Restriction of Processing (Article 18): In certain circumstances, you can ask us to restrict how we process your data.
  • Right to Data Portability (Article 20): You can request an export of the personal data you provided to us in a structured, machine-readable format.
  • Right to Object (Article 21): You can object to processing based on legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds.
  • Right to Withdraw Consent: Where we rely on consent (e.g. Rithmic data capture), you may withdraw at any time by disconnecting your account. Withdrawal does not affect the lawfulness of processing before withdrawal.
  • Right to Lodge a Complaint: If you are in the UK, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. If in the EU, contact your local supervisory authority.

To exercise any of these rights, contact us at tna@tna.live. We will respond within 30 days.

International Data Transfers

Some of our service providers operate in the United States and other countries outside the UK/EEA. International transfers are made under Standard Contractual Clauses (SCCs) or equivalent frameworks providing adequate protection. By using TNA, you acknowledge these transfers.

Experimental Product Notice

TNA Traders Networking Allegiance Ltd is an experimental, early-stage platform. While we implement security best practices, this is a beta product and things may break. By using TNA, you acknowledge the experimental nature of the platform.

Changes to This Policy

We may update this privacy policy as the platform evolves. We will update the "Last updated" date at the top of this page. Continued use after changes constitutes acceptance of the updated policy. For material changes, we will notify you by email where possible.

Contact & Data Controller

Data controller: TNA Traders Networking Allegiance Ltd

Email: tna@tna.live

For data protection queries, access requests, or to exercise any of your rights, contact us at the address above. We aim to respond within 30 days.

© 2025 TNA Traders

Networking Allegiance Ltd

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