[DATE]The data controller is [LEGAL NAME], Estonia. For any privacy question or request write to [EMAIL].
| Data | Why | Legal basis (GDPR) |
|---|---|---|
| Email address, password hash | To create an account and let you sign in | Art. 6(1)(b) — contract |
| Display name, rating (RP), colour | To show you in the rankings | Art. 6(1)(b) — contract |
| Training progress: virtual balance, trade journal, settings, knowledge-base progress | To keep your progress across devices | Art. 6(1)(b) — contract |
| Anonymised trade parameters (prices, times, direction) sent for the AI review | To generate the written review of your trade | Art. 6(1)(b) — contract |
| Subscription status and period | To give paid features to those who paid | Art. 6(1)(b) — contract |
| Product events: a random device identifier and which step was reached — page opened (with the class of the source: direct / search / social / other link, the class of device, and the interface language), app opened, signed up, signed in, first trade, every closed trade (class of market and whether the result was a plus or a minus), AI review requested, daily AI or practice limit reached, Pro window opened, Pro checkout started, a request to be notified about Pro. While you are signed in, an event also carries your account identifier — see section 6 | To see how many people come back and where they get stuck — the app is improved from these counts | Art. 6(1)(f) — legitimate interest |
| Pro waiting list: your account identifier, the date, and which plan you were looking at. No second copy of your email — it stays in your account | To send you one email on the day Pro opens, because you asked us to | Art. 6(1)(a) — consent, withdrawn at any time with “Leave the list” |
| Technical logs: IP address, browser, time of request | Security, abuse prevention, fault diagnosis | Art. 6(1)(f) — legitimate interest |
We do not collect real-money account data, identity documents, location or biometrics. We do not profile you for advertising.
Payments are handled by Lemon Squeezy. Card details never reach us — they go straight to the payment provider. We receive only the fact of payment, the plan, the period and an identifier that links the payment to your account. Invoices and tax documents are issued by the provider.
Some of these operate outside the EU. Where that happens, transfers rely on the European Commission's Standard Contractual Clauses or on an adequacy decision.
Settings, guest progress and knowledge-base progress live in your browser's localStorage. That is not a cookie and is sent nowhere unless you sign in. We use no advertising or analytics cookies. Clearing browser data removes this local copy; an account keeps the cloud copy.
We count a short, fixed list of product events — the full list is in the table in section 2, and adding to it takes a change to both the app and the database. Each event is recorded against a random identifier stored in your browser. While you are signed in, the event also carries your account identifier, so that the same person using two browsers is counted once rather than twice; that also means events recorded before and after you clear your browser data are joined back together through your account.
Nothing else in an event points at you: there is no free text, no prices, no amounts, no instrument beyond the class of market, and never an email address — nothing you type anywhere in the app is sent with it. Only aggregate counts are ever read out of this data; individual events are visible to no one but us, and the app itself cannot read them back. If your browser sends Do Not Track or Global Privacy Control, we record nothing at all, and you can object to this counting or ask for your events to be deleted — see section 8.
Under the GDPR you may: get a copy of your data, correct it, delete it, restrict or object to processing, and receive it in a portable format. Write to [EMAIL] — we answer within 30 days. You may also complain to the Estonian Data Protection Inspectorate (aki.ee).
Fastest route for deletion: write from the address the account is registered to and ask for it to be deleted.
The Service is for people 18 and older. We do not knowingly collect data from children. If such data reaches us, we delete it.
Access is restricted at the database level (row-level security: an account sees only its own rows). Traffic is encrypted (HTTPS). Passwords are stored hashed by the authentication provider and are not visible to us.
This policy may be updated; the current version always lives on this page with its date. Material changes are announced inside the Service.