Privacy Policy

Effective date: April 21, 2026
Last updated: May 16, 2026

This Privacy Policy explains how Raymond Denis ("I," "me," or "my") collects, uses, stores, and discloses information when you use the Swing application and the website located at https://swing.raydenis.co (collectively, the "Service").

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Service.

1. Who I Am

Raymond Denis is an individual sole proprietor based in New York, operating the Service as a personal trading automation tool. I am not a registered investment adviser, broker-dealer, or financial institution. The Service is not available to the general public; access is restricted to Raymond Denis and any additional individuals I explicitly authorize.

Contact:
Raymond Denis
228 Park Avenue S, Suite 35600
New York, NY 10003
Email: info@raydenis.co

2. Information I Collect

I collect the following categories of information:

Account information. When you create an account, I collect your name, email address, and mobile phone number. Authentication is handled through my identity provider, Clerk, which may collect additional authentication data as described in its privacy policy.

Mobile phone number and SMS data. If you opt in to SMS notifications, I collect and store your mobile phone number, your opt-in timestamp, your consent record, and metadata about messages sent to you (delivery status, timestamp, message category). I do not collect the content of any messages you send to the Service beyond recognized command keywords such as STOP, UNSTOP, and HELP.

Brokerage and trading information. To operate the Service, the Service accesses your Charles Schwab brokerage account through Schwab's official Trader API using OAuth 2.0. I store OAuth tokens, account identifiers (hashed), positions, order history, and trade activity generated by the Service. I do not store your Schwab account password.

Market and strategy data. I collect and store the market signals, indicator values, option chain data, and trade decisions generated by the Service.

Technical information. Server logs, IP addresses, device identifiers, browser type, and timestamps of requests made to the Service.

Communications with me. Any email, SMS, or other correspondence you send to me.

3. How I Use Information

I use the information I collect to:

  • Operate, maintain, and secure the Service;
  • Authenticate you and manage your account;
  • Detect trading signals and execute trades you approve through the Service;
  • Send SMS notifications related to trade approvals, trade executions, position alerts, and system status (only if you have opted in);
  • Send transactional email related to account security, reauthorization deadlines, and system status;
  • Maintain audit logs required for tax reporting and regulatory recordkeeping;
  • Investigate and prevent fraud, abuse, and security incidents;
  • Comply with legal obligations.

4. SMS Messaging Program

4.1 Program description

The Service sends SMS messages to the mobile phone number you provide for the following purposes only:

  • Trade approval requests when the Service detects a qualified trading setup;
  • Trade execution confirmations;
  • Position status alerts (stop-loss triggered, target hit, time-based exit);
  • System status alerts (broker reauthorization required, service disruption);
  • Account security alerts.

The Service does not send marketing, promotional, or advertising SMS messages.

4.2 Opt-in

SMS messaging is strictly opt-in. You enroll by completing the public opt-in form at https://swing.raydenis.co/sms: providing your mobile phone number and affirmatively ticking two separate, unchecked-by-default checkboxes — one for agreement to the Terms of Service and Privacy Policy, and a second, standalone checkbox confirming your consent to receive automated SMS alerts at the entered number. Both must be checked before the form will submit; SMS consent is collected independently of Terms/Privacy acceptance, not bundled with it. Your separate SMS consent, the consent text version you saw, and the timestamp are recorded server-side and retained for the duration of your account and for a minimum of ten (10) years thereafter (aligned with §6 below).

4.3 Message frequency

Message frequency varies based on market conditions and your open positions. Typical usage is zero (0) to ten (10) messages per trading day. There is no upper limit; however, the Service is designed to send messages only when actionable information is available.

4.4 Message and data rates

Message and data rates may apply based on your mobile carrier plan. I am not responsible for any charges from your mobile carrier.

4.5 Opt-out

You may opt out of SMS messages at any time by replying STOP (or any of STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, OPTOUT, or REVOKE) to any SMS message from the Service. You will receive one final confirmation message, after which no further SMS messages will be sent to your mobile number. You may also opt out by emailing info@raydenis.co.

To resume SMS messages after opting out, reply START or UNSTOP to the last message received.

4.6 Help

For help with the SMS program, reply HELP to any SMS message from the Service, or contact info@raydenis.co.

4.7 Supported carriers

The SMS program supports all major U.S. mobile carriers including AT&T, Verizon, T-Mobile, and their affiliates. Carriers are not liable for delayed or undelivered messages.

4.8 No sharing of SMS consent or mobile data for marketing

I do not share, sell, rent, or otherwise disclose mobile phone numbers, SMS opt-in data, or SMS message content to any third parties or affiliates for marketing or promotional purposes. This prohibition applies to all such data, including phone numbers collected through the Service. This information is used solely to deliver SMS messages you have consented to receive through the Service.

5. How I Share Information

I share information only in the following limited circumstances:

Service providers. I share information with vendors that operate components of the Service, strictly as necessary for them to perform their functions. These include:

  • Clerk (authentication and user identity)
  • Knock (notification orchestration for SMS, email, and in-app alerts)
  • Twilio or an equivalent SMS delivery provider (as contracted by Knock) for the transmission of SMS messages
  • Charles Schwab (brokerage operations; access is authorized by you via OAuth)
  • Neon (database hosting), Upstash (cache and queue hosting), Vercel and Railway (application hosting)

Each of these providers is contractually bound to use information only to perform services for me and is subject to their own privacy commitments.

Legal and safety. I may disclose information if I believe in good faith that disclosure is required to comply with a legal obligation, respond to a valid legal process, protect the rights, property, or safety of the Service or others, or prevent fraud or abuse.

Business transfers. If the Service is acquired, merged, or transferred, information may be transferred as part of that transaction, subject to this Privacy Policy.

I do not sell personal information. I do not share mobile phone numbers, SMS opt-in data, or any customer data with third parties for their marketing or advertising purposes.

6. Data Retention

I retain information for as long as necessary to operate the Service and to comply with legal, tax, and regulatory obligations:

  • Account and trading records: minimum seven (7) years after account closure, consistent with IRS and SEC recordkeeping guidance.
  • SMS opt-in and opt-out records: minimum ten (10) years, consistent with TCPA and state-law guidance.
  • Server logs: up to ninety (90) days, unless required for investigation of a security incident.
  • Broker OAuth tokens: retained only while the account is active; refreshed or discarded per Schwab's token lifecycle.

7. Security

I protect information using industry-standard safeguards including TLS encryption in transit, encryption at rest for sensitive data, OAuth 2.0 for brokerage authentication, role-based access controls, and audit logging. No system is perfectly secure. If I become aware of a security incident affecting your information, I will notify you as required by applicable law.

8. Your Rights

Depending on your state of residence, you may have rights to:

  • Access the personal information I hold about you;
  • Request correction of inaccurate information;
  • Request deletion of your information, subject to my retention obligations;
  • Opt out of SMS messages (see Section 4.5);
  • Withdraw consent for data processing where consent is the legal basis.

To exercise any of these rights, contact info@raydenis.co. I will respond within the timeframe required by applicable law.

New York residents: You have rights under the New York SHIELD Act regarding the protection of your personal information.

California residents: You have rights under the California Consumer Privacy Act (CCPA) including the right to know, delete, and correct. I do not sell personal information and do not share it for cross-context behavioral advertising.

Virginia, Colorado, Connecticut, Utah, and other state residents: You have rights under your state's consumer privacy laws analogous to those described above.

9. Children

The Service is not directed to children under 18, and I do not knowingly collect information from children. If you believe a child has provided information to the Service, contact info@raydenis.co and I will delete it.

10. International Users

The Service is operated in the United States and is intended for U.S. users only. If you access the Service from outside the United States, you acknowledge that your information will be processed in the United States.

11. Changes to This Policy

I may update this Privacy Policy from time to time. When I make material changes, I will post the updated policy at https://swing.raydenis.co/privacy and update the "Last updated" date. Continued use of the Service after changes are posted constitutes acceptance of the updated policy.

12. Contact

Questions, complaints, or requests regarding this Privacy Policy or the SMS program may be directed to:

Raymond Denis
228 Park Avenue S, Suite 35600
New York, NY 10003
Email: info@raydenis.co