Privacy Policy

Tradiens is a trading journal, analytics, and market-research tool. It helps you record your own trades, understand your own performance, and research public market facts. This policy explains what personal data we process, why, and the rights you have over it.

The data controller responsible for your personal data is:

• Company: Lexecon Kft. — full legal name: LEXECON Tanácsadó és Informatikai Korlátolt Felelősségű Társaság (a limited liability company incorporated in Hungary)
• Registered seat: 9028 Győr, Páva utca 40. A. ép., Hungary
• Company registration number (cégjegyzékszám): 08-09-020132
• Tax number (adószám): 22738112-2-08
• Privacy contact: privacy [at] @tradiens.com

We host Tradiens on our own servers located in the European Union. Your account data lives in the EU by default (see Section 6). Because our controller is established in Hungary, our lead supervisory authority is the Hungarian National Authority for Data Protection and Freedom of Information (NAIH — Nemzeti Adatvédelmi és Információszabadság Hatóság), and Hungarian law applies alongside the directly applicable EU General Data Protection Regulation (Regulation (EU) 2016/679).

• We never sell your data. Not to advertisers, not to data brokers, not to anyone.
• We never train AI on your trades or journal. Our AI features only rephrase numbers that our own engine already computed. Your raw trading and journal data is never used as training data.
• We connect to your broker read-only. We can read your trade history. We can never place an order, move money, or trade on your behalf.
• Your broker keys are encrypted at rest (AES-256-GCM envelope encryption) and are never logged and never sent to your browser.
• No third-party trackers. Our product analytics are first-party and contain no personal data.

We process only what the product needs. Every category below lists its purpose, the GDPR Article 6 lawful basis, how long we keep it, and how it is protected.

3.1 Account email

• What: your email address, used for passwordless sign-in (magic link + 6-digit code) and to reply to you.
• Why / lawful basis: performance of our contract with you (Art 6(1)(b)) — the service cannot run without it.
• Retention: for the life of your account; deleted when you delete your account. Sign-in tokens expire after 15 minutes and are hashed, never stored in plain text.

3.2 Two-factor (TOTP) secret — optional

• What: if you enable an authenticator app, we store your TOTP secret.
• Why / lawful basis: performance of our contract (a security feature you switch on).
• Protection: envelope-encrypted (AES-256-GCM), never stored in plain text, never returned to your browser.

3.3 Broker API keys — the most sensitive data we hold

• What: the read-only API key/secret you provide to connect a broker account (e.g. Bybit, Coinbase, IBKR).
• Why / lawful basis: performance of our contract — you explicitly connect a broker so we can sync your trade history. This is a core feature you opt into.
• Protection: encrypted with AES-256-GCM envelope encryption — a unique random data key encrypts each secret, and that data key is itself wrapped by a master key that lives only in our server environment (never in the database, never in client code). Your browser only ever sees a masked preview (***ABCD). Decryption happens exclusively inside our server-side sync worker. The connection is read-only — we request no trading permission and reject write-scope keys.
• Retention: kept while the broker stays connected; disconnecting or deleting the account immediately removes the encrypted secret columns.

3.4 Trading, journal, and Vision Board data

• What: your trades, executions, P&L, position sizes, symbols, notes, daily check-ins, playbooks, backtests, and Vision Board content. This is your own financial data.
• Why / lawful basis: performance of our contract — this is the product itself.
• Retention: for the life of your account; deleted (cascade) when you delete your account.
• Our promise: we never sell it and we never train AI on it. When you use an AI feature, our engine computes the numbers first and the AI only puts them into words; your raw data is not used to train models.

3.5 Product analytics — first-party, no personal data

• What: aggregate product events (e.g. which features are used, where onboarding drops off).
• Why / lawful basis: legitimate interest (Art 6(1)(f)) in improving the product.
• What it never contains: no P&L, no amounts, no symbols, no keys, no journal text, no email, no IP, no filled-in URLs. Events pass through a two-layer filter that drops anything that looks like personal data. The user reference is a pseudonymous, non-linked identifier.
• Retention: short rolling window (90–180 days), then automatically pruned.

