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, NinjaTrader, cTrader, or TradeLocker API keys, OAuth access tokens, 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 (including through our Expert Advisor installed on your MetaTrader platform), 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
• Symbol and Cost Data: Symbol information, contract specifications, swap rates, spreads, commissions, and other trading-related information available in your MetaTrader terminal
• Trade Annotations and Identifiers: Magic numbers, expert advisor or strategy identifiers, order comments, and any labels, tags, or notes you (or your trading platform) attach to trades or accounts
• 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

If you do not agree with this data collection, you can remove our Expert Advisor from your MetaTrader platform at any time and delete your trading account from ShowMyTrades: deleting the trading account permanently deletes all data we have collected from it.

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, cTrader Open API, TradeLocker API, broker data feeds
• Analytics Tools: Usage statistics and performance metrics from our self-hosted analytics tools (Plausible, Umami)
• 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)
• Providing a free, discounted or sponsored plan you requested through a Partner, and attributing you to that Partner (see Section 5.3b)

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
• Running transparent and verifiable referral, affiliate and partner programs: verifying attribution, calculating commissions and fees, reporting to Partners and preventing abuse (see Sections 5.3 and 5.3b)

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
• Sharing the trading data, metrics and statistics of your private trading accounts with the Partner or affiliate through which you joined or activated a benefit (consent given at sign-up through the Partner or at activation; see Section 5.3b)

You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Withdrawing the consent given for a Partner may end the free, discounted or sponsored plan linked to that Partner, never your account (Section 5.3b).

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, NinjaTrader, cTrader, and TradeLocker 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

Aggregated statistics never identify you. Content you have chosen to make public (public accounts, portfolios, and profiles) may instead be displayed in identifiable form within the Service, including in search, discovery, and community features.

4.7 Promotional and Advertising Use of Public Content

Where you have chosen to make an account, portfolio, or profile public, we may use that public content (including trading statistics, charts, username or brand name, avatar, and screenshots of your public pages) in our own marketing and advertising: paid advertising campaigns, social media posts, newsletters, blog articles, presentations, and other promotional material, online or offline.

• Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in promoting the Service using content you have already published, balanced against your rights and freedoms
• Non-public data is never used for advertising: private or unlisted accounts, private portfolios, email address, credentials, and messages are excluded
• Non-public data may only be used for these purposes in anonymized, aggregated form (see Section 4.6)
• You can object at any time (Art. 21 GDPR) by setting your account or profile to private or unlisted, or by writing to support@showmytrades.com. We will stop using your content in new material; material already published or distributed may not be immediately recallable

5. Data Sharing and Third Parties

5.1 Service Providers and Processors

We share data with trusted third-party service providers who help us operate the Service:

• Supabase (Database and Authentication): Stores user accounts, trading data, and manages authentication
  • Self-hosted infrastructure in the European Union (Germany, France, Italy)
  • GDPR-compliant data processing
• Cloud Hosting Providers: Server infrastructure, content delivery networks (CDN)
  • Data stored exclusively in EU data centers
• Analytics Services: Self-hosted Plausible and Umami analytics
  • Cookieless, privacy-friendly analytics running on our own EU servers
  • No usage data is shared with external analytics companies
• Cloudflare Turnstile: Bot protection on forms (processes technical data such as your IP address to distinguish humans from bots)
• Payment Processors: Stripe, PayPal (when paid plans are available)
  • PCI-DSS compliant
  • We do not store credit card information
• Email Service Providers: Transactional and marketing emails

All service providers are contractually bound to:

• Process data only as instructed by ShowMyTrades
• Implement appropriate security measures
• Comply with GDPR and applicable data protection laws
• Not use your data for their own purposes

5.2 Business Partners and Affiliates

We may share limited data with:

• Broker Partners: If you connect a trading account through a referral or affiliate link
• Marketing Partners: Aggregated, anonymized performance data for joint marketing efforts
• API Partners: Third-party applications you authorize to access your ShowMyTrades data

We will notify you and obtain consent before sharing data with partners beyond what's necessary for the Service.

