Privacy Policy
Last Updated: 6.8.26
Effective: 6.8.26

1. Who we are and what this covers
Prosperity School is operated by Prosperity Group FZCO, a company registered in the United Arab Emirates at IFZA, Business Park, Dubai Silicon Oasis, Dubai, UAE (License No. 33208-001 DDP) ("Prosperity," "we," "us," or "our"). We are the controller of the personal data described in this policy.

This policy explains how we collect, use, share, and protect personal data across everything we operate, including:

The website at https://www.prosperityschool.com and any funnel, landing, or checkout page we host
SMC Engine and our other trading indicators, including the access we grant on TradingView
The Inner Edge, Prosperity School, and any other course or curriculum we sell
Live Trading Floor subscriptions, the live sessions themselves, and their recordings
OrthosLabs and its associated products
Our member community spaces
Any software platform, trading journal, or AI tool we make available
Our marketing and customer contact — email, SMS, WhatsApp, and, historically, booked and recorded calls
Advertising and content we publish on third-party platforms
It applies to customers and subscribers, community members, people who opt in to a free resource or an email list, and visitors — whether or not you ever buy anything from us.

We process personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and its Executive Regulations as issued. Where the EU or UK GDPR applies to you, see §12. Where California law applies to you, see §13.

2. What we collect
You give us directly:

Name, email address, phone number, and country
Your TradingView username, where you buy an indicator product — we need it to grant you access
Payment and billing information — see §3 for how this is handled
Application, survey, and form responses you submit to us
Messages you send us by email, SMS, WhatsApp, community message, or support request
Anything you post in a community space, including your profile and your contributions
Information you told us on a sales or onboarding call, where you had one with us in the past
We collect automatically:

IP address, approximate location, device and browser type, and operating system
Pages viewed, referring URL, time on page, clicks, and how you moved through our funnels and checkouts
Advertising and campaign identifiers that tell us which ad, video, post, or link brought you to us
Cookie and local-storage identifiers, and equivalent identifiers collected server-side (see §14)
We generate:

Your subscription and billing history, including renewals, failed payments, cancellations, and refunds
Recordings of live trading sessions, which may capture your voice, camera, name, or chat messages if you take part (see §5)
Recordings and transcripts of past sales and onboarding calls, where you had one with us (see §5)
Notes, lead status, engagement records, and our internal record of our dealings with you
Usage data from any software, platform, or trading journal we provide
We receive from third parties:

Transaction, subscription, renewal, refund, and chargeback data from our payment providers
Advertising and attribution data from advertising and analytics platforms
Aggregate engagement data from the social platforms where we publish content
We do not intentionally collect government ID numbers, health data, biometric data, religious or political affiliation, or any other special-category data. Please do not send it to us. If it reaches us anyway, we delete it when we identify it.

3. Payments and subscriptions
We do not store your full card number. Card and bank details are collected and processed directly by our payment providers, who are responsible for that data under their own privacy policies and under PCI DSS. We currently use Whop and ThriveCart for checkout, and offer third-party financing through Klarna on some purchases. These providers may change over time.

From them we receive only what we need to fulfil and support your purchase: your name, email, what you bought, the amount, the date, and the payment status.

Some of our products are recurring subscriptions. Where you subscribe, we and our payment providers process your data on an ongoing basis to take payment on each billing cycle, to tell you about renewals, failed payments, and price changes, to give you access for as long as your subscription is active, and to remove access when it ends. You can cancel at any time through your account with the relevant provider or by contacting us, and we keep a record of your subscription history afterwards as described in §10.

If you take financing, you enter a separate agreement with the financing provider, and they become an independent controller of your data.

4. How we use your data
We use it to Examples
Deliver what you bought Grant course, community, and TradingView indicator access; run live sessions; provide support
Run your subscription Take recurring payment; notify you of renewals and failed payments; manage cancellation and access
Take payment Process orders, refunds, and chargebacks; detect payment fraud
Sell to you Contact you about products you enquired about; send abandoned-checkout reminders; follow up on an incomplete purchase
Market to you Send email, SMS, and WhatsApp marketing where you have opted in or where we are otherwise permitted; build audiences for advertising
Measure and attribute Understand which ad, video, or piece of content produced a lead or a sale, and what our advertising returns
Improve Analyse how our funnels, content, courses, and products perform, and improve them
Run the business Accounting, tax, audit, reporting, and record-keeping
Stay safe and lawful Prevent fraud and abuse, enforce our Terms, establish or defend legal claims, comply with UAE law and lawful requests
We do not use your data to make solely automated decisions that produce legal or similarly significant effects on you.

5. Recordings
We no longer sell by phone or video call. Our products are bought through self-service checkout. We do not book, run, or record sales calls, and you never need to speak to anyone to buy from us.

