Privacy Policy
Draft. The marked fields must be completed, and the text reviewed by a lawyer, before Margin is opened to the public.
1. Who is responsible for your data
- The controller of your personal data is [full name or company name], [address], Poland, [register and number: CEIDG or KRS], tax number (NIP) [NIP] (“we”, “us”).
- For anything concerning your data, write to [contact email] or to the address above. [We have not appointed a data protection officer / Our data protection officer can be reached at: address]
- This Policy gives you the information required by Articles 13 and 14 of Regulation (EU) 2016/679 (the “GDPR”). It is for your information and you do not need to consent to it. The rules for using Margin are in the Terms of Service.
2. In brief
- We use your data to run your journal, to keep it secure and to understand how Margin is used in general.
- We do not sell your data. Margin has no advertising and no third-party analytics or tracking pixels.
- Your email address and date of birth are stored encrypted, and your password only as a hash.
- Your journal is not published. Other users cannot see it. Administrators' statistics pages show only totals and shares.
- Some third parties receive your IP address when content is loaded from them. See section 5.
3. What we process, why and for how long
You provide this data yourself, except for technical data, which comes from your browser and device. Legal bases refer to Article 6(1) GDPR.
| Purpose | Data | Legal basis | How long |
|---|---|---|---|
| Creating and running your Account, signing you in | Email address, display name, password hash, time zone, theme, dates of acceptance, of sign-in and of password change | (b) performing the contract | Until the Account is deleted |
| Checking that you are at least 18 | Date of birth | (b) performing the contract, as the age limit is a condition of the Terms | Until the Account is deleted |
| Providing the journal and its tools | Your Content: trades, fills, fees, Trading Accounts and limits, trading rules, strategies, notes, screenshots, images, videos, recaps, guides, P&L card designs, including any picture, nick and social media names you add to a card | (b) performing the contract | Until you delete it or the Account. Notes you move to the trash stay until you delete them |
| Keeping you signed in and letting you end sessions | Session token hash, IP address, browser details (user agent), session times | (b) performing the contract; (f) our legitimate interest in security | Until the session ends or expires, at most 30 days, and removed at the next clean-up |
| Protecting Margin against password guessing and abuse | IP address, a keyed fingerprint of the email address, type and result of the attempt | (f) our legitimate interest in security | About one day |
| Resetting a password | Hash of the one-time token, its times | (b) performing the contract | 30 minutes, or until used or replaced |
| Understanding who uses Margin and how, and improving it | Sign-up survey (experience, how you found Margin, country, markets traded); age, time zone; the hours in which you were active and the number of requests in them; numbers of records you keep | (f) our legitimate interest in developing the service. Administrators see only totals and shares | Until the Account is deleted |
| Sending news and offers by email, if you agree | Email address, display name, date of consent | (a) your consent. You may withdraw it in Settings at any time, which does not affect earlier sending | Until you withdraw consent or the Account is deleted |
| Operating the server, investigating errors and attacks | Server logs: IP address, time, requested address, browser details, error messages | (f) our legitimate interest in security and reliability | [log retention period] |
| Backups, if used | Copies of the data above | (f) our legitimate interest in being able to restore the service | [backup retention period, or delete this row] |
| Handling messages, complaints, requests and notices of illegal content | What you send us, your contact details, our reply | (c) legal obligation, including consumer law, the GDPR and the DSA; (f) our legitimate interest in establishing or defending claims | Until claims may expire, generally up to 6 years |
Where we rely on legitimate interest, you may object (section 9). Please do not put special categories of data, such as health data, into Your Content, and make sure you may lawfully upload anything showing other people.
When an Account is deleted, the records above and the uploaded files are removed from the live system immediately, apart from the attempt records, which expire after about one day, and from server logs[, backups] and correspondence, which follow their own periods.
4. What you must provide
- Providing data is voluntary, but without the email address, password, display name and date of birth we cannot create an Account. The sign-up form currently also requires the survey answers and your country.
- Consent to news and offers is optional and does not affect your use of Margin.
- What you enter in your journal is up to you. Without it, the related functions will not show anything.
5. Who receives data
Data may be accessed by people who work for us, only as far as their tasks require, and by public authorities where the law requires it. Other recipients are:
| Recipient | When | What it receives | Role |
|---|---|---|---|
| [hosting provider, country] | Always | All data stored in Margin | Processor, under a contract with us |
| Google (Google Fonts) | When any page of Margin opens, including before sign-in, and when editors load more fonts | IP address, browser details, address of the page | Separate controller for its own processing. Basis on our side: (f) our legitimate interest in showing the site's typeface |
| Google (YouTube, through the youtube-nocookie.com address) | When you open a note or recap with an embedded video | IP address, browser details; it may store or read data in your browser, and may receive more if you play the video | Separate controller; we may be a joint controller only for making the transmission possible |
| X (platform.twitter.com) | When you open a note with an embedded post | IP address, browser details; it may store or read data in your browser | As for YouTube |
| Site from which you insert an image by link | When you insert it | Our server's address and the link, not your IP address | Separate controller |
Market charts on P&L cards are fetched by our server from a market data provider using the contract symbol and a time range. Your name and IP address are not sent. If an email provider or other processor is added, this Policy will be updated.
