Mindoro Privacy Policy
Effective Date: 11 October 2026
1. About Mindoro and This Privacy Policy
Mindoro is operated by Pointwest Australia Pty Ltd (ACN 168 372 601, ABN 38 168 372 601), an Australian company.
This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, register for an account or use Mindoro's services.
This policy applies to:
mindoro.com.au — Mindoro's public website
mindoro.app — Mindoro's trading performance application
Related Mindoro services, communications and Beta programs
Mindoro is a trading performance, behavioural awareness and execution intelligence platform. It provides analytical and educational tools and does not provide personalised financial advice or execute trades on your behalf.
2. International Users and Applicable Privacy Laws
Mindoro is operated from Australia and is intended to be accessible to traders in multiple countries.
This Privacy Policy applies to all Mindoro users, regardless of their country of residence.
We handle personal information in accordance with applicable Australian privacy laws and, where relevant, the data protection requirements of other jurisdictions in which we offer our services.
Depending on your location and applicable law, you may have additional rights relating to access, correction, deletion, restriction, objection or portability of your personal information.
You may contact efren@mindoro.com.au to enquire about or exercise applicable privacy rights.
Nothing in this Privacy Policy is intended to limit privacy rights that cannot lawfully be excluded.
3. Information We Collect
Depending on how you use Mindoro, we may collect:
Account and contact information: Name, email address, account credentials and preferences.
Trader profile information: Trading experience, trading style, account size, risk preferences, trading plans and behavioural challenges.
Trading information: Broker account details, imported trades, trading instruments, transaction dates, prices, position sizes, profit and loss, and related records.
Journal and coaching information: Personal trading notes, reflections, behavioural assessments, AI conversations, coaching actions and feedback.
Subscription information: Subscription status and payment-related records processed through Stripe.
Technical information: IP addresses, browser and device information, login activity, application logs and security-related records.
Website enquiries: Information submitted through our Contact, Beta Access and other website forms.
We collect information directly from you, through your use of Mindoro, or through broker connections and data imports that you authorise.
You may browse the public website without registering for a Mindoro account.
4. How We Use Your Information
We use information to:
Create and manage Mindoro accounts.
Import, organise and analyse trading histories.
Provide trade journals, performance analytics and behavioural insights.
Identify trading behaviour and execution patterns.
Deliver AI-assisted analysis and educational coaching.
Support authorised Human Coach interactions.
Manage subscriptions, payments and customer enquiries.
Maintain and improve application reliability and security.
Communicate important service updates.
Meet applicable legal and regulatory obligations.
5. Broker Connections and Trading Data
Mindoro supports trading-data imports and integrations with selected brokers and trading platforms.
When you authorise a connection or upload trading information, you permit Mindoro to receive and process the information required to provide its services.
Depending on the integration, this may include trading account identifiers, transaction histories, trading instruments, positions and related records.
You may disconnect supported broker integrations or remove certain imported data using available account-management features.
Disconnecting a broker does not necessarily remove trading information previously imported into Mindoro.
Third-party brokers and trading platforms operate under their own privacy policies and terms.
6. Artificial Intelligence and Automated Analysis
Mindoro uses artificial intelligence and rule-based analytics to provide trading performance insights, behavioural assessments and educational coaching.
AI Trading Psychology Coach
Routine AI coaching generally uses aggregated trading statistics, behavioural findings, performance indicators and trader profile information rather than complete individual trade histories.
Individual Trade Analysis
When you explicitly request AI analysis of a particular journal trade, Mindoro may send relevant trade details to the AI service, including instrument, direction, prices, position size, stop-loss and take-profit levels, and journal notes.
AI Conversations
When you interact with the AI Coach, your messages and relevant recent conversation context may be processed by an external AI service to generate responses.
Mindoro currently uses AI services through the Lovable AI Gateway. Processing may occur outside Australia, including in the United States and European Union.
The currently configured AI model is identified by the provider as supporting zero-data-retention processing. Mindoro may separately retain conversation histories and generated insights within its own application.
Mindoro has opted out of customer-data use for AI model training under its current Lovable configuration.
AI-generated assessments are informational and educational and may contain inaccuracies. They should not be treated as financial advice or guaranteed trading outcomes.
7. Human Coach Access
Mindoro allows you to authorise a Human Coach to access information associated with a selected trading account.
You control which supported account is shared and whether the coach receives read or comment permissions.
