January 27, 2025

Thank you for choosing Arc Trader (“Arc Trader,” “we,” “us,” or “our”). We deeply value your privacy and are committed to handling your personal data responsibly, securely, and transparently. This Privacy Policy (“Policy”) describes how we collect, use, and protect your personal information when you use our Bitcoin trading application (“App” or “Software”). It also explains the rights and choices you have with respect to your personal data.

Introduction
Arc Trader is a local, standalone Python-based application designed to help users trade Bitcoin by integrating with third-party platforms such as Robinhood (“Third-Party Services”). The App only collects minimal personal information necessary for subscription and payment. Your Robinhood API keys and private keys (“Security Keys”) remain stored solely on your device; Arc Trader neither transmits these keys to our servers (because we do not operate any), nor do we share them with any external party.

By using Arc Trader, you agree to the terms outlined in this Policy and any other documentation referenced herein. If you do not agree with this Policy, please discontinue use of the App.

Data We Collect
2.1 Personal Data You Provide
Subscription & Payment Data: When you create an account or subscribe to our services, we may collect:

Name (or username/alias if you choose)
Contact information (e.g., email address)
Payment details (e.g., billing address or relevant payment method information)
Communications: If you contact us with questions or support requests (e.g., via email), we collect and process the information you provide (e.g., your name, email, and the content of your message).

2.2 Data Related to Security Keys
Robinhood API Keys and Private Keys: The App enables you to input Security Keys to facilitate trading. We do not store or transmit Security Keys on any remote server. They remain on your local device unless you choose to back them up or share them elsewhere on your own accord.
2.3 Automatically Collected Data
Technical & Usage Data: Depending on your device settings, we may gather basic technical information such as operating system type and version, device model, and usage logs for diagnosing errors and improving the App’s functionality.
Cookies and Local Storage: Since Arc Trader is primarily a standalone application, we do not typically use browser cookies. If a web-based element is ever introduced for subscription or payment processing, a cookie or local storage mechanism might be employed solely to manage the session or remember your preferences.
We do not collect any more data than is strictly needed to provide, maintain, and enhance Arc Trader.

How We Use Your Data
We process your personal data for the following purposes and on these legal bases:

Provision of the App and Services

Purpose: To enable access to Arc Trader’s features, validate your subscription, process payments, and ensure the functionality of the Software.
Legal Basis:
Performance of a contract (i.e., our Terms of Use / End User License Agreement).
Our legitimate interest in providing and improving the App.
Customer Support and Communications

Purpose: To respond to your inquiries, provide support, and communicate updates about the App.
Legal Basis:
Performance of contract (for existing subscribers).
Legitimate interest (responding to potential users and inquiries).
Subscription Management and Billing

Purpose: To process payments, manage invoices, and enable refunds if applicable.
Legal Basis:
Performance of contract (managing the subscription services).
Legal Obligations and Compliance

Purpose: To comply with applicable laws, regulations, and legal processes (e.g., tax and accounting rules).
Legal Basis:
Compliance with legal obligations.
App Improvement & Analytics

Purpose: To improve App functionality, troubleshoot technical issues, and analyze usage trends in an aggregated or pseudonymized manner.
Legal Basis:
Legitimate interest in ensuring security, stability, and continuous improvement of the App.
Arc Trader does not utilize or sell personal data to third parties for marketing or advertising purposes.

Data Sharing and Transfers
No Third-Party Sales: We do not sell, lease, or trade your personal data to any third parties.
Service Providers: We may disclose certain personal data (e.g., billing details) to trusted vendors or service providers who help facilitate payment processing, subscription management, or customer support. These providers are authorized to process your data only to the extent necessary to provide their services on our behalf and are bound by contractual obligations to keep it confidential and secure.
Legal Requirements: We may disclose your data if required by law, court order, or for the purposes of legal compliance (e.g., detecting or preventing unlawful activities).
International Transfers: As Arc Trader’s infrastructure is minimal and primarily local to your device, we do not routinely transfer personal data across borders. If, however, in the future, any data must be transferred (e.g., for payment processing or subscription services), we will ensure that such transfers are carried out with appropriate safeguards in compliance with data protection regulations.
Retention of Your Data
We retain personal data only for as long as necessary to fulfill the purposes stated in this Policy or as required by law. Generally:

Subscription & Payment Information: Retained for the duration of your subscription plus any legally required period (e.g., for tax or accounting regulations).
Communications: Retained until your inquiries or issues have been resolved, plus a reasonable additional period if needed to address potential legal claims.
Automatically Collected Data: Basic logs or usage information may be retained temporarily to troubleshoot errors or enhance performance, after which they are anonymized or deleted.
Once these retention periods expire or the data is no longer needed, we securely delete or anonymize your personal data.

Security Measures
We take appropriate technical and organizational measures to safeguard your personal data. These measures include, but are not limited to:

Local-Only Storage for Security Keys: Your Robinhood API keys and private keys remain solely on your device. Arc Trader does not transmit them to remote servers.
Access Controls: Limited personnel can access any subscription data, and only for support or operational needs.
Encryption & Secure Protocols: If the App integrates any network connections (e.g., for subscription validation), we employ secure communication protocols (e.g., HTTPS/TLS).
No security measure is foolproof. You are responsible for taking steps to ensure the security of your device and for keeping your Security Keys, passwords, and other credentials confidential.

Your Rights
Depending on applicable data protection laws, you may have certain rights regarding the personal data we hold about you. These may include:

Right to Access: You can request information about, and a copy of, your personal data.
Right to Rectify: You can request corrections to any inaccurate or incomplete personal data.
Right to Erasure: You can request deletion of personal data under certain circumstances (e.g., if it is no longer necessary for the purposes for which it was collected).
Right to Restrict or Object: You may request that we limit how we use your data or object to certain processing activities.
Right to Data Portability: In certain cases, you can request to receive your data in a structured, commonly used, and machine-readable format and have it transferred to another controller.
Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time (e.g., opting out of certain communications).
To exercise any of these rights, or if you have a privacy-related complaint, please contact us at the email provided in Section 11. We will respond within a reasonable time and in accordance with legal requirements.

Children’s Privacy
Arc Trader is not directed to individuals under 18. We do not knowingly collect or store personal data from children. If you become aware that someone under 18 has provided us with personal data, please contact us so we can take steps to remove such information.
Third-Party Links and Services
Arc Trader may include links or integrations to Third-Party Services for payments or related functionalities. This Privacy Policy does not apply to the data processing practices of those external services. We encourage you to read the privacy policies of any linked websites, services, or applications before providing them with your personal data.
Policy Updates
We may modify this Privacy Policy from time to time to reflect updates in our practices or for other operational, legal, or regulatory reasons. If we make significant changes, we will notify you via email (if you have provided it) or by prominently posting a notice within the App. By continuing to use Arc Trader after any modifications become effective, you agree to be bound by the updated Policy.
Contact Us
If you have any questions or concerns regarding this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact us at:

Email: [Your Support/Privacy Email Address]
We appreciate your trust in Arc Trader and are committed to safeguarding your information. Your privacy and the security of your trading are our top priorities.

Thank you for using Arc Trader.