Drewbz Trading Privacy Policy

Drewbz Trading is the brand used for this website and its services.

Legal business name: [INSERT LEGAL BUSINESS NAME]

Company number, where applicable: [INSERT COMPANY NUMBER]

Registered or principal business address: [INSERT ADDRESS]

Privacy contact: drewbztrading@protonmail.com

The final legal entity responsible for deciding how and why personal data is used will be the data controller identified here before commercial launch.

This Privacy Policy applies to personal data handled in connection with:

• the Drewbz Trading website;
• mentorship enquiries and applications;
• mentorship payments and onboarding;
• mentorship materials and support;
• Telegram cohort communication;
• eligible graduate Discord access;
• Gold Engine enquiries, waiting lists and applications;
• future Gold Engine onboarding and account connection;
• future Gold Engine trading, monitoring, safety and reconciliation records;
• performance-fee calculations and invoices;
• email and other support communication; and
• related business, security and compliance activity.

Service-specific Terms, Risk Disclosures and notices may provide additional information.

The information collected depends on how you interact with Drewbz Trading.

Website and contact data

We may collect:

• name;
• email address;
• message content and attachments;
• contact history;
• IP address;
• browser and device information;
• access times;
• server and security logs; and
• information provided when following or contacting Drewbz Trading through a third-party platform.

Mentorship data

We may collect:

• Tally application answers;
• Telegram username;
• Discord username, where applicable;
• trading experience, goals and suitability information;
• cohort, onboarding and access status;
• support requests and communication history;
• participation or conduct information relevant to a community;
• payment status and transaction records; and
• refund or complaint information.

Gold Engine application and onboarding data

Before and during any future Gold Engine relationship, we may collect:

• age and jurisdiction information;
• application and eligibility answers;
• broker or prop-firm name;
• account type, stage and currency;
• account ownership or authority evidence;
• account identifier or masked account number;
• account balance and agreed risk-reference information;
• supported profile selection;
• onboarding checks and acknowledgements;
• account-connection status; and
• records needed for legal, regulatory, security or suitability checks where applicable.

Gold Engine account and trading data

If a client connects an approved account in the future, the service may process:

• broker or prop-firm account identifiers;
• connection tokens, terminal credentials or other access information required for the approved integration;
• account balance, equity, margin and currency information;
• deposits, withdrawals and account adjustments;
• open positions and pending orders;
• order, trade and deal history;
• realised and unrealised profit or loss;
• commissions, swaps and trading charges;
• risk-reference and high-water-mark records;
• prop-firm rule, stage and payout information;
• safety blockers and risk-limit usage;
• signal, order, execution and reconciliation records;
• system health, incident and audit logs;
• pause, suspension, disconnection and kill-switch events; and
• client-portal or status-dashboard activity.

Payment and fee data

We may collect or receive:

• payer name and email;
• billing address where required;
• invoice amount and status;
• payment date;
• transaction identifiers;
• payment-provider confirmation;
• mentorship payment and refund information;
• regular-broker performance-fee calculations;
• prop-firm payout evidence;
• overdue-payment and access-suspension records; and
• accounting and tax records.

Drewbz Trading does not intend to store full payment-card details. Those details are handled by the relevant payment provider.

Do not send full broker passwords, recovery codes, identity documents, bank statements or other sensitive information through ordinary email, Telegram or Discord unless Drewbz Trading has specifically instructed you to use that channel and confirmed it is appropriate.

The final Gold Engine onboarding process will identify the approved secure method for account connection and any identity or compliance information.

Where an integration allows, account permissions should be limited to the minimum needed for approved trading, monitoring and reconciliation. Drewbz Trading does not need withdrawal authority over client funds.

We may collect personal data:

• directly from you;
• through Tally or another application provider;
• through Stripe or another payment provider;
• through Telegram, Discord, email or other communication tools;
• from a broker, prop firm, trading terminal or approved account connection;
• from a payment processor used by a prop firm;
• from technical logs generated by the website, client portal or service;
• from professional advisers or compliance providers where lawful; and
• from public or official sources where verification is required and lawful.

Where we obtain personal data from another source, we will provide the information required by law within the applicable period, unless an exception applies.

We may use personal data to:

Operate the website and respond to enquiries

• provide and secure the website;
• respond to messages;
• maintain public availability information;
• diagnose errors and security incidents; and
• manage website and service communications.

Operate the mentorship

• receive and review applications;
• assess suitability and cohort availability;
• arrange payment and onboarding;
• provide materials and support;
• manage Telegram and eligible graduate Discord access;
• enforce programme and community rules;
• respond to refund requests and complaints; and
• maintain contract, tax and business records.

Develop and operate Gold Engine

• manage waiting lists and applications;
• assess whether a jurisdiction, broker, prop firm and account type are supported;
• verify account ownership, stage and profile;
• establish a secure account connection;
• operate the approved automation, execution, risk and safety controls;
• monitor orders, positions and account state;
• reconcile uncertain or completed activity;
• calculate high-water marks and performance fees;
• verify prop-firm payouts;
• suspend or disconnect unsafe or unpaid accounts;
• investigate incidents and complaints;
• protect account and service security; and
• maintain audit, legal, regulatory and operational records.

