Privacy Policy

Version 1.0 — last updated: 21 July 2026

Please note: This version 1.0 was drafted by the platform owner and has not yet been formally reviewed by a specialist legal adviser. A targeted legal review is planned once budget is available; version 2.0 will follow that review.

1. Who we are

HoneyBadger Trader is a service operated by sole proprietorship Agile Halewyn, registered at Middenburcht 27, 3452MS Vleuten, the Netherlands, registered with the Chamber of Commerce under number 90024559 (establishment number 000055776876). We are responsible for processing personal data as described in this Privacy Policy. Trading names: Agile Halewyn, HoneyBadger Trader and HoneyBadger Bots.

2. What data we collect

We collect the following data:

Account data: name and email address upon registration
Waitlist: name, email address and crypto experience
Contact form: name, email address, subject and message
Technical data: IP address and browser type (anonymised via Cloudflare Web Analytics)
Trading data: API key (stored encrypted) and trades executed by the bots

3. How we use your data

Providing our service (automated trading)
Displaying your trading results in the dashboard
Informing you about the status of your early access registration
Improving our service (anonymised analytics)

4. How long we retain your data

Waitlist data: up to 12 months after registration
Account data: until you delete your account
Trading data (including data linked to invoicing): 7 years after the transaction, pursuant to Dutch tax retention obligations (Section 52 of the General Tax Act). After that period, this data will be deleted unless a longer statutory retention period applies.

5. Who we share your data with

We do not share your data with third parties, except:

Bitvavo: trade orders are executed on your Bitvavo account via the API key you provide
Netlify: hosting of the public website; for the contact form and, temporarily, for early access / waitlist registrations, Netlify processes submitted form data as a processor in the course of its service provision (EU/US processor structure as described by Netlify). A data processing agreement with Netlify can be entered into via the Netlify account (Compliance / Data Processing Agreement). Once waitlist registrations run via our own API, that data will be delivered directly to our platform.
Cloudflare: Cloudflare processes anonymised pageview statistics via Cloudflare Web Analytics (JS beacon; no cookies) as a processor. A data processing agreement with Cloudflare can be established via the Cloudflare account.
Own platform (API): once the waitlist runs on our server: registrations sent directly to our API; processing and storage on our platform (Hetzner EU)
Hosting provider: Hetzner (Germany, EU) for hosting our platform
Legal obligation: where we are legally required to do so

6. Security

We take appropriate technical and organisational measures to protect your data, including encrypted storage of API keys and HTTPS connections.

7. Your rights

Under the GDPR, you have the following rights:

Right of access to your data
Right to rectification of inaccurate data
Right to erasure of your data
Right to restriction of processing
Right to data portability
Right to object to processing

8. Cookies

We use Cloudflare Web Analytics, a cookieless analytics platform. No tracking cookies are placed. See also our Cookie Policy.

9. Changes

We may amend this Privacy Policy. The latest version will always be available on this page.

10. Contact

Questions about this Privacy Policy? Contact us at privacy@honeybadgertrader.com.