Depending on the permission granted, an authorised coach may view relevant trades, analytics, behavioural findings, trading plans and coaching information, and may provide notes or recommendations.
Suggested changes to applicable trader settings require your approval before taking effect.
You may revoke a coach's access through the Coach Access feature. Revocation prevents further authorised access but does not necessarily erase previously created coaching records.
8. Data Storage and International Processing
Mindoro's primary application database is hosted using Supabase infrastructure in the Sydney, Australia AWS region.
We use third-party providers to support our services, including:
Supabase: Database and authentication services.
Lovable: Application hosting and AI connectivity.
Cloudflare: Network delivery, performance and security.
Stripe: Payment processing and subscription management.
Supported broker and integration providers: Authorised trading-data connectivity.
Personal information may be processed or disclosed outside Australia, including in the United States and countries within the European Union, and through globally distributed infrastructure.
We take reasonable steps to manage privacy and security risks associated with third-party providers and international processing, as required by applicable law.
9. Disclosure of Personal Information
We may disclose personal information to:
Technology and infrastructure providers supporting Mindoro.
Payment processors for subscription and billing services.
AI providers when you use AI-assisted features.
Human Coaches whom you authorise.
Professional advisers and contractors where reasonably necessary.
Regulatory authorities or other parties where required or permitted by law.
We do not sell personal information to advertisers or data brokers.
We do not make private trading journals or account information publicly available through Mindoro.
10. Information Security
We use technical and organisational measures intended to protect personal information from unauthorised access, misuse, loss, modification and disclosure.
These include authenticated access, application permissions and security measures provided by our infrastructure partners.
Human Coach access is controlled through account-specific permissions.
Although we take reasonable precautions, no internet-based service or electronic storage system can guarantee absolute security.
You are responsible for keeping your account credentials confidential and notifying us if you suspect unauthorised access.
11. Data Retention, Account Closure and Deletion
We retain personal information for as long as reasonably necessary to provide Mindoro services, maintain appropriate business records, meet legal obligations and support legitimate security and operational requirements.
Trading histories, journal entries, AI conversations and coaching records do not currently have a single automatic expiry period.
You may request closure of your Mindoro account by contacting efren@mindoro.com.au.
Account closure and deletion of associated personal information are separate processes. We will review requests to remove personal information and take reasonable steps to delete or de-identify information that is no longer required, subject to applicable legal obligations.
Some information may remain in backups, audit records or other systems where retention is required or otherwise permitted by law.
You may contact us to request access to, correction of, or deletion of personal information associated with your account.
12. Cookies and Browser Storage
Mindoro uses essential authentication and functional browser storage to support account sessions, security and application preferences.
The Mindoro application currently does not use third-party advertising trackers or dedicated marketing analytics tools.
Our public website, payment pages and infrastructure providers may use cookies or related technologies necessary for their services and, where configured, other functionality.
You can manage cookies and browser storage through your browser settings, although disabling essential technologies may affect functionality.
13. Marketing Communications
If you register your interest in Mindoro, apply for Beta Access or subscribe to updates, we may contact you about your enquiry, application or relevant service developments.
Where required, we will obtain consent before sending promotional communications.
You can opt out of marketing communications using an unsubscribe facility where provided or by contacting us.
Essential service, account and security communications may still be sent when necessary.
14. Access, Correction and Privacy Rights
You may contact us to request access to personal information we hold about you, seek correction of inaccurate information or enquire about its handling, retention or deletion.
Depending on your location and applicable law, additional privacy rights may apply.
We may need to verify your identity before responding to a request.
We will consider requests in accordance with applicable privacy laws and explain any relevant limitations.
Privacy contact: efren@mindoro.com.au
15. Privacy Complaints
If you believe Mindoro has mishandled your personal information, please contact us at efren@mindoro.com.au.
We will review your complaint and seek to resolve it within a reasonable period.
If you are dissatisfied with our response, you may be entitled to contact the appropriate privacy authority in your jurisdiction.
16. Changes to This Policy
We may update this Privacy Policy to reflect changes in Mindoro's services, technology, business practices or legal obligations.
The latest version will be published on our website with an updated effective date.
Where appropriate, we will provide additional notice of material changes.
17. Contact Details
Pointwest Australia Pty Ltd
ACN 168 372 601
ABN 38 168 372 601
Trading as Mindoro
Website: https://mindoro.com.au
Application: https://mindoro.app
Email: efren@mindoro.com.au
Australia