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GDPR · Art. 13 & 14

Privacy Policy

Protecting your personal data is important to us. This Privacy Policy informs you about what data we collect, how we use it and what rights you have — in accordance with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

Note: The German version of this Privacy Policy is the legally binding version. This English translation is provided for convenience only.

1. Data Controller

Company: TradeOnyx UG (haftungsbeschränkt) i.G.

Address: Stockberg 19, 52393 Hürtgenwald, Germany

Authorised representative: Managing director Christian Grube

Registration court: Amtsgericht Düren — registration applied for (formation in progress)

Email: [email protected]

Contact form: tradeonyx.io/kontakt

A separate Data Protection Officer is not required under § 38 BDSG: the company employs fewer than 20 persons in continuous automated processing of personal data.

2. Hosting & Server Log Files

This website is hosted on a dedicated server of Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany) in a data centre located within the Federal Republic of Germany. A data processing agreement (DPA) pursuant to Art. 28 GDPR is in place with Hetzner. Technically necessary server log files are collected automatically. These contain: IP address (truncated / pseudonymised after processing), date and time, requested URL, HTTP status code, data volume transferred, browser type and operating system.

Legal basis: Art. 6 (1)(f) GDPR (legitimate interest in stable, secure operation and defence against attacks). Retention: Maximum 14 days; afterwards logs are deleted or fully anonymised.

File storage (Cloudflare R2): Uploaded files (avatars, trade and journal attachments) are stored in an EU bucket of the S3-compatible object storage service Cloudflare R2. Provider: Cloudflare Germany GmbH, Rosental 7, 80331 Munich, with data processing agreement and EU data residency. Standard Contractual Clauses (SCC) under Art. 46 GDPR are covered by the Cloudflare Data Processing Addendum.

3. Registration & User Account

When you register, we collect: username, email address, password (Bcrypt hash, never in plain text), registration timestamp, last login, and optionally a profile picture you upload yourself.

Purpose: Providing and managing your user account. Legal basis: Art. 6 (1)(b) GDPR. Retention: For the duration of your account; deleted within 30 days of account closure.

3.1 Minors (Art. 8 GDPR)

The platform is intended exclusively for persons aged 18 and over (see Terms § 3). We do not knowingly process data of minors. If we become aware that we are processing data of a person under 18, we will delete it without delay (Art. 17 GDPR). Parents or guardians who suspect their child has created an account can contact [email protected].

4. Trading Data (Trading Journal)

As part of using the platform, you store the following data. All of it is exclusively linked to your account and is not visible to other users:

  • Trade data (symbol, direction, volume, prices, timestamps, P&L)
  • Journal entries (pre-market plan, market notes, post-market reflection, mood ratings, lessons learned)
  • Trade reviews (execution grade, mood before/after, plan-followed flag, notes)
  • Tags, playbooks and trade↔playbook assignments
  • Uploaded screenshots (stored locally on our server; retrievable only by you)
  • Per-account symbol mappings
  • XP / level events, trading-account configuration

Legal basis:Art. 6 (1)(b) GDPR. You can delete your data at any time; deleting a trading account also removes its symbol mappings, clearing all trades on an account removes that account's mappings.

4.1 Audit Log

Every mutation of journal entries, reviews, tags and playbooks is written to an internal audit log with timestamp, old value and new value. This gives you complete change traceability and is the foundation for planned coach/team features. The audit log is strictly internal and linked to your account; it is deleted together with your account.

4.2 Uploaded Images / Screenshots

Screenshots attached to trades or journal entries are stored on our server under a randomised path. Access is only possible through an authenticated route that verifies ownership both at the user level and at the entity level. Other users — including authenticated ones — cannot retrieve these files. Maximum file size: 6 MB, permitted formats: PNG, JPEG, WebP, GIF.

4.3 Timezone Data

Trade timestamps are stored server-side as UTC and only converted to your configured IANA timezone for display. When importing broker files you can set the source timezone per file. Changing the timezone in settings affects only display, not storage.

4.4 Tax-export calculation (Anlage KAP)

Purpose: aggregation of your closed trades as preparation for entry into the Anlage KAP form of the German income-tax return. Methodology: buy and sell fills are paired per symbol and per account using the FIFO method(First In, First Out) into round-trip trades. Per trade we sum gross P&L, commission and swap, and convert display times to the account timezone you selected. Data source: exclusively your stored trade data (see section 4); no third-party enrichment occurs. Legal basis: Art. 6 (1) (b) GDPR (performance of a contract).

