Privacy Policy

1. Introduction

This Privacy Policy describes how VENUS LABS S.R.L. (VAT IT04090370364), with registered office at Via Pasubio 3, Bomporto, MO 41030, Italy (hereinafter "ShowMyTrades", "we", "us", or "our"), collects, uses, stores, and protects your personal data when you use our trading analytics platform and related services (the "Service").

We are committed to protecting your privacy and complying with:

The General Data Protection Regulation (GDPR) - EU Regulation 2016/679
Italian Legislative Decree No. 196/2003 (Privacy Code) as amended
All applicable data protection laws and regulations

Data Controller: VENUS LABS S.R.L., Via Pasubio 3, Bomporto, MO 41030, Italy

Contact: support@showmytrades.com

2. Personal Data We Collect

2.1 Information You Provide Directly

When you create an account and use ShowMyTrades, we collect:

Account Information: Email address, password (encrypted), username, profile picture (optional)
Trading Account Credentials: MetaTrader 4, MetaTrader 5, or NinjaTrader API keys, account numbers, broker information
Profile Information: Bio, social media links, trading style, experience level (all optional)
Communication Data: Messages, comments, support requests, feedback
Payment Information: If you subscribe to paid plans (when available), billing address, payment method details (processed by third-party payment processors - we do not store credit card numbers)

2.2 Trading Data Automatically Collected

When you connect your trading accounts, we automatically collect and process:

Trade History: Open/closed positions, entry/exit prices, lot sizes, profit/loss, trade duration
Account Metrics: Balance, equity, margin, free margin, account leverage
Performance Statistics: Win rate, profit factor, Sharpe ratio, maximum drawdown, recovery factor, and 20+ calculated metrics
Time-Series Data: Balance history, equity curves, monthly returns

2.3 Technical and Usage Data

We automatically collect information about how you access and use the Service:

Device Information: Device type, operating system, browser type and version, screen resolution
Connection Data: IP address, internet service provider, approximate location (country/city level)
Usage Analytics: Pages visited, features used, time spent on platform, click patterns, navigation paths
Cookies and Tracking: Session cookies, preference cookies, analytics cookies (see Section 9 - Cookie Policy)
Log Data: Server logs, error reports, API requests, timestamps

2.4 Data from Third Parties

We may receive data from:

Trading Platforms: MetaTrader servers, NinjaTrader APIs, broker data feeds
Analytics Providers: Google Analytics, usage statistics, performance metrics
Social Media: If you choose to link social accounts, public profile information
Affiliate Partners: Referral information, campaign performance data

3. Legal Basis for Processing (GDPR Compliance)

Under GDPR Article 6, we process your personal data based on the following legal grounds:

3.1 Contractual Necessity (Art. 6(1)(b) GDPR)

Processing is necessary to provide the Service you requested:

Creating and managing your account
Syncing and analyzing your trading data
Generating performance statistics and charts
Displaying your public profile
Processing payments (when applicable)

3.2 Legitimate Interest (Art. 6(1)(f) GDPR)

We have a legitimate interest in:

Improving and optimizing the Service
Detecting and preventing fraud, abuse, or security threats
Analyzing usage patterns to enhance user experience
Sending important service updates and security notifications
Conducting research and development

We balance our interests against your rights and freedoms. You can object to processing based on legitimate interest (see Section 7 - Your Rights).

3.3 Consent (Art. 6(1)(a) GDPR)

We ask for your explicit consent for:

Marketing communications and newsletters
Non-essential cookies (analytics, advertising)
Sharing data with third-party partners beyond what's necessary for the Service

You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

3.4 Legal Obligation (Art. 6(1)(c) GDPR)

Processing may be required to comply with:

Tax and accounting regulations
Anti-money laundering (AML) laws
Court orders, legal proceedings, or regulatory requests

4. How We Use Your Personal Data

We use your data for the following purposes:

4.1 Core Service Delivery

Authenticating and managing your account
Syncing trading data from MetaTrader and NinjaTrader accounts in real-time
Calculating advanced trading statistics and performance metrics
Generating charts, graphs, and visual analytics
Creating and displaying your public or private profile page
Enabling community features (comments, messages, following)

4.2 Service Improvement and Analytics

Analyzing usage patterns to improve features and user experience
Conducting A/B tests and product experiments
Identifying and fixing bugs, errors, and performance issues
Developing new features and services

4.3 Security and Fraud Prevention

Detecting suspicious activity, fraud, or policy violations
Preventing unauthorized access and data breaches
Verifying account authenticity and preventing fake accounts
Enforcing our Terms of Service

4.4 Communication

Sending transactional emails (account verification, password resets, security alerts)
Responding to your support requests and inquiries
Notifying you of important updates, policy changes, or service announcements
Sending marketing communications (only with your consent)

