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Personal Data Processing Policy

Version 1.10 — effective October 9, 2026

Language. This English version is provided for convenience. In case of any discrepancy between the English and French versions, the French version prevails.

Established in accordance with Law 1581 of 2012 and Decree 1377 of 2013 (Colombia), with Regulation (EU) 2016/679 for users residing in the European Union and the United Kingdom, and with the privacy laws of the United States that provide for it, including the California Consumer Privacy Act as amended.

Where several of these laws apply, the rule most protective of the data subject prevails.

1. Data controller

GOSKEN S.A.S., a simplified joint-stock company (sociedad por acciones simplificada) incorporated under Colombian law NIT 901584640 Registered with the Medellín Chamber of Commerce Registered office: Medellín, Antioquia, Colombia Contact: the website's contact form Data protection officer: dpo@gosken.com

Requests relating to data are made to dpo@gosken.com. Any other question goes through the website's contact form.

2. Data processed

Account data: name, email address, encrypted password, authentication keys, display preferences.

Trading activity data: trades imported or entered, declared brokerage accounts, notes, capital movements.

Trade screenshots: the image you attach to a trade, with the date and time it was uploaded and its size. Only JPEG, PNG and WebP formats are accepted, and at most two megabytes.

The image is resized and recompressed by your browser before being sent. What leaves your device is therefore a new image: the original file's metadata — GPS position, device model, capture date — does not follow it. If this preparation fails, the upload is refused rather than carried out with the original file. The image is then sent to our server, which encrypts it before placing it in the storage container, and decrypts it to display it back to you.

Wealth and budget data: accounts and assets you declare, with the label, institution or location you enter, their value or balance at each date, loans and their due dates, securities and currencies held, money movements with the description shown on your statement, the categories and budgets you create, your goals, and the exchange rates you enter.

Data concerning third parties: a book may contain the name of a co-owner, that of a designated beneficiary, or the email address of a person you invite. A description taken from a statement may likewise contain the name of a counterparty, as your institution wrote it.

No banking identifier — IBAN, BIC code, account number or card number — is requested, and no field exists to receive one.

The statement file you import is not kept: only the selected rows are recorded, together with the position of the columns so that you need not define it again at each import. A statement in PDF format is read on your device, and the file itself is not transmitted to us; a CSV file is transmitted for analysis, then not kept.

Technical data: connection logs, IP address, timestamps, kept for the security of the Service.

Payment data: processed exclusively by Paddle.com Market Limited. The publisher keeps no card number, and receives from Paddle only the name, email address, billing country and amounts.

Assistant conversations: the question asked, the answer returned, and the thread title — which is your first question, truncated. These three are encrypted before they enter the database.

A technical execution trace is added, carrying no amount: the names of the measures called, row counts, true-or-false indicators, valuation dates and currency codes. It serves to understand afterwards why an answer was wrong.

Finally, a counter records the number of questions asked per month and per product, without the question or the answer.

3. Purposes

Providing the Service and computing the requested statistics. Authenticating users and securing access. Sending the messages needed to operate the account. Managing billing. Answering support requests. Complying with legal obligations.

4. Legal basis

Prior, express and informed authorisation of the data subject, obtained when the account is created, in accordance with Article 9 of Law 1581 of 2012.

For European users: performance of the contract, legitimate interest in security, and legal obligation for billing.

5. Access to data

The publisher does not exploit users' data for commercial purposes, does not sell it and does not share it with any third party for advertising purposes.

The publisher can technically access stored data. This access is limited to the following cases: a support request made by the user, the resolution of a technical incident, a legal obligation or an order from a competent authority.

No aggregated analysis of user data is carried out without prior notice.

Assistant conversations are exposed by no administration screen, and are not read. Their content is encrypted in the database, and the decryption key is not held there: it lives in the deployment environment. A copy of the database therefore does not give access to them. The publisher, for its part, could technically read them; that limit is written here rather than left unsaid.

6. Shared books and third-party data

The Service allows several books to be kept and access to one of them to be opened to another person, by invitation sent to their email address. A book may therefore describe the wealth of someone other than its holder: a relative, or a client where the holder works in accountancy.

Anyone who enters another person's data into a book must have made sure that this person consents to it. Law 1581 of 2012 makes processing subject to the authorisation of the data subject, and the person doing the entering cannot give it in their place. The publisher has no means of verifying it.

An invitation opens access to the invited address only, and only once it has been accepted from an account bearing that same address. The invitation link expires after seven days. Read access allows the entire book to be viewed and exported; write access allows entries to be made and changed. The holder may revoke an access at any time, and the invited person may leave a book on their own initiative.