3.6 Support messages

• What: the email and message content when you contact support.
• Why / lawful basis: legitimate interest (answering you), or contract if you are a customer.
• Retention: limited — deleted a reasonable time after your request is resolved.

3.7 IP address (transient, for security)

• What: your IP address is read to rate-limit sign-in and contact requests (anti-abuse).
• Why / lawful basis: legitimate interest in protecting the service and other users.
• Important: we do not store your IP address in our database. It is used only transiently, in memory, for the length of a rate-limit window. Our infrastructure provider (Cloudflare) may log IPs at the network edge under its own terms (see Section 5).

3.8 Billing data (only if/when paid plans launch)

• What: subscription status and a Stripe customer reference. We never see or store your card details — Stripe's hosted checkout handles payment.
• Why / lawful basis: contract (Art 6(1)(b)) plus legal obligation (Art 6(1)(c)) for accounting/tax records.
• Retention: invoice/accounting data is kept for the period required by law, which overrides deletion requests for those specific records.

We do not sell, rent, or share your personal or trading data for marketing. We do not use your trades or journal to train artificial intelligence. Our AI features are "grounded": the numbers come from our own calculation engine and the AI only phrases them. Where we use a third-party AI provider (opt-in, see Section 5), that provider does not use our API inputs to train its models under our commercial terms.

We use a small number of trusted service providers to run Tradiens. Each processes only what its role requires, under a data processing agreement.

International transfers: some providers above are in the United States. Because our controller (Lexecon Kft.) is established in the EU, any transfer of personal data to these providers is a Chapter V (Art 44–49) transfer governed in full by the GDPR. Where personal data leaves the EU to these providers, we rely on the EU-US Data Privacy Framework (DPF) where the provider is certified, and/or on Standard Contractual Clauses (SCCs) where it is not. The most sensitive processing (AI on your trade data) is opt-in, and we offer a zero-egress alternative (bring-your-own-key or a local model) so you can avoid that transfer entirely.

Your account, trading, and journal data is stored on our own servers in the European Union. The only routine flow of personal data outside the EU is to the US sub-processors listed in Section 5, which is minimized and, for AI, opt-in.

Under the GDPR you can, at any time:

• Access the personal data we hold about you.
• Export your data in a machine-readable format (portability).
• Erase your account and personal data ("right to be forgotten").
• Rectify inaccurate data.
• Restrict or object to certain processing (including our legitimate-interest analytics).
• Lodge a complaint (GDPR Art 77) with a supervisory authority. Our lead authority is the Hungarian National Authority for Data Protection and Freedom of Information (NAIH — Nemzeti Adatvédelmi és Információszabadság Hatóság), website https://naih.hu. You may also complain to the authority in your own EU country of residence.

To exercise any right, email privacy [at] @tradiens.com. We respond within one month. Deleting your account cascades the deletion of your trades, executions, notes, Vision Boards, and connected broker credentials. Your pseudonymous analytics reference is detached (nulled) on deletion so it no longer points to you. Copies in encrypted backups roll off within the backup rotation window (up to 14 days). Billing records required by law are the only exception (Section 3.8).

• Read-only broker access — we never request trading permission; write-scope keys are rejected.
• Envelope encryption (AES-256-GCM) for broker keys and TOTP secrets, with a master key that never touches the database or the browser.
• Encryption in transit (TLS) for all connections.
• Passwordless sign-in with optional two-factor, and short-lived (15-minute), hashed sign-in tokens.
• Broker keys never leave the server and are never logged. Your browser only sees a masked preview.

We use only strictly necessary cookies: a sign-in session cookie and, if you set them, your language and theme preferences. We do not use advertising, cross-site tracking, or third-party analytics cookies. Because these cookies are strictly necessary and our analytics are server-side and contain no personal data, we do not show a cookie consent banner. See our short cookie note for details.

Tradiens is not intended for anyone under 18. We do not knowingly process data from minors.

We will post changes to this policy here and update the "last updated" date; material changes will be notified in-app or by email. Questions or requests: privacy [at] @tradiens.com.