PRIVACY POLICY

> 1. WHO WE ARE

We are cedere nescio s.r.o., a company registered in the Czech Republic (ID no: 08379581, VAT no: CZ08379581), located at Jerevanska 1066/3, Praha 10, 100 00 Praha, Czech Republic. We operate TradeCortex.ai, an AI-powered trading dashboard and journal. Contact us at support@tradecortex.ai.

> 2. DATA WE COLLECT

We collect:

• - Account Information: Name and email (for registration and account management).
• - Billing Information: Full name, billing address, and payment details (for paid features, processed via a secure third-party like Stripe—coming soon).
• - Trading Data: Trade executions, positions, and performance metrics from Interactive Brokers (for your dashboard and journal).
• - Technical Data: IP address (if logged by our hosting provider, Render, for security purposes—see Section 6).
• - Cookies: Essential cookies for login and session management.

> 3. HOW WE USE YOUR DATA

We use your data to:

• - Create and manage your account.
• - Process payments for paid features (once implemented).
• - Display your trading dashboard and journal.
• - Generate AI-powered suggestions throughout the day and on-demand summaries (daily, weekly, monthly) based on your trading data, time of day, and news calendar.
• - Ensure security (if IP is collected).
• - Improve our service.

> 4. LEGAL BASIS

We process data based on:

• - Contract: To deliver TradeCortex.ai's services (e.g., account, trade features, AI insights).
• - Legitimate Interest: For security (e.g., IP logging, if applicable).

> 5. DATA SHARING

Personal Information: We don't share your email or full identity with anyone.

AI Insights: We use third-party AI providers (e.g., Google Gemini, OpenRouter) to generate suggestions and summaries. They receive:

• - Your first name (for personalization, e.g., "Hi, [Name]").
• - Trade data from your dashboard, combined with time of day and news calendar info, accessed dynamically.
• - No other identifying details (like email) are shared, and the AI cannot link this data to your full identity.

These providers may process data outside the EU (e.g., in the U.S.) under Standard Contractual Clauses.

Service Providers: Our hosting provider (Render) stores your data securely in Frankfurt, EU Central.

> 6. DATA STORAGE AND SECURITY

• - Data is stored on Render's servers in Frankfurt, EU Central.
• - We use HTTPS, JWT authentication, and encryption to protect it.
• - IP Logging: Render may log IP addresses for security and debugging—we're confirming this and will update this policy if applicable.

Retention:

• - Account and billing data are kept until you delete your account, or as required by law (e.g., tax records).
• - Trading data is deleted after X days based on your subscription tier (currently 25 days, cleaned daily; higher tiers will offer longer lookback periods once implemented).

> 7. YOUR RIGHTS

Under GDPR, you can:

• - Access, correct, or delete your data.
• - Restrict or object to processing.
• - Request data portability.

Email us at support@tradecortex.ai to exercise these rights.

> 8. COOKIES

We use essential cookies for login. We don't currently use optional cookies (e.g., analytics), but if we do, we'll ask for your consent.

> 9. CONTACT US

For questions or concerns, reach us at support@tradecortex.ai.