Privacy Policy

Effective Date: June 24, 2026 • Last Updated: June 24, 2026

1. Introduction

Facilitrades, LLC ("FaciliTrades," "we," "us," or "our") operates the FaciliTrades platform, an AI-powered peer-to-peer trading network. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the platform.

2. Information We Collect

2.1 Information You Provide

Data TypeExamplesPurpose
Account InformationEmail address, username, password hashAccount creation, authentication
Profile InformationDisplay name, profile photo, bio, city or region label, precise location (optional and opt-in)Platform personalization, nearby discovery
Trading ContentItem listings, descriptions, photos, postsPlatform functionality
CommunicationsMessages between users, support inquiriesTrade facilitation, support
Transaction RecordsTrade proposals, agreements, confirmationsPlatform functionality, dispute resolution
Payment InformationBilling contact, purchase history, and a payment-processor customer ID. Full card numbers, CVV, and bank credentials are entered directly with our payment processor and never reach FaciliTrades.Process Ticket and subscription purchases, billing records

2.2 Information Collected Automatically

Data TypeExamplesPurpose
Device InformationIP address, browser type, operating system, device identifiersSecurity, analytics, fraud prevention
Usage DataPages visited, features used, search queries, timestampsPlatform improvement, AI training
Location DataApproximate location from IP address; if you opt in, precise browser or device coordinatesRegional matching, nearby discovery, fraud prevention

When you explicitly enable location sharing, we store your precise coordinates to power distance-based discovery. Other users see only the location label you provide or confirm, such as a city or region, and an approximate distance when relevant. We do not publicly expose raw coordinates.

If you later turn location sharing off, the change takes effect immediately: other users stop seeing your city or region on your profile and your listings, and your items and wanted posts no longer appear in other users’ distance-based search results. We continue to store any location you previously entered so you can re-enable sharing without re-entering it. Self-view is never gated — you can always see your own location in your own account. If you want your stored location data permanently removed, use the account deletion flow in Settings to trigger our standard GDPR deletion process.

2.3 Information from Third Parties

  • OAuth Providers: If you sign in via Google, Apple, or Facebook, we receive your email and profile information as authorized by you
  • Analytics Services: Aggregated usage patterns (no personal identification)

3. How We Use Your Information

PurposeLegal Basis (GDPR)
Provide and maintain platform servicesContract performance
Process trades and facilitate exchangesContract performance
Process Ticket and subscription paymentsContract performance
Send transactional notificationsContract performance
Improve AI features (semantic search, listing assistance)Legitimate interest
Prevent fraud and ensure platform securityLegitimate interest
Respond to support requestsContract performance
Comply with legal obligationsLegal obligation
Send marketing communications (with consent)Consent

3.1 AI and Machine Learning

Our AI features process your data to:

  • Generate semantic embeddings for item discovery (your listings)
  • Provide listing assistance suggestions
  • Detect potential fraud patterns
  • Match traders with complementary interests

Important: AI processing is designed to improve your experience. You can opt out of non-essential AI features in account settings.

4. How We Share Your Information

4.1 Public Information

The following information is publicly visible on the platform:

  • Username and profile photo
  • Location label you choose to display, such as a city or region
  • Item and service listings
  • Reputation score and review count
  • Account age indicator

4.2 Other Users

When you engage in trades, the following is shared with your trading partner:

  • Username and profile information
  • Listing details
  • Messages exchanged
  • Trade history (after trade completion)

4.3 Service Providers

We share data with trusted service providers who assist in operating our platform:

ProviderPurposeData Shared
Google Cloud PlatformInfrastructure hostingAll platform data (encrypted)
Stripe, Inc.Payment processing for purchases made on the webBilling email and name, payment method details (entered directly into Stripe), IP address and device data for fraud detection (Stripe Radar), transaction amounts
AppleIn-App Purchase processing (iOS app)Purchase and subscription data necessary to complete App Store transactions
GoogleGoogle Play Billing (Android app)Purchase and subscription data necessary to complete Google Play transactions
Email service providerTransactional emailsEmail address, name
Analytics providerUsage analyticsAnonymized usage data
OpenStreetMap / NominatimGeocoding (turning city names into coordinates and vice versa) when you set a location in your profile or use “Use my current location”The text you type in the location picker, or your device coordinates if you opt in. Sent only when you interact with the picker — never in the background.

All service providers are bound by data processing agreements. Map and location data © OpenStreetMap contributors, available under the Open Database License.

4.4 Legal Requirements

We may disclose information when required by law, court order, or government request, or to:

  • Protect our rights, property, or safety
  • Investigate potential Terms of Service violations
  • Respond to legal claims

Child safety reporting.Where we detect or become aware of content that appears to constitute child sexual abuse material (CSAM), U.S. federal law (18 U.S.C. §2258A) requires us to report it — together with the associated content and account information — to the National Center for Missing & Exploited Children (NCMEC) through its CyberTipline, and to preserve that material for the period required by law. This reporting is mandatory and occurs without prior notice to the affected user.

