Privacy Policy

Effective Date: January 1, 2026

Last Updated: January 1, 2026

Market Maker Trading ("we," "us," "our," or the "Company") operates the website marketmakertrading.com (the "Site") and provides online trading education services, including live challenge events, mentorship programs, digital courses, and related offerings (collectively, the "Services"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you visit our Site, register for our Services, or otherwise interact with us.

By accessing the Site or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Site or Services.

1. Information We Collect

1.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us when you register for an account, sign up for a challenge event, purchase a course or mentorship program, subscribe to our communications, or otherwise contact us. This information may include:

• Full name (first and last name)
• Email address
• Phone number (including mobile number for WhatsApp communications)
• Payment and billing information (processed through our third-party payment processors; we do not store full credit card numbers on our servers)
• Any additional information you choose to provide via forms, surveys, support requests, or direct correspondence with us

We collect this information primarily through Tally-powered forms embedded on our Site. When you submit a form, the data you enter is transmitted to Tally's servers and subsequently made available to us for the purposes described in this Policy.

1.2 Information Collected Automatically

When you visit our Site, certain information is collected automatically through cookies, tracking pixels, and similar technologies. This includes:

• Device and browser information: IP address, browser type and version, operating system, device type, screen resolution, and language preferences
• Usage data: pages visited, time spent on pages, click patterns, referral URLs, entry and exit pages, and navigation paths through the Site
• Location data: approximate geographic location derived from your IP address
• Tracking and attribution data: UTM parameters, ad campaign identifiers, conversion events, and customer journey data collected through our analytics and attribution platforms (see Section 3 for details)

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Advertising platforms (such as Meta/Facebook, Google Ads) that share conversion and audience data
• Payment processors that confirm transaction status
• Publicly available sources relevant to our legitimate business interests

2. How We Use Your Information

We use the personal information we collect for the following purposes:

• Service delivery: To provide, maintain, and improve our trading education services, including enrollment in challenge events, delivery of course materials, and facilitation of mentorship sessions
• Communications: To send you transactional emails (purchase confirmations, event reminders, account updates), marketing communications (newsletters, promotional offers, new course announcements), and operational notices. You may opt out of marketing communications at any time.
• Community management: To add you to relevant WhatsApp groups, community channels, or other communication platforms associated with your enrolled programs
• Payment processing: To process transactions, manage subscriptions, issue refunds, and prevent fraud
• Analytics and optimization: To understand how users interact with our Site and Services, measure the effectiveness of our marketing campaigns, and improve user experience
• Advertising attribution: To track the effectiveness of our advertising spend, attribute conversions to specific campaigns, and optimize our marketing efforts
• Legal compliance: To comply with applicable laws, regulations, legal processes, or governmental requests
• Protection of rights: To enforce our Terms of Service, protect against fraud or unauthorized activity, and safeguard the rights, property, or safety of Market Maker Trading, our users, or the public

3. Cookies, Tracking Technologies, and Third-Party Services

3.1 Cookies

Our Site uses cookies and similar tracking technologies (including local storage and session storage) to enhance your browsing experience, remember your preferences, and collect analytical data. Cookies are small text files stored on your device by your web browser.

We use the following categories of cookies:

• Strictly necessary cookies: Required for the Site to function properly (e.g., session management, security tokens). These cannot be disabled.
• Functional cookies: Enable enhanced functionality and personalization (e.g., remembering your preferences, pre-filling form fields).
• Analytics cookies: Help us understand how visitors interact with our Site by collecting and reporting information anonymously or pseudonymously.
• Advertising and tracking cookies: Used to deliver relevant advertisements, track ad campaign performance, and attribute conversions across platforms.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impair the functionality of the Site.

