This policy explains how personal data is handled on thesourcefinance.com, in our forms, in our newsletter and in our signal rooms on Telegram.
It is written to meet the EU and UK General Data Protection Regulation (GDPR). References to GDPR articles also cover the equivalent rules of any other data protection law that applies.
When you become a client, the terms of your service tell you about any further data that service needs.
1. Controller
The controller of your personal data is The Source Finance, the brand under which this website is operated.
Contact for any data matter: thesourceoffinance@gmail.com.
2. Data we collect
We collect as little personal data as possible.
2.1Data you give us
The Get started form asks for:
- whether you join as a partner or as a trader
- for partners: your company and its type
- for traders: your trading platform
- the service lines you are interested in
- your email address
- your question, if you write one
- your agreement that we may email you about your request
The newsletter form asks only for your email address.
Please do not write account numbers, passwords or sensitive personal data in the question field.
Giving us data is your choice. Without an email address, we cannot reply.
2.2Data collected automatically
When you visit the site, our hosting provider, Netlify, processes the technical data needed to deliver pages and keep them secure: IP address, browser and device type, the page requested and the time of the request.
When you send a form, Netlify checks it for spam. For this, it may pass the submission and its technical data to a spam-filtering sub-processor.
We use no analytics, advertising or tracking tools.
2.3Telegram and social networks
Our signal rooms run on Telegram. When you join a room, we can see your Telegram name, your username and any profile details your Telegram settings make visible. We use them only to run the room and manage access.
Telegram processes your data as an independent controller, under its own privacy policy.
The links to our social network pages are plain links. Nothing loads from those networks until you click. Once you are on a network, its own privacy policy applies.
2.4Data we do not collect
This site does not ask for trading account passwords, payment card details or identity documents.
We do not make decisions about you by automated means, and we do not profile you.
3. Purposes and legal bases
We use your data only for these purposes:
- Replying to your Get started request and preparing a possible agreement. Legal basis: steps you ask for before a contract (Art. 6(1)(b) GDPR). If you write for a company: our legitimate interest in answering business enquiries (Art. 6(1)(f) GDPR).
- Sending the newsletter, with market notes and news about our services. Legal basis: your consent (Art. 6(1)(a) GDPR).
- Running the signal rooms you join. Legal basis: our contract with you (Art. 6(1)(b) GDPR).
- Keeping the site and forms secure, and filtering spam. Legal basis: our legitimate interest in a safe, working site (Art. 6(1)(f) GDPR).
- Meeting legal duties, such as tax and accounting rules or requests from authorities. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
- Establishing or defending legal claims. Legal basis: our legitimate interest (Art. 6(1)(f) GDPR).
You can withdraw your consent to the newsletter at any time, with the unsubscribe link in every email or by writing to us. This does not affect emails already sent.
Where we rely on legitimate interest, you can object at any time. See section 07.
We will not use your data for any other purpose without telling you first.
4. Retention
We keep data only as long as we need it:
- Get started requests that do not lead to an agreement: 24 months from our last exchange.
- If an agreement follows: for as long as it lasts, then up to 10 years for tax, accounting and legal claims.
- Newsletter: until you unsubscribe. After that, we keep only a record of your consent and of its withdrawal, for 24 months, as proof.
- Signal rooms: while you are a member. When you leave, we keep only the records that accounting rules require.
- Spam submissions: deleted when we see them, and within 30 days at the latest.
- Server logs: kept by Netlify for a short time, under its own rules, for security and operation. We do not export or keep them.
These periods apply wherever we keep the data, including Netlify and our email inbox.
5. Sharing
We do not sell or rent personal data. We share it only with:
- Netlify, Inc., our hosting provider. It receives and stores form submissions and forwards them to us by email. It acts as our processor.
- Netlify's sub-processors, such as its spam-filtering service, under Netlify's data processing terms.
- Our email provider, which hosts the inbox where submissions arrive and from which we reply.
- A broker, prop firm or authorised firm, only if you ask us to put you in touch, and only the data needed for that.
- Professional advisers, such as lawyers and accountants, when needed and under a duty of confidentiality.
- Authorities, courts or regulators, when the law requires it.
If you reach us through a partner that uses our services under its own brand, that partner is responsible for your data in its relationship with you, and its privacy policy applies. When we process data for a partner, we act only on its instructions.
6. International transfers
Netlify is based in the United States. Our email provider may also store data outside your country.
When personal data from the EU, the EEA, the UK or Switzerland goes to a country without an adequacy decision, it is protected by one of these safeguards:
- the EU-US Data Privacy Framework, with its UK and Swiss extensions, where the recipient is certified
- the Standard Contractual Clauses approved by the European Commission, with the UK addendum where needed, in the provider's data processing terms
You can ask us for a copy of these safeguards.
7. Your rights
You have the right to:
- access the personal data we hold about you
- correct it
- have it deleted
- restrict its use
- receive the data you gave us in a common format, where we use it on the basis of consent or contract
- object to its use based on legitimate interest, and to direct marketing at any time
- withdraw your consent at any time
To use these rights, write to thesourceoffinance@gmail.com. We reply within one month. We may ask you to confirm your identity. It is free, unless a request is clearly unfounded or excessive.
You can also complain to the data protection authority of your country of residence. In the EU and EEA, you can also complain in the country where you work or where the issue arose.
8. Cookies
This site sets no cookies.
It loads nothing from third parties: no analytics, no advertising pixels, no external fonts, maps or videos. Fonts and images are served from our own site.
The home page stores one item in your browser's session storage:
- tsf-intro, value 1: it remembers that the opening animation has played, so that it does not play again during the same visit. It holds no personal data, is not shared, and is deleted when you close the tab.
This item is used only to display the page, so it does not need your consent.
If we ever add cookies or tools that need consent, we will ask for it first and list them here.
9. Children
Our services are for adults aged 18 or over. We do not knowingly collect data from children.
If you think a child has sent us data, write to us and we will delete it.
10. Changes to this policy
This policy may be updated. The date at the top of the page shows the current version.
If a change affects how we use data you have already given us, we will tell you before it applies.
11. Contact
For privacy questions or to exercise your rights, contact: