1. Who We Are

XetraGroup ("we," "us," or "our") is a software-as-a-service provider specializing in algorithmic trading software for FX and Futures markets. We are committed to protecting your personal data and respecting your privacy rights in accordance with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and all applicable local data protection laws.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services. By accessing our website, you agree to the terms of this Privacy Policy.

2. Information We Collect

Information You Provide Directly

• Name and surname when you submit a consultation form
• Email address for communication purposes
• Country of residence to comply with regional regulations
• Trading experience level and goals provided in forms
• Preferred contact method (email or WhatsApp)
• Any additional information you voluntarily provide

Information Collected Automatically

• IP address and approximate geographic location
• Browser type, version, and operating system
• Pages visited, time spent, and navigation patterns
• Referral sources (e.g., Google, YouTube, LinkedIn)
• Device type and screen resolution

Payment Information

Payment processing is handled entirely by Stripe, a PCI-DSS compliant third-party processor. XetraGroup does not collect, store, or process any payment card data directly. Stripe's privacy policy governs the handling of your payment information.

3. How We Use Your Information

We use the collected information for the following purposes:

• To respond to consultation requests and inquiries submitted via our forms
• To deliver purchased software licenses and onboarding assistance
• To provide customer support and technical assistance
• To send transactional communications related to your purchase
• To improve our website functionality and user experience
• To comply with legal obligations and prevent fraudulent activity
• To analyze usage patterns and optimize our marketing efforts

We will never sell, rent, or lease your personal data to third parties for their own marketing purposes.

4. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your experience. These include:

Essential Cookies

Required for basic website functionality. These cannot be disabled as they are necessary for the site to operate correctly.

Analytics Cookies

We may use tools such as Google Analytics to understand how users interact with our website. This data is aggregated and anonymized where possible. You may opt out of analytics tracking via your browser settings or Google's opt-out tool.

Marketing Cookies

When you interact with embedded content or links from third-party platforms (e.g., YouTube, LinkedIn), those platforms may set their own cookies governed by their respective privacy policies.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect website functionality.

5. Data Sharing and Third Parties

We may share your information with trusted third-party service providers who assist in operating our business, under strict confidentiality obligations:

• Formspree — for processing consultation form submissions
• Stripe — for secure payment processing
• Calendly — for scheduling consultations
• Google Analytics — for website usage analytics (anonymized)

We may also disclose information if required by law, court order, or government authority, or to protect the rights, property, or safety of XetraGroup or its users.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by applicable law. Consultation inquiry data is retained for up to 2 years. Purchase and transactional data may be retained for up to 7 years for accounting and legal compliance purposes.

7. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access — Request a copy of the personal data we hold about you
• Right to Rectification — Request correction of inaccurate or incomplete data
• Right to Erasure — Request deletion of your personal data ("right to be forgotten")
• Right to Object — Object to processing of your data for marketing or profiling
• Right to Portability — Receive your data in a structured, machine-readable format
• Right to Withdraw Consent — Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at the email address listed in Section 10.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption, access controls, and secure third-party processors. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

9. International Transfers

Your data may be processed in countries outside your jurisdiction, including the United States and European Union member states. Where applicable, we ensure such transfers are subject to appropriate safeguards such as Standard Contractual Clauses (SCCs) as approved by the European Commission.

10. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact us:

⚠ Critical Warning

1. General Risk Disclosure

XetraGroup provides algorithmic trading software as a technology service. We are not a financial adviser, investment manager, or broker. Our software automates trading strategies on your behalf using your own brokerage accounts, but all financial risk is borne entirely by you, the user.

Past performance data — including verified Myfxbook statistics — is provided for informational purposes only and does not constitute a guarantee, promise, or reasonable expectation of future performance. Markets are dynamic and past results may not be replicated in future conditions.

2. Market Risk

Financial markets are subject to continuous and unpredictable fluctuations driven by economic data, geopolitical events, central bank decisions, and mass market sentiment. Key market risks include:

• Price Volatility — Prices can move rapidly and significantly in short periods, including gaps overnight or across weekends that may result in slippage beyond stop-loss levels
• Liquidity Risk — In certain market conditions, it may be impossible to execute trades at desired prices, resulting in losses larger than anticipated
• Gap Risk — Markets may open at prices significantly different from where they closed, particularly after weekends or major news events, bypassing stop-loss orders
• Correlation Risk — Simultaneous adverse moves across multiple positions can compound losses rapidly

3. Leverage Risk

Many FX and Futures instruments involve the use of leverage, which amplifies both profits and losses. For example, with 10:1 leverage, a 10% adverse price movement results in a 100% loss of your invested capital. You should carefully consider your risk tolerance and never use leverage you do not fully understand.

4. Technology Risk

Automated trading systems depend on technology infrastructure that is inherently subject to failure. Technology risks include:

• Software Failures — Bugs, errors, or unexpected behavior in the algorithm may cause incorrect trade execution or failure to execute at all
• Internet Connectivity — Loss of internet connection may prevent trade execution or result in open positions that cannot be managed
• VPS/Server Downtime — The virtual private server hosting your algorithm may experience downtime, interrupting automated trading
• Broker Platform Issues — Broker-side outages, platform crashes, or API interruptions may prevent timely order execution
• Data Feed Errors — Incorrect or delayed market data may cause the algorithm to make suboptimal trading decisions

5. Drawdown Risk

All trading strategies experience periods of drawdown — a decline in account equity from a peak to a trough before recovering. Even strategies with excellent long-term performance records experience significant drawdown periods. You must be psychologically and financially prepared to withstand extended drawdown periods without withdrawing capital or deviating from the strategy.

Historical drawdown figures (e.g., 6.06% max drawdown for Xxe-Quant FX) reflect past conditions and do not guarantee that future drawdowns will be limited to the same levels.

6. Regulatory Risk

Regulatory frameworks governing FX and Futures trading vary significantly by jurisdiction and may change over time. Changes in regulations may affect the availability of certain trading instruments, leverage limits, or the ability to operate algorithmic trading systems. You are responsible for ensuring that your use of our software complies with the laws and regulations applicable in your jurisdiction.

7. Disclaimer of Liability

XetraGroup, its founders, employees, affiliates, and partners accept no liability for any trading losses, financial losses, or consequential damages arising from the use of our software. By using XetraGroup's products, you acknowledge that:

• You have read and understood this Risk Disclosure in its entirety
• You are solely responsible for all trading decisions and outcomes
• You will only trade with capital you can afford to lose completely
• XetraGroup is a technology provider and not a regulated financial adviser
• Past performance does not guarantee future results under any circumstances

1. Introduction to AI-Specific Risks

XetraGroup's trading algorithms incorporate artificial intelligence and machine learning components designed to identify market patterns and execute trades. While these technologies provide significant advantages, they also introduce a unique set of risks that are distinct from those of conventional rule-based trading systems. This document describes those risks in full.

We believe in complete transparency. Understanding these limitations is essential for every user of our products, regardless of experience level.

2. Model Limitations and Overfitting

AI trading models are developed and optimized using historical market data. This process, while rigorous, introduces the following risks:

• Overfitting — A model trained too closely on historical data may perform well on past data but fail to generalize to new, unseen market conditions. We mitigate this through out-of-sample testing, but no model is immune
• Regime Change — Markets periodically shift between fundamentally different behavioral regimes (e.g., trending vs. ranging, high vs. low volatility). AI models trained in one regime may underperform or fail in another
• Non-Stationarity — Financial markets are non-stationary, meaning statistical properties change over time. A model optimized for conditions in 2022-2024 may not perform identically in 2025-2027

3. AI Hallucinations and Errors

AI systems can produce incorrect outputs — a phenomenon known as "hallucination" — even when presenting results with apparent confidence. In the context of trading algorithms:

• The algorithm may misinterpret market signals and generate incorrect trade signals
• Confidence scores generated by the AI may not accurately reflect actual probability of success
• Edge cases or black swan events that were not present in training data may cause unexpected algorithmic behavior
• AI decision-making processes are not always fully interpretable, even by the developers

4. Technological Dependency

The performance of AI-powered trading systems is fundamentally dependent on continuous and reliable access to technology infrastructure:

• Internet Connectivity — Loss of connection interrupts data feeds and order execution
• Latency Sensitivity — High-frequency components require ultra-low latency. Network congestion can degrade performance significantly
• Third-Party Platforms — Our algorithms rely on MetaTrader 4/5 and NinjaTrader 8, which are subject to their own maintenance, bugs, and version updates
• Broker Infrastructure — Execution quality depends on your broker's servers, which may experience downtime, requotes, or slippage

5. Data Quality and Feed Risks

AI trading decisions are only as good as the data feeding them. Data-related risks include:

• Stale or delayed price quotes due to broker connectivity issues
• Incorrect tick data causing erroneous indicator calculations
• Missing data points during market closures or broker maintenance windows
• Price manipulation or unusual market activity causing anomalous data spikes

6. Continuous Evolution of Markets

Financial markets evolve continuously as new participants enter, regulatory frameworks change, and macroeconomic conditions shift. An AI model that performs well today may degrade over time as market dynamics change. XetraGroup commits to ongoing model monitoring and periodic recalibration, but there will always be a lag between market changes and model adaptation. During such transition periods, performance may temporarily decline.

7. User Responsibility

Users of XetraGroup's AI-powered algorithms accept full responsibility for:

• Monitoring algorithm performance and connectivity regularly
• Setting appropriate risk parameters within the software
• Understanding the markets and instruments being traded
• Having contingency plans for manual intervention when needed
• Not over-allocating capital beyond their personal risk tolerance