PRIVACY POLICY

TradeLogic — Trading Journal
Last updated: April 17, 2026

1. Data Controller

The controller of your personal data (the entity deciding on the purposes and means of processing) is the application Operator:

STREFA OXYGEN SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
ul. Zielonogórska 31/54, 41-218 Sosnowiec, Poland
Tax ID (NIP): 6443564590 | REGON: 520938057 | KRS: 0000945099
Email: tradelogic.kontakt@gmail.com

Additional information: The owner of the economic copyrights to the TradeLogic application is Paweł Kalicki (Sosnowiec, Poland). The Operator provides the Service under a license agreement. The Rights Holder does not have access to Users' personal data and does not process such data for any purpose.

2. Data We Collect

When you use the TradeLogic application, we collect the following data:

Account data: first name, last name, email address, password (stored in encrypted form)
Trading data: transaction records entered by you (instruments, P/L, dates, screenshots)
Profile data: trading style, experience level, financial goals (provided during onboarding)
Technical data: IP address, browser type, operating system, device identifiers
Usage data: activity logs, feature interactions, session duration
Push notification tokens: if you opt in to receive push notifications

3. Purpose and Legal Basis for Processing

We process your data for the following purposes:

Providing and maintaining the TradeLogic service — legal basis: performance of a contract (Art. 6(1)(b) GDPR)
Managing your account and PRO subscription — legal basis: performance of a contract (Art. 6(1)(b) GDPR)
Sending service-related email notifications — legal basis: performance of a contract (Art. 6(1)(b) GDPR)
Sending push notifications (only with your explicit consent) — legal basis: consent (Art. 6(1)(a) GDPR)
Fulfilling legal obligations (e.g., tax requirements) — legal basis: legal obligation (Art. 6(1)(c) GDPR)
Ensuring security and analyzing errors — legal basis: legitimate interest (Art. 6(1)(f) GDPR)

4. Data Retention

Account and trading data: deleted immediately (within 24 hours) after account deletion by the user or administrator
Inactive accounts: automatically deleted after 24 months of inactivity (with a warning email sent 30 days before deletion)
Billing data (invoices): 5 years in accordance with accounting and tax regulations
Deletion audit log (GDPR Art. 30): anonymized data (deletion date, record counts, deletion type) retained for 3 years to demonstrate GDPR compliance
Technical and security logs: 12 months
Backups: removed with backup rotation (up to 30 days)

4a. Inactive Accounts

To protect your data and comply with the data minimization principle (Art. 5 GDPR), we automatically delete accounts that are no longer in use:

After 23 months of inactivity, we send a warning email about the upcoming deletion
After 24 months of inactivity, the account and all associated data are deleted
Each login resets the inactivity counter
You can download a copy of your data at any time from the Settings page

5. Data Sharing

Your data may be shared with the following third parties:

Supabase Inc. — database and infrastructure provider (servers in the EU)
Stripe Inc. — payment processor (for PRO subscriptions via web)
Przelewy24 (DialCom24 Sp. z o.o.) — payment processor for Polish users
Apple Inc. / Google LLC — in-app purchase processing (for subscriptions purchased via mobile apps)
AI model providers — for the AI Analytics feature which summarizes and identifies statistical patterns in the user's own historical trading data (data is anonymized before processing; no automated decision-making)

We do not sell your personal data to third parties for marketing purposes.

6. International Data Transfers

Some of our service providers are based outside the European Economic Area (EEA). In such cases, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, to protect your data in accordance with GDPR requirements.

7. Your Rights

Under the GDPR, you have the right to:

Access your personal data
Rectify (correct) inaccurate data
Erase your data ("right to be forgotten")
Restrict processing of your data
Data portability (receive your data in a structured, machine-readable format)
Object to processing based on legitimate interest
Withdraw consent at any time

To exercise any of these rights, contact us at: tradelogic.kontakt@gmail.com

You also have the right to lodge a complaint with your local data protection authority. In Poland, this is the President of the Personal Data Protection Office (UODO).

8. Cookies and Tracking

TradeLogic uses cookies and similar technologies for:

Maintaining your logged-in session
Remembering your language preferences
Analyzing app usage (anonymous statistics)

We do not use third-party advertising trackers. You can manage cookies in your browser settings.

9. Data Security

We implement the following security measures to protect your data:

Encryption of data in transit (HTTPS/TLS)
Encryption of user passwords (bcrypt hashing)
Regular data backups
Role-based access control (only authorized personnel can access personal data)
Row-Level Security (RLS) ensuring users can only access their own data

10. Children's Privacy

TradeLogic is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such data.

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy. We will notify you of any material changes via email or in-app notification at least 14 days before the changes take effect.

12. Contact Us

Email: tradelogic.kontakt@gmail.com
Address: STREFA OXYGEN Sp. z o.o., ul. Zielonogórska 31/54, 41-218 Sosnowiec, Poland