3.2 Hyros (Advertising Attribution and Tracking)

We use Hyros, a third-party advertising attribution and tracking platform, to monitor and analyze the performance of our marketing campaigns. Hyros collects data including:

• Click and conversion tracking across advertising platforms
• Customer journey mapping from initial ad impression through purchase
• Revenue attribution to specific campaigns, ad sets, and creatives
• Email and phone number matching for cross-device and cross-platform tracking

Hyros uses cookies, tracking pixels, and server-side integrations to collect this data. The information collected by Hyros is governed by Hyros's own privacy policy, available at https://hyros.com/privacy-policy. We use this data solely for marketing optimization and do not sell it to unrelated third parties.

3.3 Vidalytics (Video Hosting and Analytics)

We use Vidalytics, a third-party video hosting and analytics platform, to deliver educational video content on our Site. Vidalytics may collect:

• Video viewing behavior (play, pause, completion rates, watch duration, drop-off points)
• Device and browser information
• IP address and approximate geolocation

Vidalytics uses cookies and similar technologies to provide video playback functionality and to generate analytics reports about video engagement. The information collected by Vidalytics is governed by Vidalytics's own privacy policy.

3.4 Tally (Form Collection)

We use Tally to create and manage data collection forms on our Site. When you submit information through a Tally form, your data is processed by Tally's servers before being made available to us. Tally's handling of your data is governed by Tally's privacy policy, available at https://tally.so/help/privacy-policy.

3.5 Netlify (Web Hosting)

Our Site is hosted on Netlify. Netlify automatically collects certain server logs, including IP addresses and request metadata, as part of its standard hosting operations. Netlify's handling of this data is governed by Netlify's privacy policy, available at https://www.netlify.com/privacy/.

3.6 WhatsApp (Community Communications)

We use WhatsApp for community group communications related to our programs. When you join a Market Maker Trading WhatsApp group, your phone number and WhatsApp profile information become visible to other group members and to us as group administrators. WhatsApp's handling of your data is governed by WhatsApp's privacy policy. We do not control WhatsApp's data practices and encourage you to review WhatsApp's privacy policy independently.

3.7 Additional Third-Party Services

We may use additional third-party service providers for payment processing, email marketing, customer support, and other operational functions. Each of these providers has its own privacy policy governing its use of your data. We select providers who maintain appropriate data protection standards, but we are not responsible for the privacy practices of third-party services.

4. Legal Bases for Processing (GDPR)

For individuals located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or other jurisdictions that require a legal basis for processing personal data, we rely on the following legal bases under the General Data Protection Regulation ("GDPR") and equivalent legislation:

• Performance of a contract: Processing is necessary to fulfill our contractual obligations to you, including delivering purchased courses, challenge events, and mentorship programs (Article 6(1)(b) GDPR).
• Consent: Where you have given clear, affirmative consent for us to process your personal data for specific purposes, such as receiving marketing communications or the placement of non-essential cookies (Article 6(1)(a) GDPR). You may withdraw your consent at any time.
• Legitimate interests: Processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include marketing optimization, fraud prevention, improving our Services, and understanding how users interact with our Site (Article 6(1)(f) GDPR).
• Legal obligation: Processing is necessary to comply with a legal obligation to which we are subject, such as tax reporting or responding to lawful requests from public authorities (Article 6(1)(c) GDPR).

5. Data Sharing and Disclosure

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• Service providers: We share data with third-party vendors who perform services on our behalf (payment processing, email delivery, hosting, analytics, customer support). These providers are contractually obligated to use your data only for the purposes we specify and in accordance with this Privacy Policy.
• Advertising partners: We may share hashed or pseudonymized data (such as hashed email addresses) with advertising platforms for the purpose of audience targeting, conversion tracking, and campaign optimization.
• Business transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
• Legal requirements: We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, the safety of others, investigate fraud, or respond to a government request.
• With your consent: We may share your information for any other purpose with your explicit consent.

6. International Data Transfers

Market Maker Trading serves customers in the United States, the United Kingdom, the European Union, and other countries. Your personal information may be transferred to and processed in countries other than your country of residence, including the United States, where data protection laws may differ from those in your jurisdiction.

