Notice
Privacy policy
Last updated: 14 October 2026. This policy covers the website forms, your account and signing in to it from the desktop app, licence activation, the desktop app’s installation check-in and error reports, promotional emails, payments, partners’ links and discount codes, and plans given as a gift.
Controller
The data controller is H2Code — VAT no. IT15572751004, Via del Pigneto, 00176 Rome, Italy. For anything about your data, use the contact address at the bottom of this page.
Sign-up and waitlist forms
When you fill in a trial or waitlist form we collect your email address and, if you provide it, your name, plus the page the request came from. We use them only to send you what you asked for (trial access, launch notice) and product updates, after your explicit consent in the form. You can unsubscribe in one click from every email. Delivery runs on Brevo, an EU-based email platform acting as our processor.
Download link by email
If you ask for the download link by email, we use your address only to send you that one email, through Brevo. We don’t add it to any list.
Account
The desktop app asks you to sign in to an account, on every plan, Free included. If you create it with email and password we process your email, optional display name and password (stored only as a salted hash, never in clear). If you sign in with Google, Google gives us only your email address, whether Google has verified it, and your Google account identifier: no password, contacts or other data. Google handles its side of the sign-in as an autonomous controller, under its own privacy policy. We also process session data, the times of account activity and the version and time of the terms you accepted. Legal basis: performance of the contract. Sessions use a single essential cookie (see below).
Signing in from the desktop app
From the desktop app you sign in to your account in your own browser: the app never sees your password. For each computer signed in we record an identifier created by the app, the computer’s name (the one set in its system settings, which may include your name), the operating system and the app version, and when it signed in and was last used. The app keeps an access token that lets it stay signed in and receive your licence by itself: on your computer it is stored encrypted, on our servers we keep only a hash of it, and it changes at every renewal. A computer that does not use the app for 90 days is signed out. You can see your computers and sign them out from the reserved area, or sign out in the app. Legal basis: performance of the contract. The list is kept while the account exists.
Licences and devices
To enforce plan limits and prevent abuse we record, for each licence, the activated devices: a device identifier, the device name reported by the app, the app version and operating system, and the time of last check-in. Licence keys are stored hashed and, so that the app can receive its key when you sign in, also encrypted with a server key kept separately; only a short prefix remains visible. Legal basis: contract and our legitimate interest in preventing licence abuse. You can disconnect a device yourself from the reserved area.
Desktop app: installation check-in
When you start the desktop app it sends our licence server a short check-in, then one every 12 hours: a random installation identifier created on the first run, the plan in use, the app version, the operating system and, once you accept them in the app, the version and time of the terms you accepted. No email, name, machine name or trading data travels with it. The installation identifier is the same one the app uses when you sign in to your account (see above), so once you are signed in we can tell which installation is yours. We use it to count installations, to see which versions are in use and to support you. Legal basis: our legitimate interest in operating and supporting the product. The record is kept while the installation is in use and for 12 months after its last check-in.
Payments
Purchases are handled by Stripe acting as merchant of record, which processes the payment as an autonomous data controller: your card number is entered on Stripe’s forms and never reaches our servers, and the purchase receipt/invoice is issued by Stripe. From Stripe we receive the outcome of charges, the subscription state and what is needed to issue and manage your licence (legal basis: contract and legal obligation). Stripe may transfer data outside the EU under the EU Standard Contractual Clauses; see Stripe’s own privacy notice.
Partners’ links and discount codes
Some creators work with us as partners: each has a link of their own (an address ending in ?ref= and their name) and a discount code. If you open the site through a partner’s link, your browser keeps which partner and their code for 30 days, in its local storage and only there: the plan buttons on our pricing page then carry the code, so the discount is already applied at checkout. If you create an account within that time, we record that partner on the account, once. If you pay with a partner’s code, through the link or by typing it, Stripe tells us which code was used, and for each payment of the first 12 months we record the date, the amount with and without tax and the partner’s share. The partner never receives your name or your email: only the dates and amounts of the payments their share is paid on. A partner’s group, and whoever we add to it by hand, sees a few extra indicators in the desktop app: the app learns this when you sign in to your account. Legal basis: performance of the contract (the discount you chose) and our legitimate interest in paying our partners correctly. The partner on the account is kept while the account exists; the payment records for the terms required by tax law.
