Privacy
Policy

1. Data Controller & Scope

This Privacy Policy describes how the individual operator of Algetris ("Operator", "we", "us"), based in the Republic of Poland, European Union, processes personal data in connection with the Algetris indicator and associated website (collectively, the "Service"). For all data protection matters, contact us at: contact@algetris.com.

This Policy applies to personal data processed directly by the Operator. It does not apply to data processed independently by TradingView, Inc. or Whop.com, each of whom acts as an independent data controller for data within their own systems and is subject to their own privacy policies. The Operator is not a party to, and accepts no responsibility for, data processing that occurs exclusively within those independent systems.

This Policy is issued pursuant to Art. 13 and Art. 14 RODO/GDPR (Regulation (EU) 2016/679) and applies to all data subjects whose personal data the Operator processes.

2. What Data We Collect

Data you provide directly

• Email address — provided at subscription purchase. Used to grant and manage TradingView indicator access, send subscription-related transactional communications, and respond to support requests;
• TradingView username — required to link your subscription to your TradingView account via TradingView's invite-only script access system;
• Support communications — content and metadata (date, subject) of any messages you send to us via email or the contact form.

Data collected automatically

• Technical infrastructure data — IP address, browser type, operating system, and standard HTTP request metadata, collected passively by Cloudflare as part of hosting and DDoS-protection operations. This data is processed on the Operator's behalf and is not used for profiling, analytics, or marketing.

Data we do NOT collect

• Payment card numbers, bank account details, or any other payment instrument data — these are collected exclusively and directly by Whop;
• TradingView account credentials or passwords;
• Trading activity, open positions, brokerage account data, or financial history of any kind;
• Behavioural analytics, visitor statistics, or usage data — we do not deploy any analytics platform, advertising pixel, behavioural tracking tool, or marketing tracker. The only automated data collection on our website is performed by Cloudflare infrastructure services (bot management, DDoS protection, rate limiting) as described in Section 5 and in our Cookie Policy;
• Special categories of personal data as defined in RODO Art. 9 (including health, biometric, political, religious, racial, or ethnic origin data);
• Personal data of persons under 18 years of age.

3. Legal Bases for Processing (RODO Art. 6)

• Performance of contract — Art. 6(1)(b): processing your email address and TradingView username to activate and manage subscription access, deliver transactional communications, and provide customer support. This basis applies from the moment of subscription purchase;
• Legitimate interests — Art. 6(1)(f): fraud prevention, abuse detection, and protection of the Service's integrity. We have conducted a legitimate interests assessment and determined that these interests are not overridden by your rights and freedoms, given the minimal data involved and the absence of profiling;
• Legal obligation — Art. 6(1)(c): compliance with applicable Polish and EU law, including lawful requests from competent public authorities;
• Consent — Art. 6(1)(a): where we send optional marketing communications, only upon your prior opt-in. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Where we rely on legitimate interests, you have the right to object at any time as described in Section 8.

4. How We Use Your Data

• Activating and managing your subscription access to the Algetris indicator via TradingView's invite-only script system;
• Sending transactional emails — subscription confirmation, renewal notices, access changes, and refund confirmations;
• Responding to support enquiries and customer service requests;
• Protecting the integrity and security of the Service against abuse and unauthorised access;
• Detecting and preventing fraud and violations of our Terms of Service;
• Complying with applicable legal and regulatory obligations.

We do not use your personal data for automated decision-making, profiling, behavioural advertising, or any purpose other than those listed above.

5. Data Sharing & Processors

We do not sell your personal data. We do not share personal data with advertisers, data brokers, social media platforms, or any unrelated third parties. Data is shared only with the processors and independent controllers listed below, under appropriate contractual and legal safeguards.

No other recipients receive your personal data. Sub-processors engaged by any of the above parties are governed by the contractual arrangements of those parties, for which they bear independent responsibility.

6. International Transfers

Processing of personal data by Whop, TradingView, and Cloudflare — all headquartered in the United States — may involve transfer of personal data outside the European Economic Area. Where such transfers occur, the Operator ensures that appropriate safeguards are in place pursuant to RODO Art. 46, specifically Standard Contractual Clauses (SCCs) approved by the European Commission under Decision 2021/914. Where an adequacy decision under RODO Art. 45 applies, reliance on that decision is noted in the table above.

You may request further information about applicable transfer mechanisms, including copies of relevant SCCs where these are in the Operator's possession, by contacting contact@algetris.com.

7. Data Retention

• Email address & TradingView username — retained for the duration of your active subscription and for 3 years after its termination, for legal, tax, and dispute-resolution purposes, after which data is permanently deleted;
• Support communications — retained for 2 years from the date of the last exchange, then permanently deleted;
• Infrastructure logs (Cloudflare) — retained by Cloudflare in accordance with their data retention policy; the Operator does not maintain separate copies of this data;
• Billing and payment records — retained exclusively by Whop in accordance with their policy and applicable Polish and EU tax law requirements (typically 5–7 years from the date of the transaction). The Operator does not hold copies of payment records.

Upon expiry of the applicable retention period, personal data is either permanently deleted or anonymised so that it can no longer be attributed to an identified or identifiable individual.