If you joined ShowMyTrades, or activated a benefit, through a Partner or affiliate, the data that Partner can see about you and your trading accounts is described in detail in Section 5.3b.

Affiliate Links and Broker Suggestions

We may display broker-related suggestions (such as potential cost savings calculated from your own trading data). These may contain affiliate links: if you click them and open an account with a broker, we may receive a commission, at no additional cost to you.

• We do not share your personal data or trading data with the broker when you click an affiliate link
• We record your interactions with these suggestions (views, clicks, dismissals) to measure and improve the feature
• You can permanently opt out of broker suggestions directly from the banner

5.3 Referral Program and Invited Users

If you register through another user's referral link or invitation, we disclose a limited set of information about you to the user who invited you, and, where an affiliate or partner program applies, to the affiliate whose link you used:

• Display name and profile picture: the name shown on your profile, which may be your first and last name if you signed up with Google
• Registration date: the day you created your ShowMyTrades account
• Referral qualification status: whether you have connected a live (non-demo) trading account, and whether that account has reached at least 20 closed trades

We never disclose to them your email address, your trading data, your performance, your balance, your broker or your account numbers. This disclosure is limited to what is necessary to operate the referral program and to allow rewards to be earned and verified, and is based on our legitimate interest (Art. 6(1)(f) GDPR) in running a transparent referral program. You can change your display name and profile picture at any time in your account settings.

Exception: business partners and affiliates. The limits above describe referrals between ordinary users. Where the person or company that referred you is a Partner of ShowMyTrades under a commercial agreement (an affiliate paid on commission, a partner that offers a free or discounted plan to its clients, a white-label partner or a partner that pays for its clients' plans), a broader set of data (including data about your connected trading accounts, even private ones) may be shared with that Partner. Section 5.3b explains exactly what, why, on which legal basis, and how to stop it.

5.3b Partners and Affiliates Who Referred You: Extended Data Sharing

Who this section applies to

ShowMyTrades works with third parties (“Partners”) under commercial agreements. Partners can be, for example, brokers, VPS and hosting providers, proprietary trading firms, trading educators, signal or copy-trading services, software vendors, communities and content creators. The agreements take, among others, the following forms:

• Affiliates: the Partner earns a commission on payments made by the users it refers to us;
• Free-plan partners: the Partner obtains a free or discounted ShowMyTrades plan for its own clients (for example a VPS provider whose clients receive ShowMyTrades Pro at no cost);
• White-label partners: the Partner offers ShowMyTrades, in whole or in part, under its own brand;
• Sponsoring partners: the Partner pays ShowMyTrades for the plans of its clients.

This section applies whenever you are attributed to a Partner. You become attributed to a Partner when you create your account, or activate a Partner benefit, through any of the following: a referral or tracking link of the Partner; a co-branded or partner page on our website (for example /partners/<partner>); a widget, banner, page or profile of the Partner embedded on the Partner's site or on ours; a referral code, invitation or activation initiated by the Partner; or a Partner-operated white-label version of the Service. Existing users who activate a Partner benefit (for example a free plan offered by a Partner to its clients) are attributed to that Partner from the moment of activation, and everything in this section applies to them from that moment onwards.

What the Partner can see or receive

Depending on the agreement, the Partner can see that you are its client or referred user and may receive from us, on an ongoing basis for as long as the attribution lasts, personal data about you and about your connected trading accounts, including, but not limited to:

• Identity and contact data: your name and display name, profile picture, email address, country, preferred language and time zone;
• Account data: the date you registered, the date you were attributed to the Partner, your active plan, the status of any free, discounted or sponsored plan (activated, active, ended), and the identifiers we use to reference your account;
• Connected trading accounts: for each trading account you connect (whether it is public, unlisted or private on ShowMyTrades), the broker, trading server, account number or login, platform, account type (real or demo), currency, leverage, connection method, and the dates it was added or removed;
• Trading metrics and statistics, including for PRIVATE accounts: balance, equity, deposits and withdrawals, profits and losses (realised and floating), gain and return figures, drawdown, trading volume and lots (in total, per period (day, week, month, year) and per instrument or symbol), number of trades, win rate and other performance ratios, trade history and open positions (instrument, direction, size, open and close times and prices, commissions and swaps), trading hours and days of activity, magic numbers and strategy labels, and the charts and tables we build from this data;
• Technical and usage data: whether and how your accounts are connected (Expert Advisor, investor password, API), whether your terminal runs on a VPS and which one, the IP address and location from which your trading data reaches us, terminal and EA version and status, your last login, and your activity on the Service that relates to the Partner benefit (for example accounts added or removed, plan activated or ended);
• Aggregated, derived and summary data: totals, averages, rankings, reports and dashboards computed from any of the above, for you alone or together with other users referred by the same Partner.

The exact scope depends on the Partner and on the agreement. Some Partners only see that you registered through them; others (typically free-plan and sponsoring partners, whose agreement with us depends on the trading volume or activity of their clients) receive detailed, regularly updated information about your connected accounts. Where we operate a dedicated Partner dashboard or report, the Partner may consult this data at any time while you are attributed to it. Data marked as private on ShowMyTrades is not made public by this sharing: it is disclosed to the Partner only, under the obligations described below.

Why we share it (purposes)

• Managing the partnership agreement: verifying that you are a client or referred user of the Partner; activating, verifying, renewing, suspending or ending the free, discounted or sponsored plan linked to the Partner; checking eligibility conditions agreed with the Partner (for example a minimum trading activity or the fact that you remain the Partner's client);
• Commissions, rebates and settlements: calculating, checking and settling commissions, rebates, sponsorship fees or any other consideration between us and the Partner;
• Reporting to the Partner: providing the Partner with individual and aggregated reports about the users it referred and their trading activity on the connected accounts, so that the Partner can evaluate and run the partnership;
• Joint support: helping you when your issue concerns both ShowMyTrades and the Partner (for example a plan that should be free and is not, or a VPS terminal that stopped sending data);
• Preventing abuse: detecting and preventing fraud, self-referrals, duplicate accounts, misuse of free or sponsored plans, and breaches of our Terms or of the Partner's terms.

Legal basis

• Performance of a contract (Art. 6(1)(b) GDPR): for the data needed to provide the plan, discount or benefit you requested through the Partner, and to attribute you to the Partner whose link, page, code or invitation you used;
• Legitimate interest (Art. 6(1)(f) GDPR): for verifying attribution, calculating and settling commissions and fees, basic reporting to the Partner, joint support and abuse prevention. Our legitimate interest is running transparent, verifiable partner programs; the Partner's legitimate interest is knowing which of its clients use the Service it promotes or pays for. You may object at any time (Section 7.6);
• Your consent (Art. 6(1)(a) GDPR): for sharing with the Partner the trading data, metrics and statistics of your private trading accounts, and any other data beyond what the contract and our legitimate interest require. You give this consent when you create your account through the Partner, or when you activate the Partner benefit, after having been informed of this Privacy Policy.

Withdrawing your consent. You can withdraw your consent at any time by writing to support@showmytrades.com (or, where available, from the partner settings of your account). Withdrawal takes effect for the future: it stops any further sharing of your private trading data with the Partner, but does not affect the lawfulness of the sharing that took place before, nor the data the Partner already holds (which the Partner processes under its own responsibility, see below). Because the Partner benefit depends on the Partner being able to verify and report on its clients, withdrawing consent, or objecting to the sharing, may end the free, discounted or sponsored plan linked to that Partner: in that case your account continues on the plan you would otherwise have (typically the free plan, or a paid plan of your choice). You never lose your account, your connected accounts or your data by withdrawing consent. Ending your relationship with the Partner (for example closing your VPS or broker account) may likewise end the benefit; we may learn about it from the Partner.

