COT Bias Terminal ("we", "us", "our") is operated by the owners of the COT Bias Terminal platform, based in Berlin, Germany. As a company operating within the European Union, we are subject to the General Data Protection Regulation (GDPR) (EU) 2016/679.
This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights as a data subject. It applies to all users of the Platform globally, though EU/EEA residents have additional rights under GDPR, which are detailed below.
For any privacy-related questions, contact us at: support@cot-bias-terminal.com
| Data | When Collected |
|---|---|
| Name | On account registration |
| Email address | On account registration and contact forms |
| Payment information | On subscription purchase (processed by third-party payment provider; we do not store card data) |
| Account preferences and settings | When you configure your account |
| Communications | When you contact support |
| Data | Purpose |
|---|---|
| IP address | Security, fraud prevention, geographic compliance |
| Browser type and version | Platform optimisation and debugging |
| Device type and operating system | Responsive design and compatibility |
| Pages visited and features used | Analytics and product improvement |
| Session duration and timestamps | Usage analysis |
| Referral source | Marketing attribution |
| Cookies and similar technologies | Session management, preferences, analytics (see Section 7) |
We do not collect sensitive personal data (e.g. health data, biometric data, political opinions, racial or ethnic origin) unless you voluntarily provide it in a support communication.
We do not collect trading account data, brokerage information, or personal financial details beyond subscription payment processing.
For users in the EU/EEA, all data processing is carried out under one or more of the following lawful bases under GDPR Article 6:
| Processing Activity | Legal Basis |
|---|---|
| Creating and managing your account | Performance of a contract (Art. 6(1)(b)) |
| Processing subscription payments | Performance of a contract (Art. 6(1)(b)) |
| Providing Platform features and Content | Performance of a contract (Art. 6(1)(b)) |
| Sending transactional emails (receipts, alerts) | Performance of a contract (Art. 6(1)(b)) |
| Security, fraud prevention, and abuse detection | Legitimate interests (Art. 6(1)(f)) |
| Platform analytics and product improvement | Legitimate interests (Art. 6(1)(f)) |
| Marketing communications (where opted in) | Consent (Art. 6(1)(a)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
You may withdraw consent for marketing communications at any time by using the unsubscribe link in any marketing email or by contacting support@cot-bias-terminal.com.
We use your personal data for the following purposes:
We will never sell, rent, or trade your personal data to third parties for their own marketing purposes.
The AI Inference feature processes COT market data — which is public domain data from the CFTC — to generate natural language summaries. This processing does not involve your personal data.
AI-generated outputs are statistical summaries of public financial data, not personalised content derived from your profile or behaviour.
Your usage patterns (e.g. which instruments you view) may be used in aggregate and anonymised form to improve the Platform, but are not used to personalise AI Inference outputs.
We do not feed your personal data into any LLM or AI model.
We share personal data with third parties only where necessary and under strict conditions:
| Third Party | Purpose | Safeguards |
|---|---|---|
| Payment processor (e.g. Stripe) | Subscription billing | PCI-DSS compliant; their own privacy policy applies |
| Cloud hosting provider | Platform infrastructure | EU/EEA data centre or Standard Contractual Clauses (SCCs) |
| Analytics provider | Usage analytics | Anonymised/pseudonymised data; Data Processing Agreement in place |
| LLM provider (AI Inference) | Processing COT data for AI outputs | No personal data transmitted; only public CFTC data sent as context |
| Email service provider | Transactional and marketing emails | Data Processing Agreement in place |
| Legal/regulatory authorities | Where required by applicable law | Only to the minimum extent legally required |
We require all third-party processors to handle data in accordance with GDPR and applicable privacy laws. Where data is transferred outside the EU/EEA, we ensure adequate protections are in place via Standard Contractual Clauses (SCCs) or equivalent mechanisms.
COT Bias Terminal uses cookies and similar technologies. By using the Platform, you consent to our use of cookies in accordance with this policy.
| Type | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly necessary | Session management, authentication, security | No — required for the Platform to function |
| Functional | Remembering your preferences (e.g. theme, filters) | No — required for core usability |
| Analytics | Understanding how users interact with the Platform | Yes — via cookie consent settings |
| Marketing | Measuring the effectiveness of campaigns | Yes — via cookie consent settings |
You can manage or withdraw cookie consent at any time via the cookie settings on the Platform. You can also manage cookies through your browser settings. Note that disabling strictly necessary cookies will impair Platform functionality.
We do not use cookies for automated decision-making or profiling that has legal or significant effects on you.
We retain personal data only for as long as necessary for the purposes described in this policy:
| Data Type | Retention Period |
|---|---|
| Account data | For the duration of your account, plus 2 years after closure |
| Payment and billing records | 10 years (required under German commercial law / HGB §257) |
| Support communications | 3 years from the date of correspondence |
| Usage and analytics data | 24 months, then deleted or anonymised |
| Marketing consent records | Until consent is withdrawn, plus 1 year |
When data is no longer needed, it is securely deleted or anonymised.
Under GDPR, you have the following rights:
To exercise any of these rights, contact: support@cot-bias-terminal.com
We will respond within 30 days of receiving your request. We may need to verify your identity before processing the request.
You also have the right to lodge a complaint with your national data protection authority. In Germany, this is the Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information).
Depending on your jurisdiction, you may have additional or equivalent privacy rights under local law (e.g. CCPA for California residents, PIPEDA for Canadian residents, PDPA for Singapore residents). We will honour equivalent requests from users in these jurisdictions to the extent required by applicable law. Contact us at support@cot-bias-terminal.com to submit a request.
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:
No method of transmission over the internet is 100% secure. While we take all reasonable precautions, we cannot guarantee absolute security. If you suspect unauthorised access to your account, contact us immediately at support@cot-bias-terminal.com.
In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify affected users without undue delay and report to the relevant supervisory authority within 72 hours as required by GDPR Article 33.
COT Bias Terminal is based in Berlin, Germany (EU). When your data is transferred to service providers outside the EU/EEA (e.g. cloud hosting or analytics providers based in the US), we ensure adequate protection through:
You may request further information about our transfer safeguards by contacting support@cot-bias-terminal.com.
The Platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us at support@cot-bias-terminal.com and we will delete it promptly.
We reserve the right to update this Privacy Policy at any time. Material changes will be communicated via email or a prominent notice on the Platform. The "Last Updated" date at the top of this document reflects the most recent revision.
We encourage you to review this policy periodically. Continued use of the Platform after changes take effect constitutes acceptance.
Data Controller:
COT Bias Terminal
Berlin, Germany
Email: support@cot-bias-terminal.com
For GDPR-related requests, data subject rights, or privacy complaints, contact us at the above email. We aim to respond within 30 days.
This Privacy Policy was last reviewed and updated in June 2026.
© 2026 COT Bias Terminal. All rights reserved.