Privacy Policy

This Privacy Policy explains how LedgerPips ("we", "us", or "our") collects, uses, discloses, and protects your personal data when you use our Service. We are the data controller of the personal data we process about you. By using the Service, you agree to the practices described in this Policy.

1. Information We Collect

We collect the following categories of information:

• Account Information: name, email address, and hashed password
• Trading Data: trade history imported from your MT4/MT5 broker accounts (symbols, volumes, prices, timestamps, profit/loss)
• Broker Credentials: investor (read-only) passwords for trade synchronization, stored encrypted using AES-256-GCM
• Journal Content: notes, tags, screenshots, and other content you voluntarily add to your journal
• Payment Information: processed securely by PayPal — we do not store card numbers or CVVs; we only store billing metadata (subscription status, PayPal subscription ID)
• Usage Data: pages visited, features used, interaction events, session duration, device and browser information
• Technical Data: IP address, user-agent, timezone, operating system, error logs
• Communications: support tickets, emails, and feedback you send us

2. How We Use Your Information and Legal Basis

We use your information for the following purposes, each supported by a lawful basis under the GDPR:

• To provide the Service (performance of contract) — authenticate you, sync trades, display analytics, run the AI journal features
• To process payments and manage subscriptions (performance of contract) — through PayPal
• To send transactional and service notifications (performance of contract) — account alerts, billing receipts, security notices
• To improve the Service (legitimate interest) — analyze usage patterns, fix bugs, develop new features
• To prevent fraud, abuse, and security incidents (legitimate interest and legal obligation) — detect unauthorized access, enforce Terms
• To comply with legal, tax, and accounting obligations (legal obligation) — retain payment records, respond to lawful requests
• To send marketing communications (consent) — only if you have opted in; you can withdraw consent at any time

3. Data Sharing and Sub-Processors

We do not sell, rent, or trade your personal data. We share data only with the following categories of recipients, each bound by contractual confidentiality and data-protection obligations:

• Supabase Inc. (United States) — database hosting, authentication, row-level security
• PayPal Holdings, Inc. (United States) — payment processing and subscription billing
• Vercel Inc. (United States) — frontend hosting and content delivery
• Hetzner Online GmbH (Germany, European Union) — backend and MT4/MT5 synchronization infrastructure
• Broker platforms (MT4/MT5) — read-only connections to fetch your trade history using credentials you provide
• Legal and regulatory authorities — only when required by valid legal process (subpoena, court order, law enforcement request)
• Professional advisors — accountants, lawyers, and auditors under confidentiality, when reasonably necessary
• Business-transfer recipients — in the event of a merger, acquisition, or sale of assets, subject to equivalent privacy protections

We will update this list when we add or remove a sub-processor. For the most current list or questions, contact us at support@ledgerpips.com.

4. International Data Transfers

LedgerPips operates globally. Several of our sub-processors (Supabase, PayPal, Vercel) are located in the United States, and our infrastructure provider (Hetzner) is located in Germany (European Union). This means your personal data may be transferred to, processed, and stored in countries outside your country of residence, including countries that may not provide the same level of data-protection law as the EU or UK.

Where personal data is transferred outside the European Economic Area (EEA) or the United Kingdom, we rely on appropriate legal safeguards, such as the European Commission's Standard Contractual Clauses (SCCs) and supplementary technical measures (encryption in transit and at rest), to ensure your data receives an adequate level of protection.

5. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Account information and trading data: retained while your account is active; deleted within 30 days of account deletion, except where we are legally required to retain it
• Payment and billing records: retained for up to 7 years to comply with tax, accounting, and anti-money-laundering obligations
• Authentication and security logs: retained for up to 90 days
• Support communications: retained for up to 2 years after resolution
• Marketing consent records: retained until you withdraw consent, plus 3 years for evidentiary purposes
• Aggregated, anonymized analytics: may be retained indefinitely as it no longer identifies you

6. Data Security

We take data security seriously and implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption in transit — all traffic between your browser and our servers uses TLS 1.2+ / HTTPS
• Encryption at rest — broker credentials are encrypted with AES-256-GCM before being stored
• Access controls — Supabase row-level security (RLS) ensures users can only access their own data
• Read-only broker access — only investor passwords are accepted; we cannot execute trades on your behalf
• Secure payment handling — card data never touches our servers (handled entirely by PayPal)
• Environment isolation — production infrastructure is segregated with principle-of-least-privilege access

No system is 100% secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security of data transmitted to or stored by the Service.

7. Your Privacy Rights

Regardless of your location, you have the following rights over your personal data:

• Access — request a copy of the personal data we hold about you
• Correction — request correction of inaccurate or incomplete data
• Deletion — request deletion of your account and personal data
• Portability — export your trading data in a structured, machine-readable format
• Objection — object to processing based on legitimate interest
• Withdraw consent — withdraw consent for any processing based on consent (e.g., marketing)

To exercise any of these rights, contact us at support@ledgerpips.com. We will respond within 30 days.

8. Additional Rights for EU / UK Users (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) or equivalent UK/Swiss law, including:

• The right to restrict processing in certain circumstances
• The right to not be subject to purely automated decision-making that produces legal or similarly significant effects
• The right to lodge a complaint with your local data-protection supervisory authority if you believe we have mishandled your data

9. Additional Rights for California Users (CCPA/CPRA)

If you are a California resident, you have the right under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) to:

• Know what categories of personal information we collect, use, and disclose
• Request deletion of personal information subject to certain exceptions
• Request correction of inaccurate personal information
• Opt out of the "sale" or "sharing" of personal information — we do not sell or share your personal information for cross-context behavioural advertising
• Not be discriminated against for exercising your privacy rights

10. Children's Privacy

The Service is not intended for anyone under the age of 18. We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child under 18, we will delete that information promptly. If you believe a child has provided us with personal data, please contact us immediately.

11. Cookies and Tracking

We use essential cookies for authentication, session management, and security. These cookies are necessary for the Service to function and cannot be disabled. We may use analytics cookies (with your consent where required) to understand how users interact with the Service and improve it. You can manage cookie preferences through your browser settings; disabling essential cookies may prevent you from logging in or using core features.

12. Marketing Communications and Opt-Out

We may send you product updates, tips, or promotional emails only if you have opted in. Every marketing email includes an unsubscribe link, and you can opt out at any time from your account settings. Opting out of marketing does not affect transactional or service-related communications (billing, security, account notices), which are necessary to provide the Service.

13. Data Breach Notification

In the event of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required, within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to you, we will also notify you directly via email without undue delay.

14. Third-Party Links

The Service may contain links to third-party websites or services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites. We recommend you review the privacy policy of every site you visit.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-app notification at least fifteen (15) days before the changes take effect. The "Last updated" date at the top of this Policy indicates when it was last revised. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

16. Contact

For privacy-related questions, to exercise your rights, or to report a data-protection concern, contact us at support@ledgerpips.com.