Live trading sessions are recorded. Live Trading Floor sessions are recorded and the recordings are made available to members, including members who could not attend live. If you speak, appear on camera, or post in the chat during a session, that will form part of the recording. If you would rather not appear in a recording, attend with your camera and microphone off and do not post in the chat.

If you had a sales or onboarding call with us in the past, it was recorded. Until 2026, prospective customers could book a call with our team. Those calls were recorded and transcribed automatically, and stored in our systems. We used them to keep a record of what was discussed, to follow up, to coach our team, and to review our sales process — including with AI tools (see §6). We disclose this because those recordings still exist, even though we no longer create new ones.

You can ask us to delete a recording of you — a past call, or your participation in a live session — using the contact details in §16. See §10 for how long we otherwise keep them.

6. Artificial intelligence
We use AI tools in parts of our business, and some of them process personal data:

Message drafting. Some replies to enquiries and abandoned checkouts are drafted with AI assistance. A person is accountable for what is sent.
Products. Where we offer AI coaching, strategy, or journalling tools, what you enter into them is processed to produce your response.
Historical call analysis. Transcripts of past sales calls have been analysed by AI to summarise conversations and identify patterns in how those calls were handled.
When we use a third-party AI provider, your data is transferred to that provider as a processor under contract. We contract on the basis that our AI providers do not use your data to train their models.

A person, not a model, makes any decision that materially affects you.

7. Our lawful bases
Under the PDPL, and under the GDPR where it applies (§12), we rely on:

Basis Where we rely on it
Performance of a contract Delivering products, granting access, running your subscription, taking payment, providing support
Consent Marketing email, SMS and WhatsApp where required; non-essential cookies and advertising tracking
Legitimate interests Following up with people who enquired; measurement and attribution; product and process improvement; fraud prevention; securing our systems. We balance these against your rights, and you can object at any time (§11)
Legal obligation Tax, accounting and audit records; responding to lawful requests from authorities
Establishing or defending legal claims Retaining records of what was agreed with you
You can withdraw consent at any time. Withdrawing consent does not affect processing that already happened.

8. Who we share it with
We share personal data with service providers who process it on our behalf, under contract, and only for the purposes above. We do not sell your personal data.

Function Providers
Payments, checkout and subscriptions Whop, ThriveCart, Klarna
Customer and contact records Close
Email and SMS marketing Klaviyo
Community Skool
Indicator access TradingView
WhatsApp messaging Timelines AI
Forms and surveys Typeform
Funnels and website ClickFunnels
Attribution and analytics Hyros, Stape.io, Google Analytics
Advertising Meta
Data storage and infrastructure Supabase, Vercel, and our own self-hosted systems
AI processing Third-party AI providers, as described in §6
Historical call booking and recording (no longer in use) iClosed, Fathom
We also share data:

With advertising platforms, to build and match audiences and to measure conversions. Under California law this counts as "sharing" for cross-context behavioural advertising — see §13.
With professional advisers — lawyers, accountants, auditors — where needed.
With authorities, where required by UAE law or a valid legal request, or to protect our rights, our users, or the public.
On a business transfer — if Prosperity Group FZCO is merged, acquired, restructured, or sells assets, personal data may transfer as part of that, and this policy continues to apply until you are told otherwise.
With your consent, for anything else.
9. Security and breaches
We take reasonable technical and organisational measures to protect personal data, including encryption in transit, access controls and least-privilege access to our systems, and vetting of the providers we use.

No system is completely secure, and we cannot guarantee absolute security.

If a personal data breach occurs, we will notify the UAE Data Office without undue delay as required by the PDPL, and we will notify you directly where the breach is likely to prejudice your privacy, the confidentiality of your data, or its security. Where the GDPR applies, we will meet its 72-hour notification requirement.

If you believe you have found a security problem, contact us immediately at support@prosperityschool.com.

10. How long we keep it
Data Retention
Customer and subscriber account, access, and purchase records For as long as your access or subscription is active, then 5 years
Financial and tax records 5 years from the end of the relevant tax period, as required by UAE tax and commercial law
Live session recordings For as long as the recording forms part of the product
Past sales and onboarding call recordings and transcripts No longer being created. Retained only while we have a legitimate interest in them, and deleted on request
Lead and prospect records with no purchase For as long as we have a legitimate interest in contacting you, and deleted on request
Marketing contact records Until you unsubscribe, after which we keep a suppression record indefinitely so that we do not contact you again
Website analytics and advertising identifiers Per each provider's retention settings, typically 14–26 months
Records needed for a legal claim Until the claim and any appeal period ends
Where we no longer need data for the purpose we collected it, we delete it or irreversibly anonymise it.

11. Your rights
Whoever and wherever you are, you can ask us to:

Access — give you a copy of the personal data we hold about you
Correct — fix anything inaccurate or incomplete
Delete — erase your data, where we are not required to keep it
Restrict — pause processing while a dispute is resolved
Object — stop processing we base on legitimate interests, including profiling
Port — receive your data in a structured, machine-readable format, or have it sent to another controller
Opt out of marketing — at any time, on any channel
Withdraw consent — where we relied on it
To exercise any of these, email support@prosperityschool.com. We will acknowledge within 5 business days and respond substantively within 30 days. If a request is complex we may extend that, and we will tell you why before the 30 days are up.

We may need to verify your identity before we act, and we will not charge you unless a request is manifestly unfounded or excessive.

To stop marketing specifically, you can also use the unsubscribe link in any marketing email, reply STOP to a marketing SMS, or ask us to stop on WhatsApp. We will still send you messages about things you have bought and about any active subscription.

To complain, contact us first — we would rather fix it. You also have the right to complain to the UAE Data Office, or, if you are in the EEA or UK, to your local supervisory authority.

12. International transfers, and if you are in the EEA or UK
Where your data goes. Prosperity Group FZCO is established in the UAE, but the providers we rely on to run the business are largely based in the United States and the European Union. Your personal data will therefore be transferred outside the UAE and processed in those countries.

We rely on the transfer mechanisms permitted by the PDPL: transfers to jurisdictions with an adequate level of protection, and, where that does not apply, contractual safeguards with the receiving party, or the specific exemptions the PDPL provides — including where a transfer is necessary in order to perform a contract with you.

If you are in the EEA or UK, the EU or UK GDPR may apply to our processing of your data, because we offer products and services to you and monitor your behaviour through our advertising and analytics. Where it does:

Our lawful bases are set out in §7
You have the rights set out in §11, which are your GDPR rights
Transfers of your data outside the EEA or UK are made under the European Commission's Standard Contractual Clauses, and the UK Addendum or UK IDTA where relevant, with supplementary measures where needed
You can lodge a complaint with your national supervisory authority, or with the UK Information Commissioner's Office
13. If you are in California
We do not sell personal information for money. However, our use of advertising and analytics providers (§8) may constitute "sharing" personal information for cross-context behavioural advertising under the California Consumer Privacy Act as amended by the CPRA.

You have the right to know, delete, and correct your personal information, and to opt out of that sharing. We will not discriminate against you for exercising those rights.

To opt out of sharing, email support@prosperityschool.com with the subject line "Do Not Share My Personal Information," or use the opt-out link in our website footer where available.

We do not knowingly sell or share the personal information of anyone under 16.

14. Cookies, tracking, and server-side collection
We use cookies, pixels, local storage, and server-side tracking to run the website, remember your progress through a funnel or checkout, measure our advertising, and attribute leads and sales to the content or ad that produced them.

Server-side tracking means some of this data is collected by our own server and forwarded to analytics and advertising providers, rather than being sent from your browser directly. It serves the same purposes as browser cookies. We disclose it here because browser-level controls do not always block it.

Essential cookies keep the site, your login, and the checkout working, and cannot be turned off. Analytics and advertising cookies and identifiers are non-essential.

You can control cookies through your browser settings, though disabling them may break parts of the site. Because browser controls do not affect server-side collection, you can also email support@prosperityschool.com to ask us to stop analytics and advertising tracking associated with you, and we will action it.

Our Cookie Policy describes the specific categories of cookie we use and the third parties involved.

15. Age
Our products are for adults aged 18 and over. We do not offer them to, and do not knowingly collect personal data from, anyone under 18.

If we learn that we hold personal data from someone under 18, we will delete it and cancel any access. If you believe a minor has given us their data, contact support@prosperityschool.com and we will act promptly.

16. Contact us
For any privacy question, or to exercise your rights:

Email: support@prosperityschool.com
Post: Prosperity Group FZCO, No 33208-001 DDP, IFZA, Business Park, Dubai Silicon Oasis, Dubai, United Arab Emirates

We acknowledge within 5 business days and respond substantively within 30 days.

17. Changes to this policy
We update this policy when our products, providers, or legal obligations change. The current version is always posted here with its "Last Updated" date.

If we make a material change — a new purpose, a new category of data, or a change that reduces your rights — we will tell you by email or by a prominent notice on our website at least 30 days before it takes effect.

Your continued use of our products after a change takes effect means you accept the updated policy. Where a change requires your consent, we will ask for it rather than assume it.

This Privacy Policy should be read alongside our Terms of Service, Refund and Cancellation Policy, Cookie Policy, and End User Licence Agreement.