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Privacy Policy

Effective 2026-10-03

This Privacy Policy explains what information Holobyte LLC ("Reflect", "we") collects when you use Reflect, how we use it, and who we share it with.

Information we collect

Account information. The email address and any profile details you provide when you request access and create an account.

Broker connection data. When you connect a brokerage account, we store the access credentials (authorization tokens) needed to read your account activity and place orders on your behalf, along with identifiers for the connected account and environment (for example, demo or live).

Trading and activity data. Order, fill, position, and balance information from your connected brokerage account; the copying configuration you set; and the records Reflect generates to mirror, reconcile, and bill for trades (including fees, charges, and payouts).

Payment information. Payments are handled by our payment processor (Stripe). We receive limited billing details, card brand or bank name and last four digits, processor identifiers, bank-mandate status, and payment and payout status. Stripe collects payment credentials and trader verification information through its own flows. We do not store full payment card or bank account numbers.

Usage and technical data. Log data, device and browser information, IP address, and cookies used to keep you signed in and to remember your role and preferences.

How we use information

We use information to operate the copying service, place and reconcile orders, calculate and process fees and payouts, secure and debug the service, communicate with you, and comply with legal obligations.

We do not sell your personal information.

How we share information

We share information with the following recipients as needed to provide the service:

  • your broker, to read account activity and place orders you have authorized; your broker also handles data under its own agreements and privacy policy
  • Stripe, to verify payment and payout accounts and process payments and payouts; Stripe also handles information under its own privacy policy and legal obligations
  • our hosting and infrastructure provider, to run the service
  • our error-monitoring and email providers, to operate and support the service

We may also disclose information to comply with law, enforce our Terms, or protect the rights, safety, and property of Reflect, our users, or others, and in connection with a business transfer.

Relationship participants receive each other's email address and display name, proposed and accepted terms, relationship activity, and the trading and compensation information shown for that relationship. Invitations include the sender's identity, proposed terms, and any note for the recipient. Reflect does not share your brokerage credentials or brokerage account identifiers with the other participant.

Optional verified connections

If you use Verily to connect an external identity, Reflect sends Verily your display name and an identifier derived from your Reflect user ID, rather than your raw user ID or email address. Reflect reads the resulting connection records, including revoked and expired records, and may show connection badges to users viewing your trader profile or relationship request. Verily operates at verily.shirkadeh.org and receives browser requests when you use its connection tools. Review the information shown in that flow before connecting. Revoking a connection does not necessarily delete its historical record.

Data security

We use reasonable administrative and technical safeguards to protect information, including access controls, scoped data access, and encryption at rest of the broker access credentials we store. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for protecting your own login credentials.

Data retention

We retain information for as long as your account is active and as needed to provide the service, then as required to meet legal, accounting, tax, and dispute-resolution obligations. Financial and transaction records may be retained longer than other data to satisfy those obligations.

Your choices

You may remove a linked account to stop Reflect using it for copying. Removing it does not revoke the broker's authorization grant; use your broker's controls to revoke that grant. Other accounts sharing the connection can remain linked. You may ask to delete your account at any time in settings. The deletion completes once your open copied positions are closed and amounts owed are settled, and you can cancel it until then. While it is waiting, no new positions are opened for you. Deleting the account removes your sign-in, sessions, and stored broker credentials; we keep the financial and transaction records we must retain. You may request a copy of your personal information at legal@reflect.trading.

Cookies

We use cookies to keep you signed in and to store interface preferences such as your active role and view. Disabling cookies may break sign-in and core functionality.

Children

Reflect is not directed to anyone under 18 and we do not knowingly collect information from them.

Changes

We may update this policy. Material changes will be indicated by updating the effective date and, where appropriate, by notice.

Contact

Privacy questions: legal@reflect.trading