Privacy Policy

1. Who is responsible

The party processing your personal data in this app:

Sedat Kişial ("WuWTrade") Akıncılar Mah. 3971 Sok. No: 10, Yüreğir / Adana, Türkiye Tax office and number: Yüreğir / 5630627114 Privacy requests: gizlilik@wuwtrade.com Data protection contact: iletisim@wuwtrade.com

2. In short

WuWTrade is a technical analysis tool. We process the data needed to open your account, run your subscription, count your query allowance and keep the community safe. We show no ads, we sell no data, and we do not track you across apps.

The app contains no analytics or crash reporting software. Your advertising identifier (IDFA) is never touched.

3. What we process

Account

• Your email address and whether it is verified
• Your username (the name shown in the community)
• Provider identity data if you signed in with Apple or Google
• Your language and theme choice
• Your notification preferences (which notifications you want to receive)

Session and device

• A hash of your session token (never the token itself)
• Device name or model, app version, platform (iOS/Android)
• Installation identifier and notification token
• The prefix of your IP address — the full address is never stored

My list and portfolio

• The stocks you add to your list and whether each is marked as watching or portfolio
• For watching: the price on the day you added the stock (the system price or the price you entered)
• For portfolio: the date, price and number of shares of each buy and sell transaction, and the average cost and profit/loss calculated from them
• Your commission rate, if you entered one, and whether you chose to hide amounts
• The transaction history of fully sold positions (closed trades)
• Only if you use "Review my portfolio": the record of the permission you gave for this analysis and the portfolio analysis texts generated

Only you enter this information. No bank, brokerage or other account is connected, and your account balance or holdings are never read.

Survey

• Answers you give in the in-app survey and any free text you write in the "Other" field
• Which questions you skipped and the free queries you earned
• A per-topic comprehension score, used only to choose your next question and to improve the product; it is never shown to you and never used for pricing or investment decisions
• E-mail addresses, phone numbers, IBANs, identity numbers and usernames in free text are masked before storage; the raw text is not kept

Webinar updates

• Only if you explicitly opt in: the verified e-mail address on your account is added to the webinar announcement list. Turning the switch off in Settings → Notifications deletes the record.

Usage

• Your query counters and plan allowance
• The remaining balance of extra query and AI packs you bought
• Generated AI summary texts
• The questions you write in the "Ask about the summary" chat and the answers
• The record of the permission you gave for the "Ask about the summary" chat
• Thumbs-up/thumbs-down votes you give on AI answers, and reports you send about answers you find wrong
• Items you add to favourites in the broker recommendations section

Announcements

• WuwTrade announcements sent to you are kept in your in-app announcement inbox (the last five are shown). For each announcement we record when you first open its detail and, if there is one, when you first tap "Watch the video". This is used only to count how many people opened an announcement; administrators do not see who opened it. It is deleted when you delete your account.
• Announcement notifications are on by default; you can turn them off in Settings → Notifications. If your phone's notification permission is off, no notification is sent and the announcement only appears in your inbox.

Community and support

• The community messages you write in symbol chat rooms
• Reports, blocks, moderation decisions and sanctions
• Your support messages and feedback

Payment

• Subscription transaction identifiers and status from the store
• We never see or store your card details. Payment runs entirely through Apple (the App Store on iPhone/iPad) or Google (Google Play on Android).

HGVTrade membership (only if you link it)

• The HGVTrade e-mail address you enter when linking
• Your HGVTrade user identifier, membership status (active / expired / none), membership start and end date, plan code, the time you linked and the time of the last check
• The record of the explicit consent you gave for linking
• Your HGVTrade password is never stored and never written to logs; it is only passed to HGVTrade for verification (§8)

Legal

• Which document you accepted, at which version, and when
• That your age declaration was taken (we never ask your date of birth)

4. Why we process it

My list and portfolio data is never used for advertising, profiling or scoring. It is used to generate AI text only if you explicitly allow "Review my portfolio", and only the summary information listed in §7.

5. Who we share it with

We send our email from our own server; no third-party email service sits in between.

My list and portfolio data is not shared with third parties. Only if you start "Review my portfolio" with your explicit permission is the summary information listed in §7 sent to the AI provider. Prices are fetched from our data provider (HGVTrade) by symbol; these requests contain neither your identity nor your positions.

We do not sell your data and we share it with no one for advertising.

6. Transfers Abroad

Some of our service providers are outside Türkiye. For this reason, the following data is transferred abroad under Article 9 of the Turkish data protection law (KVKK):

The transfer for the "Ask about the summary" chat is based on your explicit consent (KVKK Art. 9/6-a). Before you use the chat for the first time, the app tells you that your question will be sent to AI providers abroad and asks for your permission; the permission you give is recorded. If you do not agree, the chat stays off and none of your questions are sent. Your right to withdraw consent is set out in §10.

The AI summary carries market measurements only; it contains nothing that identifies you.

Transfers to Apple and Google are necessary to conclude or perform the contract when you sign in, buy or receive notifications through these services, and are made under KVKK Art. 9/6-b.

7. About the AI analysis

When you request an AI summary, the request leaves our server carrying only the measurements for that symbol: symbol code, timeframe, data and market status, wave direction, trend durations, cage zone names and calculated labels.

