Privacy Notice
Effective: November 15, 2026
1. Controller
Fekete Szilárdné, sole proprietor (Hungary)
- Registered address: Murányi utca 36. 4/36, 1078 Budapest, Hungary
- Email: support@prognon.com
This notice is a translation; in case of any difference, the Hungarian version prevails.
2. What we process, why, and for how long
| Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Account: name, email, password (encrypted), language, time zone | account, sign-in, notifications | performance of contract, Art. 6(1)(b) | 12 months after the subscription ends |
| Subscription: plan, status, Stripe customer ID; credits and their use | billing, allowances | contract, (b) | billing records 8 years, the rest 12 months after the subscription ends |
| Trading data: trades uploaded by the Cockpit (instrument, direction, price, size, stop/target, times, result, simulated or not, the trade's lifecycle) | verdicts and progress tracking | contract, (b) | 12 months after the subscription ends |
| Strategies: the rules you recorded and the documents and images you uploaded | the basis of the verdict | contract, (b) | 12 months after the subscription ends |
| Conversations, verdicts, analyses | the coach's operation | contract, (b) | 12 months after the subscription ends |
| Chart images | image verdicts | contract, (b) | not stored — only passed to the AI provider for the evaluation |
| AI usage log: which operation ran, when, with how many tokens and at what cost (no content) | cost control, fair use | legitimate interest, (f) | 12 months after the subscription ends; anonymised when the account is deleted |
| Paired machines (licence data): machine ID (a 16-character code derived from the hardware), machine name, last seen, Cockpit version; a heartbeat every minute for the one-machine rule | licence protection, one-machine rule | contract, (b) | for the life of the account; 12 months for an unpaired machine |
| Marketing email: name, email address, time of consent | sending product news and offers | consent, (a) — given separately and optionally at registration, withdrawable at any time | until consent is withdrawn |
| Trial: machine ID, start, expiry, Cockpit version — without an account | one trial per machine | legitimate interest, (f) (preventing abuse) | 12 months after expiry |
| Partner code: which partner the account belongs to | access to the partner's strategy library | contract, (b) | 12 months after the subscription ends |
| Telemetry: feature counters, error signatures, number of launches, Cockpit/NinjaTrader/Windows version | improving the software | not personal data: it contains no user, machine or IP data | 90 days |
The system makes no automated decision about you with legal effect: a verdict is an informative assessment based on your own rules.
3. Processors
| Provider | Used for | Where |
|---|---|---|
| Anthropic PBC | the AI coach, verdicts and strategy processing (messages, trade data, chart images) | USA — Anthropic does not use data received through its commercial API to train models |
| Supabase Inc. | database, sign-in, file storage | EU (Frankfurt, Germany) |
| Vercel Inc. | website and servers | USA / global |
| Stripe Payments Europe Ltd. | payments, invoicing | EU / USA |
| Resend | system emails (confirmation, password); with consent, product news and offers | USA |
Transfers outside the EU are based on the EU–US Data Privacy Framework or the European Commission's standard contractual clauses.
4. Cookies
We only use cookies needed for the service to work: your sign-in session and your chosen language. There are no tracking, advertising or analytics cookies.
5. Your rights
Access, rectification, erasure, restriction, data portability, and objection (where processing is based on legitimate interest). Send your request to support@prognon.com; we reply within 30 days. Complaints: the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), Falk Miksa utca 9–11, 1055 Budapest, www.naih.hu — or the data protection authority of your country of residence.
You can unsubscribe from product news and offers at any time, using the link at the bottom of the email or by writing to the address above. Unsubscribing does not affect your account or your subscription.
6. Changes
We will notify you of material changes by email; the current version is always available on this page.