Improve and protect services

• test and improve reliability;
• detect misuse, account interference or unauthorised access;
• prevent fraud;
• enforce legal documents;
• establish, exercise or defend legal claims; and
• comply with legal or regulatory obligations.

We will identify and document a lawful basis before using personal data.

Depending on the purpose, we may rely on:

Contract and steps before a contract

We may process information needed to:

• review an application;
• answer pre-contract questions;
• onboard a student or Gold Engine client;
• provide paid access;
• connect and operate an approved account;
• calculate fees;
• issue invoices; and
• manage cancellation or support.

Legitimate interests

We may rely on legitimate interests where necessary and balanced against your rights, including:

• operating and improving the website and services;
• protecting materials, accounts, systems and communities;
• preventing fraud and misuse;
• maintaining proportionate audit and incident records;
• responding to enquiries;
• managing business administration; and
• establishing, exercising or defending legal claims.

Where we rely on legitimate interests, we will consider the purpose, necessity and effect on your rights and reasonable expectations.

Legal obligation

We may process data to comply with tax, accounting, consumer, data-protection, financial-services, fraud-prevention, court, regulatory or other legal obligations.

Consent

We may rely on consent where it is required, including for optional direct marketing or a specific optional use of information.

You may withdraw consent at any time where consent is the lawful basis. Withdrawal does not make earlier lawful processing unlawful.

Some information is optional. Other information may be needed to:

• assess an application;
• form or perform a contract;
• verify an account;
• connect or operate Gold Engine safely;
• calculate a fee;
• meet a legal obligation; or
• resolve a security or account incident.

If required information is not provided, Drewbz Trading may be unable to accept an application, provide access, connect an account, continue trading, calculate an invoice or resolve a request.

Gold Engine is intended to apply automated trading, execution, risk and safety rules to a connected account. This can determine whether an order is placed, blocked, managed or reconciled, and whether new trading is paused because of a safety or payment condition.

These operational decisions may have a financial effect on the connected account.

Before commercial launch, Drewbz Trading will assess whether any processing falls within legal rules for solely automated decisions producing legal or similarly significant effects and will provide any required explanation, safeguards, human review or right to challenge.

Access, complaint, fee-dispute and client-eligibility decisions should not be made solely by automation without an available human review where the law requires one.

Drewbz Trading does not intentionally request special-category personal data through ordinary applications or service use.

Do not provide medical, biometric, religious, political, sexual-orientation or similar sensitive information unless it is genuinely necessary and Drewbz Trading has explained why and how it will be handled.

Identity and financial-account information can be sensitive even where it is not legally classed as special-category data. Access will be restricted and protected according to the risk involved.

Mentorship or Gold Engine applications may be submitted through Tally or another approved form provider.

The form provider may process application data under its own privacy policy and terms.

Drewbz Trading uses application data to assess suitability, availability, supported account conditions and whether to offer access.

Payments may be processed by Stripe or another approved payment provider.

The payment provider may process name, email, billing address, payment method, card information, amount, payment status, transaction identifiers and fraud-prevention data under its own privacy terms.

Drewbz Trading may receive the information needed to confirm payment, provide access, issue invoices, process refunds, maintain accounts and comply with legal obligations.

Drewbz Trading does not intend to store full payment-card details.

Drewbz Trading may use Telegram for mentorship cohort communication, support and onboarding.

Eligible graduates may be invited to a Discord community.

If you use Telegram or Discord, those platforms may process profile, username, message, interaction, device and technical information under their own policies.

Drewbz Trading may process your username, messages, access status, support history and relevant community activity to provide access, support and enforce rules.

Gold Engine support should use the approved secure support and incident channels identified during onboarding.

A broker, prop firm, trading terminal or connection provider may act as an independent controller for information it handles under its own terms.

Drewbz Trading may receive account and trading data from those parties where the client has authorised the connection and the processing is lawful.

Drewbz Trading does not control a broker's or prop firm's independent use of personal data. Clients should read the relevant third-party privacy notices.

We may share personal data where necessary with categories of provider such as:

• website hosting and deployment providers;
• form and application providers;
• payment and invoicing providers;
• email, Telegram, Discord and support providers;
• secure cloud infrastructure and credential-management providers;
• broker, prop-firm, terminal and account-connection providers;
• monitoring, logging, incident and cybersecurity providers;
• professional legal, regulatory, tax and accounting advisers;
• identity, compliance or fraud-prevention providers, where required; and
• courts, regulators, law enforcement or public authorities where legally required.

Providers acting on our behalf should receive only the data reasonably required for their role and should be subject to appropriate contractual and security controls.

We do not sell personal data.