4.5 Legal and Compliance

Complying with legal obligations and regulatory requirements
Responding to lawful requests from authorities
Protecting our rights, property, and safety
Enforcing legal agreements and resolving disputes

4.6 Research and Aggregated Analytics

Creating anonymized, aggregated statistics about trading performance trends
Publishing industry insights and research (no personally identifiable information)
Benchmarking performance across different trading strategies

6. Data Storage, Security, and Retention

6.1 Data Location

All personal and trading data is stored exclusively in the European Union:

Primary data centers: Germany, France, Italy
Backup servers: Within the EU
No data transfer outside the EU/EEA

This ensures full compliance with GDPR data transfer restrictions.

6.2 Security Measures

We implement industry-standard security practices to protect your data:

Encryption: Data encrypted in transit (TLS 1.3) and at rest (AES-256)
Access Controls: Role-based access control (RBAC), least privilege principle
Row-Level Security (RLS): Database-level access controls ensure users can only access their own data
Authentication: Secure password hashing (bcrypt), multi-factor authentication (coming soon)
API Security: Rate limiting, API key rotation, secure token storage
Monitoring: Intrusion detection, security audits, vulnerability scanning
Backups: Regular automated backups with encryption

However, no security system is 100% impenetrable. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

6.3 Data Retention

We retain your personal data for as long as necessary to provide the Service and comply with legal obligations:

Active Accounts: Data retained for the duration of your account lifetime
Deleted Accounts: Most data deleted within 30 days
- Some data may be retained for up to 90 days in backups
- Aggregated, anonymized data may be retained indefinitely for analytics
Financial Records: Billing and transaction data retained for 10 years (Italian tax law requirement)
Legal Holds: Data may be retained longer if required for legal proceedings or regulatory investigations
Support Communications: Support tickets and correspondence retained for 2 years

6.4 Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms:

We will notify the relevant supervisory authority within 72 hours (GDPR requirement)
We will notify affected users via email without undue delay
We will provide details about the nature of the breach, data affected, and remedial actions

7. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

7.1 Right to Access (Art. 15 GDPR)

You can request:

Confirmation of whether we process your personal data
A copy of all personal data we hold about you
Information about how we use, store, and share your data

How to exercise: Email support@showmytrades.com with subject "Data Access Request"

7.2 Right to Rectification (Art. 16 GDPR)

You can request correction of inaccurate or incomplete personal data.

How to exercise: Update your profile settings or contact support@showmytrades.com

7.3 Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR)

You can request deletion of your personal data in certain circumstances:

Data is no longer necessary for the purpose it was collected
You withdraw consent (where consent was the legal basis)
You object to processing based on legitimate interest
Data was unlawfully processed

How to exercise: Delete your account in settings or email support@showmytrades.com

Limitations: We may retain data when required by law or for legal claims.

7.4 Right to Restriction of Processing (Art. 18 GDPR)

You can request that we limit how we use your data in certain cases:

You contest the accuracy of data (during verification period)
Processing is unlawful, but you don't want erasure
We no longer need the data, but you need it for legal claims
You object to processing (pending verification of our legitimate grounds)

7.5 Right to Data Portability (Art. 20 GDPR)

You can request your data in a structured, machine-readable format (JSON, CSV) to transfer to another service.

How to exercise: Email support@showmytrades.com with subject "Data Portability Request"

Response time: We will provide your data within 30 days.

7.6 Right to Object (Art. 21 GDPR)

You can object to:

Processing based on legitimate interest
Direct marketing communications
Profiling or automated decision-making

How to exercise: Email support@showmytrades.com or use unsubscribe links in marketing emails

7.7 Right to Withdraw Consent (Art. 7(3) GDPR)

Where processing is based on consent, you can withdraw consent at any time:

Marketing emails: Click "unsubscribe" in any email
Cookies: Adjust settings in cookie banner or browser
Data sharing: Contact support@showmytrades.com

7.8 Right to Lodge a Complaint

If you believe we have violated your data protection rights, you can file a complaint with:

Italian Data Protection Authority (Garante per la Protezione dei Dati Personali)
- Website: www.garanteprivacy.it
- Email: garante@gpdp.it
- Phone: +39 06 696771
Your local EU/EEA data protection authority

7.9 Response Time

We will respond to all valid GDPR requests within 30 days (may be extended to 60 days for complex requests). We will keep you informed of any delays.

8. International Data Transfers

We do NOT transfer personal data outside the European Union or European Economic Area (EU/EEA).

All data is stored and processed exclusively within EU data centers (Germany, France, Italy).

