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Legal Document

Privacy 

Policy

This policy explains how Flow88 - Gestão de Ativos, incorporated in Portugal, collects, uses, and protects your personal data when you use Tracker Fx. We are committed to your privacy and comply with the General Data Protection Regulation (GDPR).

Last updated: 6 April 2026

01

Who We Are

The data controller responsible for your personal data is:

Flow88 - Gestão de Ativos

Portugal

Email: support@trackerfx.com

For any questions or requests relating to your personal data, please contact us at the address above.

02

Data We Collect

We collect the following categories of personal data:

Account data

  • Full name
  • Email address
  • Password (stored in hashed form - never readable)
  • Subscription plan and billing status

Trading data

  • Trade history imported from connected trading platforms (open/close prices, volume, profit/loss, timestamps)
  • Notes and tags you add manually
  • Playbook content and strategy rules you create

Payment data

  • Payments are processed by Stripe. We do not store your card number or full payment details. We only receive a payment confirmation and a Stripe customer reference.

Technical data

  • IP address and browser/device type, collected automatically when you access the Service
  • Session data necessary for the Service to function

03

How We Use Your Data

We use your data solely to operate and improve the Service:

  • To create and manage your account
  • To provide the journaling, analytics, and reporting features of the platform
  • To process your subscription payments via Stripe
  • To send transactional emails (account confirmation, password reset, billing notifications, and free trial reminders)
  • To respond to your support requests
  • To maintain the security and integrity of the Service

We do not use your data for advertising, profiling, or any purpose beyond what is described above.

04

Legal Basis for Processing

Under GDPR, we process your personal data on the following legal bases:

  • Contract performance - processing your account data and trading data is necessary to provide the Service you subscribed to
  • Legitimate interests - processing technical data to maintain security and prevent fraud
  • Legal obligation - retaining billing records as required by Portuguese and EU law

05

Data Storage & Security

Your data is stored on secure servers provided by Amazon Web Services (AWS). AWS is certified under ISO 27001 and other industry security standards.

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or disclosure, including encrypted connections (HTTPS), hashed passwords, and access controls.

No method of transmission or storage over the internet is 100% secure. While we take your data security seriously, we cannot guarantee absolute security.

06

Third-Party Services

We share your data only with the following third-party services, which are strictly necessary to operate the Service:

Stripe

Payment processing. Stripe handles all card transactions. Their privacy policy is available at stripe.com/privacy.

Amazon Web Services

Cloud infrastructure and data storage. AWS processes data on our behalf under a data processing agreement.

Trading Platforms

When you connect a trading account, we access your trade data via the platform's official read-only API. We do not share your data back to these platforms.

We do not sell your data to third parties. We do not share your data with advertisers or marketing platforms.

07

Cookies

Tracker Fx uses only essential cookies - small files stored in your browser that are strictly necessary for the Service to function. These include:

  • Session cookies to keep you logged in during your visit
  • Security cookies to protect against cross-site request forgery (CSRF)

We do not use advertising cookies, tracking cookies, or any third-party analytics cookies.

08

Data Retention

We retain your personal data for as long as your account is active. If you cancel your subscription, your data remains stored until you explicitly request its deletion.

To delete your account and all associated data, contact us at support@trackerfx.com. We will process your request within 30 days.

Billing records may be retained for longer where required by Portuguese or EU tax and accounting law, independently of account deletion.

09

Your Rights

Under GDPR, you have the following rights regarding your personal data:

  • Right of access - request a copy of the personal data we hold about you
  • Right to rectification - request correction of inaccurate or incomplete data
  • Right to erasure - request deletion of your personal data ("right to be forgotten")
  • Right to restriction - request that we limit the processing of your data in certain circumstances
  • Right to data portability - request your data in a structured, machine-readable format
  • Right to object - object to processing based on legitimate interests

To exercise any of these rights, contact us at support@trackerfx.com. We will respond within 30 days. You also have the right to lodge a complaint with the Portuguese data protection authority, the CNPD (Comissão Nacional de Proteção de Dados), at cnpd.pt.

10

Children's Privacy

Tracker Fx is not directed at children. The Service requires users to be at least 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has created an account, we will delete it promptly.

11

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page and, where changes are material, notify you by email.

Continued use of the Service after the effective date of any changes constitutes your acceptance of the updated policy.

12

Contact

For any privacy-related questions or to exercise your rights, please contact us:

Flow88 - Gestão de Ativos

Portugal

Email: support@trackerfx.com

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