6. Transfers outside the EEA
- Google and X may process data in the United States and other countries outside the European Economic Area. Such transfers rely on a European Commission adequacy decision, including the EU-US Data Privacy Framework for certified recipients, or on standard contractual clauses. Details are available from those providers, and you can ask us for a copy of the safeguards we use.
- Our hosting: [state that data is stored in the EEA, or name the country and safeguard].
7. Cookies and browser storage
Margin stores a small amount of information in your browser, and does not use advertising or analytics cookies. The full list, the categories and the way to manage them are in the separate Cookie Policy.
Embedded YouTube videos and posts from X may store or read their own data in your browser, under those providers' policies.
8. Security
- Email addresses and dates of birth are encrypted with AES-256-GCM, and are found by a keyed fingerprint. Passwords are stored as Argon2id hashes. Session tokens are stored only as hashes. The keys are held outside the website folder. Other data, including your display name, survey answers and journal, is protected by access controls, not by separate field encryption.
- Connections use HTTPS, requests that change data are protected against forgery, and repeated sign-in attempts are limited.
- No system is completely secure. If a personal data breach is likely to result in a high risk to you, we will tell you without undue delay, and we report breaches to the supervisory authority as the GDPR requires.
9. Your rights
Subject to the conditions in the GDPR, you have the right to:
- obtain access to your data and a copy of it (Article 15);
- have inaccurate data corrected (Article 16);
- have data erased (Article 17);
- restrict processing (Article 18);
- receive the data you provided in a machine-readable format, and have it transmitted to another controller (Article 20);
- object at any time, on grounds relating to your situation, to processing based on legitimate interest, and object at any time to direct marketing (Article 21);
- withdraw consent at any time, without affecting earlier processing (Article 7(3)).
To use these rights, write to the address in section 1, using the email address of your Account where possible. It is free of charge, and we reply within one month, which can be extended by two months in complex cases. We may ask you to confirm your identity.
You may also complain to a supervisory authority. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw. You may also complain in the Member State where you live or work, or where an infringement took place.
10. Automated decisions
- We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, within the meaning of Article 22 GDPR.
- The statistics, Margin score, grades and rule checks are calculated from your entries for your own use. The automatic checks, which refuse sign-up under the age of 18 and temporarily limit repeated attempts, apply fixed rules. If you think a check is wrong, contact us and a person will look at it.
11. Age limit
Margin is intended for adults only. We do not knowingly process data of persons under 18. If you believe a minor has created an Account, please let us know and we will delete it.
12. Changes to this Policy
We update this Policy when our processing or the law changes. The version and date are shown at the top, and we tell you of material changes in Margin or by email before they apply. This Policy is available in Polish and English. If the versions differ, the Polish version prevails, unless mandatory law provides otherwise.
13. The Margin Discord server and bot
- This section applies if you join the Margin server on Discord, where our bot, Margin Bot, runs. Joining is optional and is not linked to a Margin Account. The bot does not read or receive your journal. Discord is a separate controller of the data it handles for its own platform, and its own terms and privacy policy apply to that.
- The bot processes your Discord user ID, username, display name, account creation date, the dates you join and leave the server, your server roles and the fact that you accepted the server rules and passed its check. The answers to that check are not stored. After too many wrong answers, a short waiting time is kept in the bot's memory until it ends or the bot restarts.
- To support moderation, the bot keeps recent messages in the channels it can access briefly in its memory. If such a message is edited or deleted, the bot copies its author, channel and text to a moderation log in a private staff channel on Discord. Warnings, timeouts, bulk deletions and their reasons are recorded there too. Messages in staff channels are not copied. If you are warned, the bot may send you a direct message.
- We do this to run the server, verify members and protect it from spam and abuse. The legal basis is our legitimate interest (Article 6(1)(f) GDPR). You may object at any time as described in section 9, and we will consider your objection against the need to keep the server safe.
- The bot has no database of its own. Roles last while you are a member of the server. Moderation log entries are kept as messages on Discord for [moderation log retention period].
- Moderators and administrators of the server can see the moderation log. The bot runs on [where the bot runs: provider, country]. Discord may process data outside the European Economic Area, as described in its privacy policy.
- You have the rights described in section 9. To use them for this data, write to the contact address in section 1 and include your Discord username. You can leave the server at any time, but this does not by itself remove earlier moderation log entries.