A detailed description of the calculation methodology together with an explicit limitation of liability is provided in our Terms § 11a (Anlage-KAP Export — Disclaimer).

4.5 Algorithmic pattern detection and profiling (Art. 13 (2)(f) GDPR)

(1) What happens. The platform analyses your trade and journal data using rule-based detectors ("Onyx Engine") that surface statistical patterns in your trading behaviour and report them back to you as "Patterns" (e.g. revenge_trading, overtrading, position_sizing_drift, hold_time_asymmetry). This analysis constitutes profiling within the meaning of Art. 4 (4) GDPR.

(2) Logic. The detectors compare individual trades against your own baseline values (volume, hold time, time of day, risk profile) and flag trades that deviate significantly. The thresholds and algorithms are documented openly in our public architecture documentation.

(3) Scope. The insights serve exclusively your personal self-reflection. No automated decision producing legal effects or similarly significantly affecting you takes place (Art. 22 (1) GDPR does not apply). You remain the sole decision-maker for all trading actions; the platform does not issue investment recommendations.

(4) Right to object. You can object to the profiling at any time (Art. 21 (1) GDPR). In that case the Onyx Engine analysis is disabled for your account; the underlying trade data is unaffected. Write to [email protected].

(5) AI analyses (Pro Plus). In addition to the rule-based Onyx Engine you can run individual trades or journal entries through an AI provider (see section 6 "AI-Powered Analyses"). That processing is also profiling; it is triggered exclusively by your active click (Art. 6 (1)(a) GDPR).

5. Cookies, Local Storage & Consent

On your first visit we display a consent bannerat the bottom of the screen. You decide there per category what we may load — three equally-prominent buttons (“Only essential” · “Settings” · “Accept all”) plus a close button that maps to rejecting the non-essential categories. Your choice is stored locally in your browser and is valid for 12 months; afterwards we ask again. Via the Cookie settings link in the footer you can change or fully revoke your choice at any time — as easily as you gave it (Art. 7 (3) GDPR).

5.1 Essential (always on)

  • Session cookie (session): Encrypted session ID to recognise your login. Deleted on logout or when the browser is closed. Provider: TradeOnyx UG (haftungsbeschränkt) i.G., EU-Hetzner servers.
  • CSRF protection: Hidden token to defend against cross-site request forgery. Reissued per session.

Payment processing (Stripe) — planned, not yet active: The current free beta has no payment surface, so no Stripe cookies are set. Only once paid plan checkout is enabled after the UG is registered (see Terms § 4) may the payment provider set fraud-prevention cookies (__stripe_mid, __stripe_sid; provider then: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Dublin 2, Ireland) — and only when you start a payment yourself. We will update this section before activation.

5.2 Comfort (opt-in)

  • Language preference (tradeonyx_lang): Stores your chosen language (DE/EN) in localStorage. No tracking, no server access.
  • Theme (tradeonyx_theme): Stores your colour preference (light/dark) in localStorage.

5.3 Analytics (opt-in)

Currently no analytics cookies are active. We plan a self-hosted reach-measurement (Plausible Analytics on our own EU server) that records only anonymous aggregate statistics — no personal profile building, no cross-site tracking, no third-country transfer. Until then, the toggle in the banner is a placeholder.

5.4 External content (opt-in)

Embedded YouTube videos are delivered in click-to-load mode by default (see the “Embedded walkthrough videos” section below). Only when you click play does the YouTube player load in privacy-enhanced mode. Activating this toggle disables the click-to-load shield for embedded videos so third-party content may load directly on page open.

Legal basis: Essential cookies: Art. 6 (1)(b) and (f) GDPR in conjunction with § 25 (2) (2) TDDDG (technically required for contract performance). Comfort, Analytics and External content: Art. 6 (1)(a) GDPR in conjunction with § 25 (1) TDDDG (your active consent via the banner).

6. External Services

Google Fonts

This website loads fonts asynchronously from Google Fonts. Google may process the IP address of your browser in doing so. Legal basis: Art. 6 (1)(f) GDPR. More information: Google Privacy Policy.