4.5 Payment Processors

When you purchase Tickets or a subscription, your payment is processed by a third-party processor acting on our behalf, depending on the platform you use:

  • Web: Stripe, Inc. (PCI-DSS Level 1 certified). Full card numbers, CVV, and bank credentials are entered directly into Stripe’s interface and are never transmitted to or stored by FaciliTrades. Stripe processes your data under Stripe’s Privacy Policy.
  • Apple iOS app:Apple processes In-App Purchases under Apple’s privacy policy and Media Services terms.
  • Google Android app:Google processes Google Play Billing purchases under Google’s privacy policy and Google Play terms.

FaciliTrades retains only the records needed to deliver your purchases and meet legal and tax obligations — a payment-processor customer ID, your subscription status, and transaction history (amounts, dates, and product purchased). You may request deletion of your payment-processor customer ID by contacting info@facilitrades.com; transaction records required for legal or tax compliance may be retained in anonymized form.

5. Data Retention

Data TypeRetention PeriodReason
Active account dataDuration of accountService provision
Closed account data30 days after closureReactivation period
Trade records7 yearsLegal/tax requirements
Support communications3 yearsDispute resolution
Server logs90 daysSecurity, debugging
AI usage logs12 monthsBilling, service improvement
Payment transaction records7 yearsLegal/tax requirements
Payment-processor customer IDDuration of account + 7 yearsBilling continuity, refund processing
CSAM evidence (confirmed reports)90 days after CyberTipline report; longer only on government requestLegal preservation duty (18 U.S.C. §2258A(h))
Moderation & safety records3 years after resolutionAbuse investigation, platform safety

5.1 Deletion Requests

Upon verified deletion request:

  • Personal profile data: Anonymized or deleted within 30 days
  • Location data: Precise coordinates and saved location labels are removed within 30 days of account closure
  • Trade records: Preserved for legal and platform integrity reasons, but linked accounts are anonymized
  • Backups: Purged within 90 days of deletion

6. Your Rights

6.1 All Users

You have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Delete your account and data
  • Export your data in portable format
  • Object to certain processing activities

6.2 EU/EEA Residents (GDPR)

Additional rights under GDPR:

  • Right to restrict processing
  • Right to data portability
  • Right to withdraw consent
  • Right to lodge complaint with supervisory authority

6.3 California Residents (CCPA)

Additional rights under CCPA:

  • Right to know what data is collected
  • Right to know what data is sold (we do not sell personal data)
  • Right to opt-out of data sales (not applicable)
  • Right to non-discrimination for exercising rights

6.4 Exercising Your Rights

To exercise your rights, contact us at:

We will respond within 30 days (or sooner as required by applicable law).

7. Data Security

We implement appropriate technical and organizational measures:

MeasureImplementation
Encryption in transitTLS 1.3 for all connections
Encryption at restGCP default encryption (AES-256)
Access controlsRole-based access, principle of least privilege
AuthenticationJWT tokens, OAuth 2.0, optional MFA
MonitoringAutomated threat detection, audit logging
Incident responseDocumented breach notification procedures

8. International Data Transfers

Your data is stored on Google Cloud Platform servers in the United States (us-east4 region).

For EU/EEA users, transfers are protected by:

  • Google Cloud's Standard Contractual Clauses (SCCs)
  • Additional technical safeguards

9. Children's Privacy

FaciliTrades is not intended for users under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware of data collected from a child under 13, we will delete it promptly.

Content involving the sexual exploitation of a minor is handled differently from ordinary under-13 data: where we detect apparent child sexual abuse material (CSAM), we do not simply delete it. As required by 18 U.S.C. §2258A we preserve it in a restricted, access-limited store and report it, together with associated account information, to the National Center for Missing & Exploited Children (NCMEC) and cooperate with law enforcement.

10. Non-Custodial Platform Notice

Important: FaciliTrades is a non-custodial platform. We do not hold, store, or control:

  • Physical items being traded
  • Cryptocurrency or digital assets
  • Precious metals or commodities

Users arrange fulfillment directly with each other. We provide matchmaking, agreement structuring, and reputation tracking only.

11. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted with an updated "Last Updated" date. Material changes will be notified via:

  • Email notification
  • In-app notification
  • Banner on the platform

Continued use after changes constitutes acceptance.

12. Contact Us

Facilitrades, LLC

All Inquiries: info@facilitrades.com

Founding Member

Fenrir Consulting, LLC (50% Founding Member)

Data Protection Officer (GDPR)

Email: info@facilitrades.com