Some service providers may process personal data outside the United Kingdom.

Where a restricted transfer occurs, Drewbz Trading will use a lawful transfer mechanism, such as:

• UK adequacy regulations;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved standard contractual clauses; or
• another mechanism permitted by UK data-protection law.

You may contact Drewbz Trading for information about the safeguards used for an applicable transfer.

Drewbz Trading will use technical and organisational measures appropriate to the sensitivity and risk of the information.

Measures may include:

• access controls and least-privilege permissions;
• encryption in transit and, where appropriate, at rest;
• secure credential or secret storage;
• separation between client accounts;
• account and operator authentication;
• logging and incident monitoring;
• backup and recovery controls;
• secure development and update procedures;
• provider due diligence; and
• prompt revocation or rotation of access after disconnection or suspected compromise.

No method of storage or transmission is completely secure. Clients must also protect their devices, passwords, email and broker or prop-firm accounts.

Gold Engine connection credentials, tokens or terminal access information should be used only for the approved account connection and service purposes.

Access should be restricted to authorised systems and personnel.

When an account is disconnected, access should be disabled, revoked or deleted as soon as reasonably practical, subject to short-lived security backups, incident investigation and legal record requirements.

Trading credentials should not be retained merely for convenience after the relationship ends.

We keep personal data only for as long as reasonably needed for the purpose, legal obligations and claims.

The intended retention framework is:

• unsuccessful or withdrawn mentorship applications: normally up to 12 months;
• unsuccessful or withdrawn Gold Engine applications: normally up to 12 months, unless a longer compliance record is required;
• active mentorship and community records: for the relationship and a reasonable period afterwards;
• contract, invoice, payment, tax and accounting records: normally 6 years after the relevant financial year or relationship, subject to legal requirements;
• Gold Engine trading, risk, fee, reconciliation, audit and incident records: normally up to 6 years after the relationship ends, subject to final regulatory and legal requirements;
• ordinary support communications: for as long as needed to resolve the issue and maintain appropriate business records;
• account credentials and live connection tokens: only while needed for the approved connection, then revoked or deleted promptly;
• security backups: for a limited rotation period before secure deletion or overwrite;
• website and infrastructure logs: for the provider's configured security and operational period; and
• optional marketing information: until consent is withdrawn or the information is no longer needed, with a limited suppression record where necessary to respect an opt-out.

The final Gold Engine retention schedule must be confirmed before commercial launch and may differ where financial-services, tax, anti-fraud, complaint or litigation rules require a longer period.

Depending on the circumstances and lawful basis, you may have the right to:

• be informed about how your personal data is used;
• request access to your personal data;
• ask for inaccurate data to be corrected;
• ask for deletion;
• ask for processing to be restricted;
• object to processing;
• receive certain data in a portable format;
• withdraw consent where consent is used; and
• request safeguards or human review for certain automated decisions.

These rights are not absolute and may be limited by law, another person's rights, legal claims or regulatory record requirements.

To exercise a right, contact drewbztrading@protonmail.com. Drewbz Trading may need to verify your identity before responding.

You have the right to object to processing based on legitimate interests in certain circumstances.

You also have the right to object to direct marketing at any time.

Contact drewbztrading@protonmail.com to object or opt out.

Please contact Drewbz Trading first so the issue can be investigated:

drewbztrading@protonmail.com

You also have the right to complain to the Information Commissioner's Office if you are unhappy with how your personal data has been handled.

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113

The ICO's current contact methods are available through its official website.

The public Drewbz Trading website does not currently run Google Analytics, Meta Pixel or advertising pixels and does not currently set its own non-essential cookies, localStorage or sessionStorage for users.

Hosting providers and linked third-party services may process technical logs or set their own cookies under their policies.

A future Gold Engine client portal may require strictly necessary authentication, security or session storage. Before those tools are introduced, this Privacy Policy and any required cookie information or consent controls must be updated.

Optional analytics, advertising or similar tracking must not be added without the required privacy and consent review.

The mentorship page may display public information such as founding-price spots, cohort capacity, next cohort timing or application status.

Those public counter values do not contain personal data. They are used only to display public availability information.

The Drewbz Trading Mentorship and Gold Engine are intended only for people aged 18 or over.

Drewbz Trading does not knowingly offer paid access to children.

The website may link to third-party websites, brokers, prop firms, forms, payment providers, social platforms or other services.

Drewbz Trading is not responsible for the privacy practices of independent third parties. Review their privacy notices before providing personal data.

This Privacy Policy may be updated to reflect legal, regulatory, technical or service changes.

The revised version will be published with a new Last updated date. Material changes affecting active users will be communicated where required.

The Gold Engine sections must be reviewed again before commercial launch against the final infrastructure, provider list, account permissions, retention schedule and regulatory model.

Privacy questions and requests should be sent to:

drewbztrading@protonmail.com

Legal business name: [INSERT LEGAL BUSINESS NAME]

Business address: [INSERT ADDRESS]