Market Data (Yahoo Finance)

The platform fetches price data (candles) and symbol search results server-side from the Yahoo Finance API (query1.finance.yahoo.com, query2.finance.yahoo.com). All requests originate from our server, not your browser — no personal data, IP addresses or identifiers of our users are transmitted to Yahoo. Fetched price data is cached locally to minimise Yahoo requests.

AI-Powered Analyses (optional, plan-dependent)

For certain features — in particular the AI analysis of individual trades and journal entries, daily market briefings, and news/calendar summaries — the platform calls a third-party AI provider's API (currently Anthropic PBC, api.anthropic.com, data centres in the United States). This transmits your trade data, journal content, review notes, tags, playbook descriptions and account currency as prompt context to the AI provider. The response (Markdown text) is cached on our side for the duration of your subscription so you can re-access it without a new API call, and is deleted together with your account. A Data Processing Addendum with Anthropic PBC including a zero-retention clause contractually prohibits use of the data for model training. If we switch AI provider, we commit to securing an equivalent contractual guarantee in advance.

We reserve the right to change the AI provider (e.g. to OpenAI, Google, Mistral or self-hosted models) to optimise cost, performance or privacy. Any change will be reflected here and existing users will be notified of material changes.

Legal basis:Art. 6 (1)(b) GDPR (performance of contract) and Art. 6 (1)(a) GDPR (consent, given by actively clicking the "Run analysis" button for each trade/journal entry). Third-country transfer: conducted primarily under the EU Commission's adequacy decision for the EU-US Data Privacy Framework (Decision 2023/1795; Anthropic PBC is DPF-certified), and additionally under EU Standard Contractual Clauses (SCC) pursuant to Art. 46(2)(c) GDPR, plus technical safeguards (TLS 1.2+, zero-retention addendum). The AI analysis can be disabled by the administrator and simply not used by individual users. Further information: Anthropic Privacy Policy.

Notice under the EU AI Act: AI-generated content is clearly labelled "AI analysis" in the UI. Results are algorithmically generated, do not constitute financial advice, and come without warranty.

Transactional emails (Postmark)

For transactional emails (account confirmation, password reset, weekly digest, system notifications) we use the email-delivery service Postmark, operated by ActiveCampaign, LLC, 1 N Dearborn St, 5th Floor, Chicago, IL 60602, USA. We transmit only your email address, name (where stored) and the email content. A data-processing agreement (DPA) including EU Standard Contractual Clauses is in place under Art. 46 (2)(c) GDPR. Legal basis: Art. 6 (1)(b) GDPR (contract performance) or Art. 6 (1)(f) GDPR (security / service notifications).

Error monitoring (Sentry)

To ensure stable operation and quick error resolution we use Sentry by Functional Software, Inc. d/b/a Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA, with EU data residency (de.sentry.io, Frankfurt). When an error occurs we collect the error message, stack trace, requested URL, browser and OS information and a truncated IP address. The data serves solely for technical debugging; no profiling or ad-targeting takes place. Retention in Sentry: 30 days. Legal basis: Art. 6 (1)(f) GDPR (legitimate interest in platform stability). Third-country transfer: EU data residency; a DPA including EU Standard Contractual Clauses is in place. Further information: Sentry Privacy Policy.

Content delivery network & access protection (Cloudflare)

All web traffic to tradeonyx.io and the subdomains app.tradeonyx.io, uploads.tradeonyx.io and assets.tradeonyx.io is routed via the Cloudflare CDN, operated by Cloudflare Germany GmbH, Rosental 7, 80331 Munich (contracting party) and its parent Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare runs a globally distributed edge network in which IP address, user agent and requested URL are technically processed for content delivery and DDoS mitigation. Administrative areas (staging, admin inbox) additionally use Cloudflare Access; a short-lived JWT cookie (CF_Authorization) is set in the authorised administrator's browser.

Legal basis: Art. 6 (1)(f) GDPR (legitimate interest in stable, performant and secure delivery of the platform) and Art. 6 (1)(b) GDPR for the contract-related subdomains. Third-country transfer: A data-processing addendum including EU Standard Contractual Clauses under Art. 46 (2)(c) GDPR is in place with Cloudflare. Further information: Cloudflare Privacy Policy.

