Privacy Policy

This Privacy Policy explains what personal data Action Journal collects, why we collect it, how long we keep it, who we share it with, and what rights you have over it. It applies to the Action Journal mobile application, its backend services, and any website or download page we operate that links to it.

We are the data controller for the personal data described in this Policy. We are not the controller for information that remains on your device and never reaches us, and we are not the controller for data held by your broker or trading platform. Where those parties process your data, their own policies apply to you instead of ours.

Trading activity is not anonymous. A history of your trades, together with your account numbers, broker identity, profit and loss, and written reflections, can reveal a great deal about your financial position and your behaviour. We treat that information with care for the whole of this Policy.

We collect only what the Service needs to operate. We do not collect data for advertising, and we do not build advertising profiles. The categories below are the complete set.

• Account and identity data. Your email address, which is also your sign-in identifier, and a password you choose. We never see or store your password in a form we can read back, and a one-time sign-in code may be emailed to you at your request.
• Profile data you choose to provide. A display name, username, short biography, phone number, timezone, and profile picture. Every one of these is optional, and you can add, change, or remove them at any time in your profile settings.
• Trading account data. The name, broker, platform, account number, server name, base currency, and the balance, equity, margin, and profit and loss figures reported for each trading account you add.
• Trade history. Imported or manually entered trades, including instrument, direction, volume, entry and exit times, entry and exit prices, profit and loss, fees, and any position or ticket reference your broker provides.
• Journal content. Notes, tags, screenshots, and reflections you attach to trades or accounts. This content is yours and is often the most sensitive thing you store in the app.
• Broker credentials. Where you connect a broker, we store what that connection requires. For MetaTrader 5 this is your investor login, server name, and investor password. For Deriv this is your API token. These are encrypted at rest and are never shown to us in readable form.
• Technical and usage data. Your device and app version, operating system, device model, locale, time zone, crash reports and diagnostic logs, the pages and features you use, and the IP address from which a request reaches our servers.
• Commercial data. If you buy a subscription, your plan, billing status, transaction references, and the amount and currency of each payment.

A trading journal is only useful if it contains real trading activity, so the Service is designed to receive sensitive financial information. You decide what to enter and which accounts to connect. We do not scrape your broker, we do not link to your bank, and we have no access to your brokerage account outside the credentials you deliberately supply.

If you choose to connect a broker, you authorize that connection yourself. The connection is read-only, is used to import your own history, and is scoped to the accounts you select. We do not place, modify, or close trades on your behalf, and we cannot move money through it.

We rely on the following legal bases, depending on the processing and on where you live: performing our contract with you, which is providing the Service you asked for; our legitimate interests in operating, securing, and improving a software service; and your consent, asked for separately and withdrawable at any time, for anything optional such as marketing email.

• To create and secure your account, authenticate you, and keep you signed in.
• To store, organize, and display your trades, notes, and statistics, which is the core function you are paying for if you subscribe.
• To import trade history from a broker connection you have authorized.
• To synchronize your data between your device and your online account when you enable sync.
• To bill you, process payments, and provide support.
• To diagnose faults, keep the Service secure, and prevent abuse, including through aggregated or de-identified usage information.
• To send service messages, such as password resets, security notices, and important changes to this Policy. These are not marketing and cannot be switched off while you hold an account.
• To send marketing email only where we have your consent, and to measure whether we have it.

We do not use your trading data to make investment recommendations, to target advertising, or to train artificial intelligence models.

We do not sell your personal data. We share it only with the categories of recipient listed below, and only to the extent each one needs it to perform its function for you or for us.

• Supabase, our infrastructure provider, which hosts our database, authentication, file storage, and server-side functions. It processes data on our instructions under contract.
• Our payment providers, which process the payments you make for a plan. They receive what they need to take payment, such as your plan, the amount, and a transaction reference, and return the payment status. We do not see or store your full card number.
• Sentry, our crash and error reporting provider, which receives diagnostic reports so we can find and fix faults. Error reports are designed to exclude your trading content and credentials.
• Your broker or trading platform, and the MT5 connection infrastructure we operate to reach a broker terminal, where those parties provide the connection or the data you asked us to import.
• Professional advisers, auditors, and regulators, where we are required to disclose information by law or need it to establish or defend legal claims.
• A successor or business partner, if we sell or transfer the Service or substantially all of its assets, provided the buyer is bound by confidentiality and this Policy continues to apply to your data.

Every recipient above is either a supplier bound by contract to protect your data or a public authority with a lawful basis to receive it. We do not share your personal data with data brokers, advertising networks, or social media platforms, and we do not permit a recipient to use your data for its own marketing.

Our infrastructure providers operate globally, so your data may be processed in a country other than the one you live in, including the United States. Where data leaves the European Economic Area, the United Kingdom, or Switzerland, we rely on an adequacy decision or on standard contractual clauses approved by the European Commission, together with a transfer risk assessment and additional technical safeguards.

