1. Scope and Controller
[COMPANY LEGAL NAME] ("we", "us") operates FinSimTrading. This policy covers the Platform, our emails and our support channels. Where a school, district or organization licenses the Platform, that institution may act as the data controller for learner records and we process those records on its instructions.
Privacy questions: [PRIVACY EMAIL] · Postal: [COMPANY MAILING ADDRESS]
2. Information We Collect
2.1 Information you provide
- Name, username/handle and display name
- Email address and, where provided, phone number
- Organization, school, district, class and teacher associations
- Date of birth or age band, and grade level
- Parent/guardian name, email and typed consent signature where applicable
- Uploaded files, essays, research reports, stock pitches and messages you send us
2.2 Learning and activity information
- Course and lesson enrollments and completion
- Quiz scores, practice attempts and mastery indicators
- Simulation performance, portfolio history and trade logs (VCcoins only)
- Competition entries, awards, certificates and digital badges
- Streaks, achievements and leaderboard placements
2.3 Technical information
- Device and browser information, operating system and screen characteristics
- IP address and approximate location derived from it, where permitted
- Log data, diagnostics, crash reports and performance metrics
- Cookies and similar technologies (see our Cookie Policy)
- Analytics events describing how features are used
2.4 Payment information
Payments are processed by a secure third-party payment provider. We receive limited billing metadata such as plan, status, last four digits and expiry — we never receive or store full card numbers.
2.5 Policy acceptance records
When you create an account or accept updated policies, we record the acceptance timestamp, user ID, policy versions accepted, IP address, browser and device information, user agent and (where available) country. These records are retained for legal and audit purposes.
3. How We Use Information
- Provide, personalise and maintain accounts, lessons, simulations and certificates
- Deliver AI tutoring, feedback and study recommendations
- Process subscriptions, licences, competition entries and refunds
- Send essential service messages and, if you opt in, product news
- Score competitions, generate leaderboards and issue awards
- Provide progress reports to authorised teachers, schools and plan owners
- Detect fraud, cheating and abuse, and secure the Platform
- Analyse and improve features, content and reliability
- Meet legal, tax, accounting and audit obligations
Where required by law, our legal bases include performance of a contract, legitimate interests (security, improvement, fraud prevention), consent (optional cookies and marketing) and legal obligation.
4. Educational Data
Educational information may be shared with authorised schools, teachers, districts, organizations, employers running educational programs, and competition or scholarship administrators for purposes including:
- Enrollment and roster management
- Attendance and participation tracking
- Assignments and progress monitoring
- Certificates and course completion
- Competitions, awards and scholarships
- Leaderboards within the learner's plan or class
- Reports, academic analytics and program administration
Access is limited to the learners assigned to that teacher, class, plan or program. Learners outside a plan cannot see one another's records.
6. AI Processing
When you use AI tutoring or feedback features, your prompt and relevant learning context are sent to our AI provider to generate a response. We instruct providers not to use Platform content to train their general models. Do not enter sensitive personal information into AI features. See our AI Usage Policy.
8. Data Retention
- Account and learning records: while the account is active, then deleted or anonymised within a reasonable period after closure
- School-administered records: per the institution's instructions and contract
- Policy acceptance and billing records: retained as required for legal, tax and audit purposes
- Security and log data: retained for a limited period for troubleshooting and abuse prevention
9. Your Rights and Choices
- Access the personal information we hold about you
- Update your profile and account details
- Request deletion of your account and associated data, where applicable
- Download a copy of your personal data in a portable format
- Manage cookie preferences
- Opt out of promotional communications at any time
- Object to or restrict certain processing, and withdraw consent where processing is consent-based
- Lodge a complaint with your local data protection authority
To exercise a right, contact [PRIVACY EMAIL]. We may need to verify your identity first.
10. Children's Privacy
Accounts must be held by adults. Where a learner under 13 participates through a parent/guardian or school account, we handle their information as described in our Children's Privacy Policy (COPPA) and, for school records, our FERPA Information page.
11. Security
We use encryption in transit, access controls, row-level database security, least-privilege service credentials, logging and regular review. No online service is perfectly secure; please use a strong unique password and tell us promptly about anything suspicious.
12. International Transfers
We and our providers may process information in countries other than yours. Where required, we use appropriate safeguards such as standard contractual clauses and provider certifications.
13. Changes to This Policy
We may update this policy. The version and "Last updated" date above always reflect the current text, and we notify account holders of material changes by email or in-app notice.
14. Contact Us
[COMPANY LEGAL NAME] · [COMPANY MAILING ADDRESS] · Privacy: [PRIVACY EMAIL] · Support: [SUPPORT EMAIL]