Bot protection (Cloudflare Turnstile): On the contact form (/kontakt) and the registration form (/register) we use Cloudflare Turnstile. Turnstile is a privacy-friendly alternative to CAPTCHA services (notably Google reCAPTCHA): no click puzzles, no tracking cookies, no browser-history evaluation. When the form is opened, a script from challenges.cloudflare.com is loaded that checks in the background whether the request is human or automated; in the process the IP address, user agent and a few browser properties are transmitted to Cloudflare. Legal basis: Art. 6 (1)(f) GDPR (legitimate interest in preventing spam and bot registrations). Third-country transfer and DPA apply analogously to the Cloudflare CDN entry above.

Embedded walkthrough videos (YouTube)

On selected pages (e.g. /walkthrough/<name> and individual Academy articles) we embed walkthrough videos from the TradeOnyx UG (haftungsbeschränkt) i.G. YouTube channel. The YouTube service is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

We use a two-step pattern: we first show a preview image and play button hosted on our own servers (click-to-load). Until you actively click play, your browser does not connect to Google at all — no cookies are set, no IP address, user agent or other data is transmitted. Only your active click loads the actual YouTube player in privacy-enhanced mode (youtube-nocookie.com). From that moment on your browser connects directly to Google's servers — at that moment your IP address, user agent, referrer URL and device information are technically required to deliver the video. If you are signed in to a Google account at the time, Google may associate the playback with that account — you can avoid this by signing out of your Google account before clicking play.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a low-friction, audiovisual product demonstration). Third-country transfer: Once the video is started, data is transferred to the USA. We have a Data Processing Addendum with Google covering EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Further information: Google Privacy Policy.

Web Analytics

We do not use Google Analytics, Meta Pixel, LinkedIn Insight, TikTok Pixel or any comparable tracking solution. Our own usage statistics are derived exclusively from the server logs (see section 2) and contain no personally identifiable identifiers. Identification of individual users is neither possible nor intended. A self-hosted reach- measurement (Plausible Analytics on our own EU server) is planned and will be documented here before activation; it will appear as opt-in in the cookie banner. Legal basis: Art. 6 (1)(f) GDPR. No cookie consent banner is required under § 25 (2) TDDDG for the server-log-based measurement.

7. Data Sharing with Third Parties

We do not share your personal data with third parties unless you have consented, sharing is necessary to perform the contract, a legal obligation exists, or a legitimate interest prevails.

8. Your Rights as a Data Subject

  • Right of access (Art. 15 GDPR): What data we hold about you.
  • Right to rectification (Art. 16 GDPR): Correction of inaccurate data (also available in your profile).
  • Right to erasure (Art. 17 GDPR): Request via [email protected] or directly in your profile via the delete-account function.
  • Right to restriction of processing (Art. 18 GDPR).
  • Right to data portability (Art. 20 GDPR): You can export your trading data as CSV and your journal entries (including reviews and tags) as JSON from the profile. For data not covered by the export function (e.g. audit log) an informal request to [email protected] is sufficient.
  • Right to object (Art. 21 GDPR).
  • Right to withdraw consent (Art. 7 (3) GDPR): At any time with effect for the future.

Contact for all data-protection enquiries: [email protected]

9. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR):

: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestr. 2-4, 40213 Düsseldorf, Germany — [email protected], ldi.nrw.de

A list of all German data protection authorities: www.bfdi.bund.de

10. Data Security

  • Passwords are stored exclusively as Bcrypt hashes — never in plain text.
  • Database access is conducted via encrypted connections within the server network.
  • Session tokens are encrypted and have a limited validity period.
  • HTTPS/TLS 1.2+ encryption for all data in transit
  • Server-side encryption at rest for uploaded files (Cloudflare R2)
  • Bcrypt password hashing (never plain text)
  • Optional two-factor authentication (TOTP, RFC 6238) in the settings. Admin accounts use 2FA mandatorily (Art. 32 GDPR — appropriate technical measure for privileged access).
  • Security emails on sign-ins from new devices and on critical actions (password change, 2FA enabled / disabled). The device fingerprint is stored only as a SHA-256 hash over browser family, OS family, country, and IP prefix (/24 IPv4, /48 IPv6) — never a raw IP. Trusted devices can be reviewed and revoked individually in the settings (Art. 16 + Art. 17 GDPR).

Last updated: 14 May 2026 · This Privacy Policy will be updated when the platform or applicable law changes.