You may ask us for a summary of the transfer mechanisms we use, or for a copy of the safeguards that apply to your data, by writing to the address in Section 15.

We keep your data for as long as your account is active, because that is the period in which it is useful to you. After you delete your account, we remove or anonymize your personal data within a reasonable period, and in any event within 30 days, except where we must retain specific records longer to meet a legal or accounting obligation.

• Account, profile, and trading data. Held while your account is active, then deleted or anonymized within 30 days of account deletion.
• Broker credentials. Deleted as soon as you disconnect the relevant account, or within 30 days of account deletion. Disconnecting an account removes the stored password or token without deleting the trade history already imported.
• Journal notes, tags, and images. Retained with your account until you delete them or your account.
• Security and diagnostic logs. Retained for a limited period, generally up to 12 months, and then deleted or aggregated.
• Billing and payment records. Retained for the period required by tax and accounting law, commonly 7 to 10 years, even after you close your account.
• Backups. Encrypted backups are retained for a short rolling period, up to 35 days, after which deleted data falls out of rotation.

We apply technical and organizational measures proportionate to the sensitivity of the data we hold, which includes your trading history and your broker credentials.

• Encryption in transit. Data travels between your device and our servers over TLS.
• Encryption at rest. Broker passwords, API tokens, and database contents are encrypted when stored.
• Row-level access control. Every record in our database is tied to your user account, and the database itself refuses to return a row to a request that does not belong to the person making it. Even a defect in our application code cannot read another user's journal.
• Device-local storage. When you do not use sync, your trading data stays on your device and is never uploaded.
• Restricted internal access. Staff access to production data is limited to what a task requires and is logged.
• Access logging. Security-relevant actions, including sign-in, credential changes, and account deletion, are recorded so that misuse can be investigated.

No method of storage or transmission is completely secure, so we cannot promise absolute security. If a breach affects your personal data and is likely to create a risk to you, we will notify you and the relevant supervisory authority without undue delay.

Depending on where you live, you may have some or all of the following rights over your personal data. We extend the same rights to every user regardless of location, wherever we can.

• Access. Ask for a copy of the personal data we hold about you.
• Rectification. Ask us to correct data that is inaccurate or incomplete.
• Erasure. Ask us to delete your data, which you can also do yourself from inside the app at any time.
• Restriction. Ask us to pause certain uses while a dispute about accuracy or lawful basis is resolved.
• Portability. Receive your data in a structured, commonly used, machine-readable format so you can move it to another provider.
• Objection. Object to processing based on legitimate interest, and to direct marketing at any time.
• Withdraw consent. Withdraw any consent you gave, without affecting processing that already happened lawfully.
• Complain. Contact your local data protection authority, such as the Information Commissioner's Office in the United Kingdom or your national authority in the European Economic Area. We would rather you came to us first, and we will not treat a good-faith complaint as a breach of these Terms.

• A profile picture is optional, and we ask for photo library access only so you can choose one.
• Marketing email is sent only with your consent, measured by whether you open it, and stops as soon as you unsubscribe.
• Diagnostics beyond what is needed to keep the Service running are optional and can be turned off in your settings.

The mobile app does not use advertising cookies, tracking pixels, or cross-site advertising identifiers. We store a small number of preferences on your device, such as your appearance, currency, and notification choices, and the app keeps your session so you do not have to sign in on every visit.

Where we use strictly necessary storage to run the Service, such as the session token that keeps you signed in, we rely on that being necessary rather than on consent. Any other optional storage is off until you turn it on.

The Service is not directed at children, and trading involves financial risk and is not appropriate for anyone under 18 or the age of majority where you live, whichever is higher. We do not knowingly collect data from children. If you believe a child has given us personal data, write to us and we will delete it.

We do not use your personal data to make decisions that produce legal effects for you, and we do not build a profile of your characteristics or preferences in order to treat you differently. Statistics, charts, and summaries in the Service are calculations performed on the data you supplied, designed to show you your own results. They are not predictions about you and they are not advice.

We may revise this Policy as the Service or the law changes. We will post the new version here with a revised effective date and notify you in the app or by email before a material change takes effect. If you continue to use the Service after that date, the revised Policy applies to you.

For any privacy question, request, or complaint, open the live chat in the app: tap Profile, then Chat. Please describe what you need as clearly as you can, and we will confirm receipt and respond within a reasonable period, normally within 30 days where a formal right is involved.

If you are in the European Economic Area, the United Kingdom, or Switzerland, you also have the right to complain to your local supervisory authority. We would prefer that you contact us first, because we can usually resolve the issue faster than a regulator can.

If Action Journal is sold, merged, or otherwise transferred, your data will pass to the new owner as part of that transaction. We will tell you before your data changes hands, and you will keep every right described in Section 9, including the right to delete your data and object to the transfer.