When you write a question in the "Ask about the summary" chat (Max), your question is sent to the AI provider together with the summary and measurements on that screen so an answer can be generated. Before sending, we mask email addresses, phone numbers, IBANs, Turkish identity numbers, @usernames and links in your question. The app tells you this and asks for your permission before you use the chat for the first time; your permission is recorded. If you do not agree, the chat stays off.

"Review my portfolio" (Max). This analysis describes how your portfolio looks in terms of technical measurements and fund data; it gives no buy, sell or hold suggestion and is not investment advice. To produce it, only the following information from your portfolio is sent to the AI provider (OpenRouter or NVIDIA): stock codes, each stock's weight in the portfolio as a percentage, the percentage change against your average cost, how many days you have held the stock, and the technical and fund measurements of these stocks. Amounts, lot counts, purchase price and cost, your name, your email and your account details are never sent. Before you use the analysis for the first time, the app tells you this and asks for a separate permission; the permission you gave for "Ask about the summary" does not count for it. If you do not agree, nothing is sent. Permission is given and withdrawn with the Portfolio analysis permission switch on the "Review my portfolio" screen and on Account → AI and permissions; you can turn it off at any time. When you do, your portfolio summary is no longer sent and your saved portfolio analyses are deleted; if you turn it back on you can request a new analysis.

If you report a portfolio analysis with "Report this text", your reason and optional note are stored linked to that analysis; amounts or positions are not added to the report. The report is deleted when the analysis is deleted. A card made with "Create share card" is created on your device and is shared or saved only by you. The card shows no weights, profit/loss percentages or amounts.

Your account identifier, email, device and IP address are never sent to the AI provider.

8. Linking an HGVTrade membership

HGVTrade (hgvtrade.com) is the provider we get the app's market data from. If you have an existing HGVTrade account, you can link it to your WuWTrade account under Account → HGVTrade üyeliği (HGVTrade membership). Linking is optional; if you do not link, no data about you is sent to HGVTrade.

• To link, you enter your HGVTrade e-mail address and password and tick the explicit consent box.
• Our server passes your e-mail address and password to HGVTrade only to verify them. We do not store your password and do not write it to our logs.
• If verification succeeds, we read your membership summary from HGVTrade: HGVTrade user identifier, membership status (active / expired / none), membership start and end date, plan code.
• What we store: the HGVTrade e-mail address you entered, the HGVTrade user identifier, membership status, membership start and end date, plan code, the time you linked and the time of the last check.
• When you use the app, we re-check your membership status about once a day; for this we send HGVTrade the e-mail address you linked. Your password is not used for this check.
• One HGVTrade account can be linked to only one WuWTrade account at a time.

This processing is based on your explicit consent. To withdraw it, you can remove the link at any time under Account → HGVTrade üyeliği → Bağlantıyı kaldır (Remove link); the link data is deleted and the membership checks stop. The effect of the link on your plan is set out in the Subscription Terms.

9. How long we keep it

When you delete your account, your data is deleted. A 7-day recovery window runs after the request; you can cancel during that window.

After deletion, only the following remain, only for these periods:

Your support requests and correspondence are deleted as soon as your account is deleted. Your community messages remain visible under the name "deleted user"; the link between the messages and your account is removed.

You can remove your survey answers without deleting your account: Account → Delete my survey answers. This deletes your answers, free text, comprehension scores, credits earned from the survey, your survey consent and your webinar record. Only aggregate counts that cannot be linked to you (how many times an option was chosen) remain. Deleting your account performs the same cleanup automatically.

You can also remove the HGVTrade link without deleting your account: Account → HGVTrade üyeliği → Bağlantıyı kaldır (Remove link). This deletes all of the link data that §8 says we store. Deleting your account deletes the link data as well. The record of the consent you gave for linking is kept for 10 years, like other consent records.

You can also remove your list and portfolio data without deleting your account: My list → Portfolio settings → Delete my portfolio data (also reachable from the Account tab). This immediately deletes your positions, purchase prices, transaction history, closed trades, commission setting and saved portfolio analyses; your watching rows stay. Deleting your account deletes your whole list and portfolio; there is no separate retention period for this data.

Records are deleted automatically once their period expires.

10. Your rights

Under Turkish data protection law (KVKK Article 11) and, where it applies to you, the GDPR:

• Learn whether your data is processed and obtain a copy
• Have inaccurate or incomplete data corrected
• Request erasure
• Object to processing or ask that it be restricted
• Withdraw consent where processing is based on consent
• Receive your data in a structured format (portability)

Write to gizlilik@wuwtrade.com; we answer within 30 days.

You can delete your account from inside the app or, without installing it, at https://wuwtrade.com/hesap-silme

If you are not satisfied with the outcome, you may complain to the Turkish Personal Data Protection Authority, or to your local supervisory authority where the GDPR applies to you.

11. Age limit

WuWTrade is for people aged 18 and over. We close accounts we learn belong to someone under 18 and delete their data.

12. Website

wuwtrade.com uses no cookies, runs no analytics software and embeds no third-party content.

13. Security

Passwords are stored irreversibly, all traffic is encrypted in transit, session tokens are never stored directly, IP addresses are kept only as a prefix, and the admin panel requires two-step verification.

14. If this text changes

For a significant change we notify you in the app and ask you to accept the new version once. The version number and effective date are at the top of this page.