WuwTrade
TREN

Privacy Policy

Version 1.2.4 · Effective 2026-10-03

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

Session and device

My list and portfolio

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

Survey

Webinar updates

Usage

Announcements

Community and support

Payment

HGVTrade membership (only if you link it)

Legal

4. Why we process it

PurposeLegal basis
Opening and running your accountPerformance of a contract
Showing you your list, positions and profit/loss; sending the notifications you choose (a brokerage recommendation for a stock on your list, a change in a fund report, Cage and trend direction)Performance of a contract
Managing subscription and query allowancePerformance of a contract
Keeping the balance of purchased extra query/AI packsPerformance of a contract
Using survey answers to improve the productExplicit consent
Sending webinar announcementsExplicit consent
Sending your "Ask about the summary" question to an AI provider abroadExplicit consent
Linking your HGVTrade membership: passing your e-mail and password to HGVTrade for verification, reading your membership status and granting Max accordinglyExplicit consent
Keeping the community safe, preventing abuseLegitimate interest
Meeting legal obligationsLegal obligation
Sending notificationsConsent (you can turn it off at any time)
Showing announcements sent to you in your inbox and counting, without names, how many people opened themLegitimate interest
Sending the portfolio summary described in §7 to an AI provider abroad for "Review my portfolio" (Max)Explicit consent

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

PartyWhat is sharedWhere
Keyubu İnternet ve Bilişim Tic. Ltd. Şti.Hosting — the database runs on this serverTürkiye
OpenRouter and the model providers it routes the request to (e.g. DeepSeek)AI summary: market measurements. "Ask about the summary" chat: the question you write (contact details masked), the summary and measurements on screen. "Review my portfolio" (Max, with explicit permission): stock codes, weight percentages, percentage change against your average cost, days held, and the technical and fund measurements of these stocks. Your identity, email, username, device and IP are never sentUSA and the model provider's country (§6)
NVIDIA (backup provider)Same content as OpenRouter, only when that provider is selectedUSA
AppleOn iPhone/iPad: Sign in with Apple, account deletion verification, App Store subscriptions and purchases; notifications are delivered through the Apple Push Notification service (APNs) (notification token and notification text)USA/EU
GoogleOn Android: subscriptions and purchases through Google Play Billing; notifications are delivered through Firebase Cloud Messaging (FCM) (notification token and notification text); Google Sign-In where offeredUSA and other countries
HGVTrade (hgvtrade.com)We pull market data. If you link your HGVTrade membership: your HGVTrade e-mail address and password are sent for verification, and your membership summary (HGVTrade user identifier, membership status, start and end date, plan code) is read; when the membership status is re-checked, your HGVTrade e-mail address is sent (§8). For users who do not link, no data is sent—
AuthoritiesOnly where legally required, only as far as the request requires—

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):

RecipientWhat is sentCountry
AppleOn iPhone/iPad, the data needed for sign-in, purchases and notifications (§5)USA and EU
GoogleOn Android, the data needed for purchases, notifications and Google Sign-In (§5)USA and other countries where Google operates
OpenRouterMarket measurements for the AI summary; in the "Ask about the summary" chat, your question (contact details masked), the summary and measurements on screenUSA
Model providers OpenRouter routes the request to (currently DeepSeek)The same content that goes to OpenRouterPeople's Republic of China or the other countries where the model provider operates
NVIDIA (backup provider)The same content that goes to OpenRouter, only when this provider is selectedUSA

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.

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:

WhatPeriodWhy
Subscription transaction records10 yearsTax and commercial law
Consent records10 yearsObligation to prove consent was given
Moderation and sanction records2 yearsShowing grounds and handling appeals
Administrator action records2 yearsAccountability
Purchase (pack) transaction records10 yearsTax and commercial law

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:

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.