8. Your Rights (RODO Chapter III, Art. 15–22)

As a data subject under RODO/GDPR, you have the following rights in respect of personal data processed by the Operator:

• Right of access — Art. 15: obtain confirmation of whether we process your personal data and, if so, receive a copy of it together with information about the processing;
• Right to rectification — Art. 16: request correction of inaccurate personal data or completion of incomplete personal data we hold about you;
• Right to erasure ("right to be forgotten") — Art. 17: request deletion of your personal data where the data is no longer necessary for the purpose for which it was collected, subject to any overriding legal retention obligations (such as applicable tax law);
• Right to restriction of processing — Art. 18: request that we restrict processing of your personal data in certain circumstances, including while a rectification or objection request is being assessed;
• Right to data portability — Art. 20: receive the personal data you have provided to us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible and where processing is based on contract or consent;
• Right to object — Art. 21: object at any time to processing based on legitimate interests (Art. 6(1)(f)); we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims;
• Right to object to direct marketing — Art. 21(2): object at any time to processing for direct marketing purposes, including any associated profiling. Upon such objection, processing for this purpose ceases immediately;
• Right to withdraw consent — Art. 7(3): where processing is based on your consent (e.g. marketing communications), withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Right not to be subject to solely automated decision-making — Art. 22: we do not carry out automated individual decision-making or profiling that produces legal effects or similarly significantly affects you;
• Right to non-discrimination: exercising any of the rights above will not result in any denial of service, reduction in service quality, or any other form of disadvantage in your access to the Algetris indicator.

To exercise any of these rights, contact us at contact@algetris.com with a description of your request and sufficient identifying information for us to verify your identity. We will acknowledge receipt within 72 hours and respond within 30 days, extendable by a further 60 days for complex or multiple requests, with prior written notice.

We may ask you to verify your identity before processing your request in order to protect against unauthorised access to your data.

You also have the right to lodge a complaint with the Polish supervisory authority: Urząd Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl, tel. +48 22 531 03 00. If you reside in another EU/EEA member state, you may alternatively lodge a complaint with the supervisory authority in your country of residence.

9. Security & Breach Notification

The Operator implements appropriate technical and organisational security measures to protect personal data against unauthorised access, loss, alteration, or unlawful disclosure. These measures include encrypted transmission (HTTPS/TLS), access controls, secure infrastructure via Cloudflare, and strict data minimisation — limiting collection to only what is necessary for the stated purposes.

No method of electronic storage or internet transmission is completely secure, and the Operator cannot guarantee absolute security against all possible threats.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, the Operator will:

• Notify the Polish supervisory authority (UODO) without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with RODO Art. 33;
• Where the breach is likely to result in a high risk to your rights and freedoms, notify you directly without undue delay by email to the address we hold on file, in accordance with RODO Art. 34;
• Maintain an internal record of all personal data breaches, including those not meeting the notification threshold, in accordance with RODO Art. 33(5).

The Operator's breach notification obligations apply exclusively to breaches occurring within systems directly under its control. Breaches occurring within the independent systems of Whop, TradingView, or Cloudflare are the responsibility of those entities, and you should refer to their respective breach notification procedures in such cases.

10. Cookies

The Algetris website uses a strictly limited set of cookies and similar technologies. We use only strictly necessary cookies — specifically, a consent-preference cookie (algetris_consent) and security and infrastructure cookies set by Cloudflare, Inc. (our processor) for bot management, DDoS protection, and rate limiting.

We do not use analytics cookies, advertising cookies, behavioural tracking cookies, social media pixels, or any other non-essential cookies. No consent is required for the cookies deployed on this website, as they all fall within the strictly necessary category under Art. 5(3) of the ePrivacy Directive and are processed on the basis of legitimate interests under RODO Art. 6(1)(f). The cookie notice displayed on your first visit is therefore informational only and does not require an active opt-in selection.

When you access the Whop payment interface (during checkout or subscription management), Whop.com may set their own cookies. Whop acts as an independent data controller for all data it collects; those cookies are governed by Whop's own Privacy Policy and are outside the Operator's control.

For full details — including a complete list of all cookies used, their purposes, duration, provider roles, and legal basis — see our Cookie Policy.

11. Children's Privacy

The Service is not directed at persons under the age of 18. The Operator does not knowingly collect personal data from minors. If you are a parent or guardian and believe that a person under 18 has provided personal data to us, please contact us at contact@algetris.com and we will take prompt steps to delete such data.

12. Notice for California Residents (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and, where applicable, the California Privacy Rights Act (CPRA). The Operator does not sell or share personal information as defined under the CCPA. The Operator does not use personal information for cross-context behavioural advertising. To exercise your rights of access, deletion, or correction under California law, please use the contact details in Section 15. We will not discriminate against you for exercising your privacy rights.

13. Third-Party Links & External Services

The Algetris website and related communications may contain links to third-party websites and services, including TradingView and Whop. Such links are provided for informational purposes only. The Operator has no control over, and accepts no responsibility for, the data processing practices of any third-party website or service. We strongly encourage you to review the privacy policies of any third-party services you access.

Your use of TradingView is governed exclusively by TradingView's own Privacy Policy and Terms of Service. Your use of Whop's payment services is governed exclusively by Whop's own Privacy Policy and Terms of Service. The Operator is not a party to any data processing that occurs exclusively within those independent systems.

14. Changes to This Policy

The Operator may update this Privacy Policy from time to time to reflect changes in processing practices, applicable legal requirements, or the scope of the Service. Material changes will be communicated by email to your registered address and/or by a prominent notice on the website at least 14 days before taking effect. The "Effective date" at the top of this document reflects the date of the last revision.

Where required by applicable law, material changes to processing activities that require renewed consent will be communicated separately, and continued use of the Service will not constitute consent to such changes.

15. Contact

For all privacy-related enquiries, data subject rights requests, complaints, or questions regarding this Privacy Policy, contact us at:
contact@algetris.com