Privacy Policy for Forgalis TradingJournal

1. Who we are and what this policy covers

Forgalis AB is the data controller for the personal data described in this policy.

This policy applies to Forgalis TradingJournal, a Windows desktop trading journal distributed through Microsoft Store. The general Forgalis website has a separate privacy policy.

2. Privacy summary

• Your journal database, screenshots, notes, backups and exports remain on your computer unless you choose to move or share them.
• Forgalis does not provide cloud storage or synchronisation for journal data.
• FTJ does not send usage analytics, journal data or crash reports to Forgalis.
• Internet access is used for distribution, licensing and optional services that you choose to use.

3. Local journal data

FTJ stores journal information in a local database on your computer. Depending on how you use the application, it may contain account information, trades, executions, prices, timestamps, broker references, profit and loss, costs, screenshots, notes, strategies, review fields, exchange rates and local import settings.

Application preferences, backups and exports are also stored locally on your computer.

FTJ does not upload this local journal data to Forgalis. The data remains on your computer until you edit or delete the records or manage the related database, backup and export files.

4. Optional imports and external data services

MetaTrader 4 and MetaTrader 5

FTJ reads available account history through the selected MetaTrader terminal on your computer. The terminal may remain connected to your broker while FTJ communicates with it locally. Selected records are stored in your local journal and are not routed through a Forgalis journal-data service.

cTrader

The optional cTrader integration uses cTrader's authorisation and API services. When you connect an account, your browser opens cTrader's authorisation page and FTJ can retrieve the account and execution-history information you authorise.

FTJ does not store your cTrader password. Authorisation tokens are protected locally for the current Windows user. The account and execution-history information you authorise is transferred between your computer and cTrader, then stored in your local journal. It is not routed through a Forgalis journal-data service.

CSV imports

FTJ processes the CSV file you select on your computer. Selected records are stored in your local journal, and the file contents are not uploaded to Forgalis.

Exchange rates

When you choose to fetch exchange rates, FTJ sends the requested date and currency codes to the Frankfurter exchange-rate service. The provider also receives normal technical connection information, such as the IP address. Your journal database, notes and screenshots are not included in these requests.

These optional services are initiated by you to provide the requested application feature. The relevant external provider processes information under its own privacy terms.

5. Full Access licensing and purchases

The Demo can be used without a licence key. Full Access purchases, activation and periodic licence validation are handled through Freemius.

Licensing requests can include:

• the licence key;
• product and installation identifiers;
• a pseudonymous identifier derived from the Windows device and user environment; and
• licence status and subscription information.

These requests do not include journal records, screenshots, notes or the journal database.

During checkout, Freemius and its payment providers may process contact, billing, transaction, payment-method and technical connection information. Payment-card details are not collected inside FTJ. Forgalis may receive the customer, purchase, subscription, transaction and licence information needed to provide Full Access, maintain accounting records and answer support enquiries.

Freemius may send transactional messages, such as receipts, licence information and renewal notices. It may also send other communications where permitted under its privacy terms and the preferences you provide.

Freemius Inc. is located in the United States, so personal data may be transferred outside the EU/EEA. Where required, these transfers are protected by the European Commission's Standard Contractual Clauses. You may contact Forgalis for more information about the safeguards.

The legal basis is:

• Article 6(1)(b) GDPR to provide and administer Full Access and the customer relationship;
• Article 6(1)(c) GDPR where records must be retained for accounting, tax or another legal obligation; and
• Article 6(1)(f) GDPR for security, misuse prevention and general support, based on our legitimate interest in protecting the service and assisting users.

Full Access cannot be activated or validated without the required licence information.

6. Support and diagnostic information

FTJ creates local technical logs when certain errors or licensing problems occur. These logs remain on your computer unless you choose to provide them to support.

When you contact Forgalis for support, we process your message and any screenshots, logs or other files you choose to send. Before sharing screenshots or other user-selected files, make sure they contain only the information relevant to the issue.

We use support information to investigate and answer the request, provide support and manage the customer relationship. The legal basis is Article 6(1)(b) GDPR for contractual support or Article 6(1)(f) GDPR for general troubleshooting and communication.

Support messages are kept only for as long as needed to handle the enquiry, provide follow-up support, manage disputes or legal claims and meet applicable legal obligations.

Providing diagnostic information is voluntary, but we may be unable to investigate an issue without enough relevant detail.

7. Microsoft Store and Windows

Microsoft Store handles distribution and application updates. Microsoft processes information connected with Store use under the Microsoft Privacy Statement.

Windows may separately collect diagnostic or error information according to your Windows settings and Microsoft's policies. This information is handled by Windows and Microsoft, separately from the local technical logs created by FTJ.

8. Recipients and international transfers

Depending on the features you use, relevant external providers can include:

• Freemius for checkout, billing, customer services and licensing;
• cTrader for the account and execution-history access you authorise;
• Frankfurter for optional exchange-rate requests;
• Microsoft for Store distribution, updates and Windows platform services; and
• hosting and email providers when you contact Forgalis.

FTJ communicates locally with the selected MT4 or MT5 terminal, while CSV files are processed on your computer. Neither workflow uses a Forgalis-hosted journal-data service.

Some providers may process information outside Sweden or the EU/EEA. Where required, international transfers are protected by an applicable legal mechanism, such as an adequacy decision or the European Commission's Standard Contractual Clauses.

You may contact Forgalis for more information about safeguards that apply to personal data for which Forgalis is responsible.

9. Retention

• Local journal data remains on your computer until you edit or delete the records or remove the related database, backup, export or application files.
• Support correspondence is retained only while needed to handle the enquiry, provide follow-up support, manage disputes or legal claims and meet applicable obligations.
• Customer and licence information is retained while needed to provide Full Access, manage the relationship, protect legal rights and meet applicable obligations.
• Accounting records, including relevant transaction records, are retained for the period required by Swedish law.
• External providers apply their own retention rules to information they process through their services.

10. Your rights

Depending on the circumstances, you may have the right to:

• access personal data processed by Forgalis and receive a copy;
• correct inaccurate data;
• request deletion or restriction;
• object to processing based on legitimate interests;
• receive certain data in a portable format; and
• withdraw consent where processing is based on consent.

Most journal content is stored only on your computer and is not held by Forgalis. Requests to Forgalis can therefore cover only information that Forgalis actually holds or controls, such as support correspondence and customer or licence information received through service providers.

Contact contact@forgalis.com to exercise a right. We may need information to verify your identity.

You may also lodge a complaint with the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (IMY).

11. Changes and contact

We may update this policy when FTJ, its integrations, service providers or legal requirements change. The current version will show its latest update date.

Questions about this policy can be sent to contact@forgalis.com or by post to Forgalis AB at the address above.