7. Processors

Vercel Inc. (website hosting, United States), Neon Inc. (database, AWS Ohio region, United States), Resend (email delivery, United States), OVH SAS (trade screenshot storage, France), Mistral AI SAS (the assistant's language model, France).

The screenshots you attach to your trades are the only data hosted at OVH, and they are hosted nowhere else. They are kept in a private container located in Paris, encrypted at rest, in which no object is publicly accessible: a screenshot is served only through a signed address, issued to its owner alone and valid for one hour. This storage does not leave the European Union.

These images are encrypted before entering the container, and the key is not there: it is held in the deployment environment, at a different provider. A copy of the container, a backup or access to the storage account therefore does not make them visible. The publisher, for its part, could technically do so, as with conversations — see Article 5.

Mistral AI (the assistant's language model, France) receives the question asked and the figures the Service computed to answer it, for as long as it takes to obtain the answer. Those figures come with the labels you wrote yourself — names of accounts, of spending categories or of pairs — and with addresses of screens within the Service. Neither your sign-in credentials nor your screenshots are sent to it; no measure of the assistant reads them.

The economic calendar shown in the Service is a component of MetaQuotes Ltd. (Tradays): loading it sends that publisher the visitor's IP address and the component's display settings.

Paddle.com Market Limited (subscription payments, United Kingdom) acts as merchant of record: it processes billing data on its own behalf, as a data controller, and not as a processor of the publisher.

The price and exchange-rate sources used by the Service receive no personal data: only currency codes and asset identifiers are sent to them, identical for all users. They are therefore not processors. The list of these sources appears in the legal notice.

These transfers outside Colombia and outside the European Union rely on standard contractual clauses and on the compliance commitments of these providers.

8. Retention period

Account and activity data — trades, analyses, movements, preferences — are kept as long as the account exists. Deleting the account erases them immediately from the database.

The publisher may delete an account left unused. This requires that no access, paid or granted, be open on it, that no shared book remain accessible to it, and that one year have passed since the later of these two dates: the end of the last access, and the last sign-in. Three warnings are sent to the account's address before deletion — two months, one month and seven days beforehand. The first recalls how to export your data, and warns that the people to whom a book has been opened will lose access to it.

A screenshot is kept as long as the trade it is attached to exists. The button that removes a screenshot erases the object from the container, not merely its reference in the database; the container has no versioning, so no earlier copy remains. Replacing a screenshot erases the previous one in the same way. Deleting the trade, the brokerage account or the account erases the corresponding screenshots from the container at the same time as the data in the database.

An assistant conversation is deleted ninety days after its last message. Picking up an older thread pushes its deletion back by as much. You may also choose, in your preferences, that no conversation be recorded at all: neither the question, nor the answer, nor the title is then written.

The counter of questions asked survives that deletion. It carries neither question nor answer, and serves to apply the limits of the plan subscribed to.

Sessions expire thirty days after their last use.

Proof of acceptance of contractual documents is kept for five years after the account ends, as evidence.

Billing data is kept for the legal period required by Colombian accounting law.

The host's technical logs, including IP addresses, follow Vercel's retention period, in the order of a few days.

Encrypted backups of the database are kept offline for at most eight weeks. A deleted account may remain in them until they are erased, without being used.

9. Rights

The user has the rights to know, update, rectify and delete their data, and to revoke their authorisation.

Full export of the data and deletion of the account are available directly from the personal area, without any prior request.

Any request is handled within ten business days, which may be extended in accordance with the law.

In the event of disagreement, a complaint may be addressed to the Superintendencia de Industria y Comercio (Colombia), or to the data protection authority of the country of residence for European users.

10. Security

Passwords stored as hashes, two-factor authentication offered to every account and mandatory for administration accounts, API keys and invitation tokens stored as hashes, encrypted connections, limits on the number of attempts, assistant conversation content encrypted in the database with a key held outside it, trade screenshots encrypted in the storage container with a key that is not held there either.

No system is infallible. In the event of a data breach presenting a risk, the data subjects and the competent authorities are informed within the legal time limits.

11. United States residents

Personal data is neither sold nor shared for targeted advertising, within the meaning of US state laws. No automated decision-making or profiling is carried out.

Residents of states whose law so provides, including California, have the right to know what data is processed, to obtain a copy of it, to have it corrected or deleted, and not to be discriminated against for exercising these rights.

These rights are exercised at dpo@gosken.com, free of charge. Full export of the data and deletion of the account remain available directly from the personal area.

12. Cookies

The Service uses two strictly necessary cookies: a session cookie, to keep the user signed in, and a language cookie, which remembers the chosen language. It also uses the browser's local storage for a few display settings. No advertising or audience measurement cookie is set.

The MetaQuotes calendar component keeps its own settings in the browser.