A plan given as a gift
We sometimes give the paid plan to someone we invite (a creator, a partner, a tester) before they have an account. For that we keep their email address, the plan and its length, an internal note and who gave it, only until the gift starts. It starts when an account with that address is created and the address is confirmed (with its link or with Google): from then on the gift is a licence of that account. If no account arrives, the record is deleted after 90 days, or earlier if we withdraw the gift. Our log of these operations never records the address. Legal basis: our legitimate interest in inviting people to try the product.
Transactional email
Account and purchase emails — verification links, password resets, licence keys, billing notices — are sent through Brevo as our processor. They are part of the service, not marketing, and cannot be opted out of while the account exists.
Errors of our servers
When something breaks on our licence or account server, the error is reported to Sentry, as our processor, in its EU region (Frankfurt, Germany): the kind of error, where in our code it happened, the version of the service and the time. Before it leaves, email and IP addresses, licence keys and tokens are removed from it, and it never carries the request you made, its contents or cookies. Sentry is a US company and works under the EU Standard Contractual Clauses. The reports are kept for at most 90 days. Legal basis: our legitimate interest in keeping the service working.
Errors of the desktop app
When something breaks in the desktop app, it sends an error report to Sentry, as our processor, in its EU region (Frankfurt, Germany): the kind of error, where in our code it happened, the app version, your operating system and the time. Before the report leaves your computer, the app removes from it email and IP addresses, licence keys, tokens, your broker logins, your accounts’ ids and names, your computer’s and your user’s name, your home folder in file paths, decimal numbers and long numbers (prices, order ids); it never carries the details of your orders and positions. Reports are on by default: you can turn them off in the app, under Settings › Support, and from then on nothing is sent. Sentry is a US company and works under the EU Standard Contractual Clauses. The reports are kept for at most 90 days. Legal basis: our legitimate interest in finding and fixing what breaks in the app.
Promotional emails
We send promotional emails (news, offers) only if you ask for them, with a separate, optional box when you sign up or the switch in the reserved area; we record when you gave your consent. You can withdraw it at any time from the reserved area or with the unsubscribe link in every email. They are sent through Brevo, as our processor: your address is on the promotional list only while your consent is active. Legal basis: consent.
Site statistics, without cookies
To count visits and see which parts of the site are used (for example which installer is downloaded, which plan button is clicked, which FAQ questions are opened, what is searched in the guide and how far a page is read), we run a self-hosted analytics tool (Umami) on our own server in the EU. It sets no cookies and uses no cross-site identifiers; it stores aggregate statistics only. That is why this site shows no tracking banner. If we ever add measurement tools that require consent, we will ask first.
Cookies
The public site sets no tracking cookies. The reserved area sets one essential session cookie (HttpOnly) whose only purpose is keeping you signed in; it requires no consent banner and is deleted on sign-out or expiry. If you sign in with Google, a second technical cookie protects the sign-in: it lasts at most 10 minutes and is deleted when you come back from Google. If you sign in from the app and still have to confirm your email, the page remembers the sign-in in progress in your browser, and only there, so you can pick it up again after the confirmation: it is ignored after an hour and deleted once used. If you open the site through a partner’s link, your browser keeps the partner’s name and code for 30 days in its local storage, only to apply the discount and credit the partner (see above); clearing the site’s data removes them.
Retention
Account, licence, device and signed-in computer data are kept while the account is active and then deleted or anonymised, except what we must keep for legal obligations (e.g. invoicing records, kept for the terms required by tax law). Consent to promotional emails lasts until you withdraw it; contacts from the site forms are kept until you unsubscribe. The email of someone invited with a gift before signing up is kept at most 90 days if no account arrives (see above).
Your rights
Under the GDPR you can request access, rectification, deletion, restriction, portability and object to processing based on legitimate interest, at any time, from the contact below. You also have the right to lodge a complaint with your supervisory authority (in Italy, the Garante per la protezione dei dati personali).
Contact
For any request about your data, write to privacy@tradingkonsole.com.