The Partner's responsibilities and your rights

• The Partner is an independent data controller for the data it receives from us: it processes them under its own privacy policy and its own legal obligations, and we do not control what it does with them once received. Read the Partner's privacy policy before signing up through it;
• We require Partners, by contract, to keep the data confidential, to use them only for the purposes described in this section, not to sell, rent, resell or transfer them to third parties, to protect them with appropriate security measures, to honour your rights, and to delete them when the partnership or your attribution ends, except where they must keep them by law;
• We do not sell your data to Partners, and no Partner pays us for your data as such: what we exchange with Partners are plans, commissions and fees tied to the partnership, as described above;
• You can ask us at any time which Partner(s) you are attributed to and which categories of data they have received (Section 7.1, Right to Access), and you can exercise all the rights listed in Section 7 both towards us and directly towards the Partner;
• Partners may be located outside the European Economic Area. Where that is the case, the transfer is covered by the safeguards described in Section 8;
• Being attributed to a Partner never affects how your data is shown publicly: your public, unlisted and private settings keep working exactly as described in Section 5.4.

Where the referrer is an ordinary user of ShowMyTrades and not a Partner under a commercial agreement, only the limited disclosure described in Section 5.3 applies.

5.4 Public Profiles

When your profile is public, the following data is visible to everyone:

• Username, profile picture, bio
• Trading statistics and performance metrics
• Equity curves, balance charts, monthly returns
• Number of trades, win rate, profit factor
• Comments and community interactions

You can change your profile to private at any time in your account settings.

5.5 Legal Disclosures

We may disclose your personal data if required by law or to:

• Comply with legal processes, court orders, or government requests
• Enforce our Terms of Service or other agreements
• Protect the rights, property, or safety of ShowMyTrades, our users, or the public
• Detect, prevent, or address fraud, security issues, or technical problems
• Respond to claims of intellectual property infringement

5.6 Business Transfers

If ShowMyTrades is involved in a merger, acquisition, asset sale, or bankruptcy:

• Your personal data may be transferred to the acquiring entity
• We will notify you via email and/or a prominent notice on our website
• The new entity will be bound by this Privacy Policy (or you will be notified of changes)

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
• Sharing with a Partner or affiliate who referred you (Section 5.3b): write to support@showmytrades.com or, where available, use the partner settings of your account. Sharing of your private trading data stops for the future; the free, discounted or sponsored plan linked to that Partner may end; your account, your connected accounts and your data are never affected

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 (Cookieless)

We use self-hosted Plausible and Umami for usage analytics (page views, feature usage, performance monitoring). These tools are cookieless: they do not store any identifier on your device, and all data stays on our EU servers.

A/B Testing Cookies

We run A/B tests to compare different versions of our interface:

• First-party cookies named ab_* remember which variant you were assigned, so you always see the same version
• They contain only the variant label (e.g. "A" or "B"), no personal data, and expire after 180 days
• Test results are measured in aggregate form through our self-hosted analytics

Preference Cookies

These cookies remember your choices:

• Dark mode / light mode preference
• Language settings
• Chart display preferences

Referral and Partner Cookies

When you reach ShowMyTrades through a referral link, a trader's public page or a partner's page, we set first-party cookies so that your sign-up can be attributed correctly:

• ref: the referral code of the trader or partner who sent you (a number, no personal data). Kept for 180 days.
• ref_at: when ref was set, so that a later visit does not overwrite it within 24 hours. Kept for 180 days.
• partner: the partner page you arrived from (for example a VPS provider that offers ShowMyTrades Pro to its clients). Kept for 180 days.
• follow: the public accounts you asked to follow before signing up (their identifiers only, no personal data), so that we can follow them for you once you have an account. Kept for 30 days, removed as soon as it is used.

These cookies decide who gets credit for your sign-up and, for partner offers, which plan you are entitled to. The attribution they record also determines whether a Partner or affiliate may receive information about you and your trading accounts, as described in Section 5.3b. They do not track you across other websites and are read only by ShowMyTrades.

9.3 Third-Party Cookies

We use cookies from:

• Supabase: Authentication and session management
• Cloudflare Turnstile: Bot protection on forms

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

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:

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