Exception: If you access ShowMyTrades from outside the EU:

Your data will still be stored in the EU
Data transmission between your device and our servers is encrypted
By using the Service from outside the EU, you consent to this data transfer

If we ever need to transfer data outside the EU in the future, we will:

Notify you in advance
Use Standard Contractual Clauses (SCCs) approved by the European Commission
Ensure adequate safeguards are in place (GDPR Art. 46)
Obtain your explicit consent where required

9. Cookie Policy

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help us provide, improve, and secure the Service.

9.2 Types of Cookies We Use

Essential Cookies (Always Active)

These cookies are necessary for the Service to function and cannot be disabled:

Authentication: Keep you logged in
Security: Prevent fraud and protect your account
Session Management: Maintain your preferences during your session

Analytics Cookies (With Your Consent)

These cookies help us understand how users interact with ShowMyTrades:

Google Analytics: Page views, user flows, feature usage
Performance Monitoring: Load times, errors, API response times
A/B Testing: Feature experiments and user experience optimization

Preference Cookies

These cookies remember your choices:

Dark mode / light mode preference
Language settings
Chart display preferences

9.3 Third-Party Cookies

We use cookies from:

Google Analytics: Usage analytics and traffic analysis
Supabase: Authentication and session management

These third parties have their own privacy policies. We do not control their cookies.

9.4 Managing Cookies

You can control cookies through:

Cookie Banner: Accept or reject non-essential cookies when you first visit
Browser Settings: Block or delete cookies in your browser preferences
Opt-Out Tools: Use Google Analytics opt-out browser add-on

Note: Disabling essential cookies may prevent you from using certain features of the Service.

9.5 Do Not Track (DNT)

We respect browser Do Not Track signals. When DNT is enabled, we:

Disable non-essential tracking cookies
Limit data collection to essential functions only

10. Children's Privacy

ShowMyTrades is NOT intended for children under 18 years of age.

We do not knowingly collect personal data from children under 18
If you are under 18, do not create an account or provide any personal data
If we discover that we have collected data from a child under 18, we will delete it immediately

Parents/Guardians: If you believe your child has provided personal data to ShowMyTrades, contact us at support@showmytrades.com and we will delete it.

11. Automated Decision-Making and Profiling

We do NOT use automated decision-making or profiling that produces legal effects or significantly affects you.

However, we use limited automated processing for:

Fraud Detection: Algorithms flag suspicious accounts or activity for manual review
Spam Prevention: Automated filters detect spam comments or messages
Content Recommendations: Suggest traders to follow based on your activity

You always have the right to:

Request human intervention
Express your point of view
Contest any automated decision

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

Changes in our data practices
New features or services
Legal, regulatory, or operational requirements

When we make changes:

We will update the "Last Updated" date at the top
We will notify you via email for material changes
We may display a prominent notice on the Service
Continued use after changes constitutes acceptance

If changes significantly reduce your rights: We will obtain your explicit consent before applying the new policy.

We recommend reviewing this Privacy Policy periodically.

13. Contact Information and Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Data Controller:

VENUS LABS S.R.L.

Via Pasubio 3
Bomporto, MO 41030
Italy

VAT Number: IT04090370364

Email: support@showmytrades.com

Website: https://showmytrades.com

13.1 GDPR Requests

To exercise your GDPR rights (access, erasure, portability, etc.), email us at:

support@showmytrades.com

Subject line: [GDPR Request] - [Type of Request]

Example: [GDPR Request] - Data Access Request

We will respond within 30 days.

13.2 Complaints

If you are not satisfied with our response, you can file a complaint with:

Garante per la Protezione dei Dati Personali (Italian Data Protection Authority)
- Website: www.garanteprivacy.it
- Email: garante@gpdp.it

14. Additional Information for EU Residents

14.1 Legal Representative

VENUS LABS S.R.L. is established in Italy (EU member state) and is subject to Italian and EU data protection laws.

14.2 Data Protection Impact Assessment (DPIA)

We have conducted a Data Protection Impact Assessment for high-risk processing activities to ensure:

Proportionality of data collection
Necessity of processing operations
Adequacy of security measures
Compliance with GDPR principles

14.3 Data Processing Records

We maintain internal records of all processing activities as required by GDPR Article 30.

15. Quick Summary

🔒 Your Privacy at a Glance:

✅ We do NOT sell your data
✅ Data stored exclusively in EU (Germany, France, Italy)
✅ GDPR compliant - full data rights respected
✅ Bank-level encryption (TLS 1.3, AES-256)
✅ You control your data - delete anytime
✅ Transparent processing - clear legal basis
⚠️ Profiles public by default - change in settings
📧 Contact us: support@showmytrades.com

This Privacy Policy is effective as of October 21, 2025.

We are committed to protecting your privacy and complying with GDPR and Italian data protection laws.