For transfers of personal data from the EEA or UK to countries that have not been deemed to provide an adequate level of data protection, we implement appropriate safeguards, which may include:

• Standard Contractual Clauses ("SCCs") approved by the European Commission
• The UK International Data Transfer Agreement or Addendum, as applicable
• Binding Corporate Rules, where applicable
• Transfers to recipients in countries with an adequacy decision from the European Commission or UK Secretary of State

By using our Services, you acknowledge and consent to the transfer and processing of your information in jurisdictions outside your country of residence.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, tax, or reporting requirements. Specifically:

• Account and transaction data: Retained for the duration of your account relationship with us, plus a minimum of seven (7) years after the relationship ends, to comply with tax and financial record-keeping obligations.
• Marketing communication data: Retained until you unsubscribe or request deletion, unless we are required to retain it for legal purposes.
• Analytics and tracking data: Retained for up to twenty-six (26) months from the date of collection, after which it is aggregated or anonymized.
• Support correspondence: Retained for up to three (3) years after the resolution of your inquiry.

When personal data is no longer required for the purposes stated above, we will securely delete or anonymize it. Where deletion is not immediately possible (for example, because data is stored in backup archives), we will isolate and protect the data from further processing until deletion is feasible.

8. Your Rights Under GDPR (EEA and UK Residents)

If you are located in the European Economic Area or the United Kingdom, you have the following rights under the GDPR and equivalent UK data protection legislation:

• Right of access (Article 15): You have the right to request a copy of the personal data we hold about you.
• Right to rectification (Article 16): You have the right to request correction of inaccurate or incomplete personal data.
• Right to erasure (Article 17): You have the right to request deletion of your personal data, subject to certain legal exceptions (e.g., where retention is required for legal compliance).
• Right to restriction of processing (Article 18): You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to data portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to object (Article 21): You have the right to object to the processing of your personal data based on our legitimate interests. You also have the right to object to direct marketing at any time.
• Right to withdraw consent (Article 7(3)): Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with your local data protection supervisory authority if you believe your rights have been infringed.

To exercise any of these rights, please contact us at info@marketmakertrading.com. We will respond to your request within thirty (30) days, or within the time period required by applicable law.

9. Your Rights Under CCPA (California Residents)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"):

• Right to know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share the information.
• Right to delete: You have the right to request that we delete your personal information, subject to certain legal exceptions.
• Right to correct: You have the right to request that we correct inaccurate personal information.
• Right to opt out of sale or sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes as defined by the CPRA. If this practice changes in the future, we will provide a "Do Not Sell or Share My Personal Information" link on our Site.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge you different prices, or provide a different level or quality of service because you exercised your rights.
• Right to limit use of sensitive personal information: If we collect sensitive personal information (as defined under the CPRA), you have the right to limit its use to purposes necessary to perform the services you have requested.

To exercise your CCPA rights, please contact us at info@marketmakertrading.com or submit a request through our Site. We may need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

10. Data Security

We implement reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Secure hosting infrastructure provided by Netlify with industry-standard security certifications
• Access controls limiting employee and contractor access to personal data on a need-to-know basis
• Regular review and updating of our security practices

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

11. Children's Privacy

Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe that a child under 18 has provided us with personal information, please contact us at info@marketmakertrading.com.

12. Do Not Track Signals

Some web browsers transmit "Do Not Track" ("DNT") signals to websites. Because there is no universally accepted standard for how to respond to DNT signals, our Site does not currently respond to DNT signals. However, you can manage your tracking preferences through cookie settings in your browser and through the opt-out mechanisms described in this Policy.

13. Third-Party Links

Our Site may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the content, privacy practices, or data collection practices of any third-party sites or services.

14. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on our Site. Your continued use of the Site or Services after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Market Maker Trading
Email: info@marketmakertrading.com
Website: marketmakertrading.com

For GDPR-related inquiries, EEA and UK residents may also contact their local data protection supervisory authority.

For CCPA-related inquiries, California residents may also contact the California Attorney General at oag.ca.gov.