Privacy Policy
Last updated: 21 July 2026
Trade By Focus ("we", "our", "us") is operated by James Mitchell, trading as Trade By Focus, a sole trader in the United Kingdom, of United Kingdom. We are the data controller for the personal data described in this policy, and we are committed to protecting it in accordance with the UK GDPR and the Data Protection Act 2018.
Trade By Focus is for adults: you must be at least 18 to use it, and we do not knowingly collect data about anyone under 18.
1. Data We Collect
Account information: name, email address, phone number (if provided)
Trade By Focus data: MT5 account balance, equity, open positions, trade history, and live tick data received from your MT5 platform via the Trade By Focus EA. This data is used solely to power your Focus Dashboard and is not shared with third parties.
Hosted MetaTrader 5 session data: for customers using the hosted path, we collect and store only your broker server name (e.g. “VTMarkets-Live”, used for support diagnostics and broker identification); your account session details (account type — demo or live — and connected trading pairs); and your trading activity (open positions, trade history, account balance and equity) received from the hosted MT5 instance to power the Trade By Focus interface. Your MT5 broker login (account number) and password are never stored. Both are pass-through only: transmitted over an encrypted connection, passed directly to our hosted infrastructure, used to start the MetaTrader 5 session, and then released — the password is held in memory and written to a restricted-permission file for under three seconds during MetaTrader 5 startup then permanently deleted, and the account number is forwarded once and never written to our database or application logs. We retain only a one-way salted hash of the account number so we can detect when you switch MT5 accounts; that hash cannot be reversed to your account number.
Multiple accounts and copy trading: where your plan lets you connect more than one MT5 account, we store the same information for each connected account (broker server name, session details, trading activity, and a one-way salted hash of the account number), plus any nickname you choose as a label for an account. The credential rule is identical for every account — your MT5 login and password are never stored. If you use account-to-account copy trading, we also keep a record of the trades copied between your own accounts, used solely to show you the copy activity and operate the feature.
Economic calendar data: economic calendar events sourced from MQL5's calendar API and stored in our database to display the calendar within Trade By Focus.
Journal and analysis data: trading journal entries, reviews, and check-ins you create within Trade By Focus, used to power your journal, focus insights, and AI analysis
Payment information: processed securely by Stripe — we do not store card details
Usage data: pages visited, features used, chat interactions with Fraser, our AI support. Analytics and advertising data is only collected with your consent — see our Cookie Policy.
2. How We Use Your Data — and Our Lawful Basis
| Purpose | Lawful basis (UK GDPR) |
|---|---|
| Providing the Trade By Focus service and its features, including your Focus Dashboard, hosted sessions, tasks, and copy trading | Performance of a contract — you have subscribed and provided your details to enable the service |
| Managing your account, subscription, and billing | Performance of a contract |
| AI-powered support, journal insights, and analysis | Performance of a contract |
| Transactional emails (receipts, service notices, changes to terms) | Performance of a contract / legal obligation |
| Marketing emails | Consent — you can withdraw it at any time via the unsubscribe link |
| Analytics and advertising measurement (cookies and similar) | Consent, given through the cookie banner and withdrawable at any time |
| Improving the platform using aggregated usage information | Legitimate interests — understanding how the product is used, in ways you would reasonably expect |
| Fraud prevention and abuse records | Legitimate interests — protecting the business and other customers |
We do not make any decisions with legal or similarly significant effects about you by purely automated means. We never sell your personal data.
3. Third-Party Services
- Supabase — database and authentication (hosted in the London region, AWS eu-west-2)
- Vercel — hosting of the web application (US company; may process data in the US)
- Hetzner — hosted MetaTrader 5 server infrastructure (Falkenstein, Germany)
- DigitalOcean — Trade By Focus relay infrastructure (London, United Kingdom)
- Stripe — payment processing (US company)
- Resend — transactional and marketing email delivery (US company)
- Anthropic (Claude AI) — AI chat and analysis features (US company)
- Google Analytics (GA4) — usage analytics, with your consent (US company)
- Hotjar / Contentsquare — session recordings and heatmaps, with your consent
- TikTok — advertising attribution, with your consent (may process data in the US and elsewhere)
4. International Transfers
Your data is stored primarily in the United Kingdom and Germany. Some of the providers above are based in, or process data in, the United States or other countries outside the UK. Where that happens, we rely on safeguards recognised under UK law: the UK–US “Data Bridge” (the UK Extension to the EU–US Data Privacy Framework) for US providers certified under it, and otherwise the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses built into each provider’s data processing terms. You can contact us for more information about the safeguard applying to a particular provider.
5. Data Retention
Your account data is retained while your account is active. Specific retention periods apply to Trade By Focus and hosted MetaTrader 5 data:
- Broker password — never retained. Pass-through only; permanently deleted from the hosted server within three seconds of MetaTrader 5 startup
- Broker account number (MT5 login) — never retained. Pass-through only; used once to start the MetaTrader 5 session, never written to our database or application logs. A one-way salted hash is kept solely to detect account switches; that hash cannot be reversed to the account number
- Broker server name — retained for the duration of your subscription (broker identification only, not a credential)
- Account nicknames and copy-trading records — where you connect more than one account, any nickname you set and any record of trades copied between your own accounts are retained for the duration of your subscription
- Open positions and trade events — retained for the duration of your subscription plus 90 days
- Live tick data — automatically deleted after 1 hour
- Economic calendar events — automatically deleted after 90 days
On account deletion we remove your chat history, journal entries, and stored session and trading data. A minimal record (such as your email and a note of the deletion) is retained for fraud prevention, and billing records are kept for as long as tax law requires.
6. Your Rights
Under UK GDPR you have the right to access, correct, delete, or port your personal data, to object to or restrict certain processing, and to withdraw consent at any time where consent is the basis (marketing and cookies). This includes the right to request erasure of all stored Trade By Focus and hosted MetaTrader 5 session data. Contact james@tradebyfocus.com to exercise any of these rights — we will respond within one month.
You also have the right to complain to the UK’s data protection regulator, the Information Commissioner’s Office (ICO), at ico.org.uk or 0303 123 1113. We would appreciate the chance to resolve your concern first, but you can go to the ICO at any time.
7. Cookies
Non-essential cookies run only with your consent, which you can withdraw at any time via the “Cookie settings” link in the footer. See our Cookie Policy for details.
8. Security
We implement appropriate technical and organisational measures including HTTPS encryption in transit, row-level database security, restricted access to production systems, and secure authentication. No system is perfectly secure, but the design principle behind Trade By Focus is data minimisation — most notably, never storing your broker credentials at all.
9. Changes to This Policy
If we make a significant change to this policy — such as collecting a new category of data or sharing data with a new kind of recipient — we will tell you by email or an in-app notice before the change takes effect. The “Last updated” date at the top always shows the current version.
10. Contact
James Mitchell, trading as Trade By Focus
United Kingdom
james@tradebyfocus.com