Privacy Policy

1. Introduction & Scope

K.M.F. Development ("we", "us", or "our") operates:

• WEB The website at kmfjournal.com (the "Website").
• APP The K.M.F. Trading Journal mobile application on Google Play (the "App").

This Privacy Policy covers BOTH the Website and the App. Each section indicates which it applies to. By using either, you agree to the collection and use of information described below.

2. Contact & Controller

Data Controller: K.M.F. Development
Email: kmf45.ai@gmail.com, contact@kmfjournal.com
Location: Romania (European Union)

3. Information Collected on the Website WEB

3.1 No Direct Personal Data

The Website has no signup form, no contact form, no newsletter, and no payment processing. We do not collect your name, email, password, address, or any personal identifiers through the Website itself.

3.2 Analytics (with your consent only)

If you click "Accept" on the cookie consent banner, we load Google Analytics 4 (GA4) to collect anonymous usage statistics:

• Pages viewed and time on page
• Browser type, OS, device category
• Approximate location (country/region only — IP is anonymized via anonymize_ip)
• Referring source (which site brought you here)
• Events: button clicks, calculator usage, language switches

If you click "Reject" or your browser sends a Do Not Track signal, GA4 is not loaded and no analytics cookies are set.

3.3 Cookies Set by the Website

Both cookies are set only after you click Accept. You can change your choice anytime via the "Cookie Preferences" link in the Website footer.

3.4 Local Storage in Your Browser

The Website stores a small amount of data in your browser's localStorage to preserve your settings between visits. This data never leaves your device and is not accessible to us:

You can clear this data anytime via your browser's "Clear site data" option.

4. Third-Party Services Used by the Website WEB

The Website loads resources or data from the following third parties. Each may receive your IP address as part of the standard HTTP request:

The Website does NOT use: Facebook Pixel, advertising networks, retargeting pixels, social plugin scripts, Hotjar, Sentry, PostHog, or similar trackers.

5. Information Collected by the Mobile App APP

The mobile app collects more data than the website because it is account-based. The following applies only after you create an account and log in.

5.1 Personal Information

When you create an account, the App collects:

• Email address (required for authentication)
• Password (hashed by Firebase Authentication — never stored in plain text)

The App does NOT collect:

• Your name (unless you voluntarily provide it)
• Physical address
• Phone number
• Payment information (handled by Google Play)
• Personal photos (only trade-related screenshots you upload)

5.2 Trading Data

To provide App functionality, the App stores:

• Trade details (instrument, entry price, exit price, lot size, profit/loss)
• Trade notes, ratings, and pre/post-trade emotion ratings
• Pre-trade checklist responses
• Weekly review responses
• Photos/screenshots you attach to trades
• Account balance information (user-entered)
• Timestamps for all activities

5.3 Technical and Usage Data

The App automatically collects via Firebase Analytics and Crashlytics:

• Device model and operating system version
• App version
• IP address (temporary, for authentication purposes)
• Crash logs and error reports
• Usage analytics (screens viewed, features used, session duration)
• Unique device identifiers

6. Automated Decision-Making & Profiling APP

The App uses automated analysis on data you provide to generate insights for your own use. None of these decisions have legal or significant effects on you — they are advisory only.

• Trader Personality Profile: Classifies your behavior into archetypes (Sniper, Robot, Momentum Rider, Wave Rider, Gambler, Revenge Trader) based on trade patterns. Computed locally and stored with your account.
• Tilt Detection: A 4-level warning system that flags potential emotional trading based on recent loss patterns and self-reported emotions. Triggers in-app warnings; you remain in full control of every trade.
• Honesty Mirror: Correlates your self-reported trade quality ratings with actual P/L to identify systematic over- or under-confidence.

Under GDPR Article 22, you have the right to request human review of any automated decision.

7. Legal Basis for Processing (GDPR Article 6)

8. How We Use Your Information

8.1 To Provide Functionality APP

• Authenticate your account
• Store and sync your trading data across devices
• Calculate trading statistics and performance metrics
• Generate PDF reports
• Display your trading history and analytics

8.2 To Improve the Service WEB APP

• Analyze usage patterns to improve features
• Identify and fix bugs and crashes
• Optimize performance

8.3 To Communicate With You

• Respond to your support requests
• Send important updates about the App (if necessary)
• Notify you about policy changes

We do NOT use your data for:

• Marketing or advertising purposes
• Selling to third parties
• Unrelated commercial purposes
• Cross-site or cross-device tracking beyond what you explicitly consent to

9. App Third-Party Services APP

• Google Firebase (Google LLC) — Authentication, cloud database (Firestore), file storage, analytics, crash reporting. Privacy: policies.google.com/privacy
• Twelve Data (Twelve Data Inc.) — Real-time market prices and exchange rates inside the App. Data shared: trading symbols requested, IP address. No personal or trading data is shared. Privacy: twelvedata.com/privacy-policy

We may also disclose information if required by law or in response to valid requests by public authorities.

10. Data Storage, Retention & Security

10.1 Storage Location

APP Account data, trading data, and App analytics are stored on Google Cloud servers in the European Union (eur3 region), under GDPR-compliant standards.

WEB Website analytics data (if you consent) is processed by Google Analytics, which may transfer data to Google servers in the United States under the EU–US Data Privacy Framework. localStorage data stays entirely on your device.

10.2 Retention Periods

10.3 Security Measures

• Encryption in transit (HTTPS/TLS)
• Encryption at rest (Firebase Firestore encrypted by default)
• Secure authentication (Firebase Authentication)
• Password hashing (your password is never stored in plain text)
• Regular security updates

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

11. Your Data Rights Under GDPR

11.1 Right to Access

APP You can access all your data through the App at any time. WEB For Website data, contact us — we hold very little (primarily anonymized analytics if you consented).

11.2 Right to Rectification

You can edit or correct your trading data, notes, and settings within the App.

11.3 Right to Deletion ("Right to be Forgotten")

You can request deletion of your account and all associated data by:

• Using the "Delete Account" feature in the App Settings
• Contacting us at kmf45.ai@gmail.com

WEB For Website cookies/analytics, click "Reject" in the cookie banner or use "Cookie Preferences" in the footer.

11.4 Right to Data Portability

You can export your trading data via the built-in export feature (PDF, and CSV/JSON for Premium users).

11.5 Right to Object

You can object to processing for analytics or legitimate-interest-based processing by rejecting cookies (Web) or by discontinuing use and deleting your account (App).

11.6 Right to Withdraw Consent

You can withdraw consent at any time. For Website analytics, use "Cookie Preferences" in the footer. For App data, delete your account.

11.7 Right to Lodge a Complaint with a Supervisory Authority

If you believe your data rights have been violated, you have the right to file a complaint with a Data Protection Authority. In Romania, this is:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
dataprotection.ro

If you reside in another EU member state, you may file with your local DPA.

To exercise any of these rights, contact us at kmf45.ai@gmail.com. We will respond within 30 days.

12. Children's Privacy and Age Requirement

APP The App is intended for users aged 18 and older. We do not knowingly collect information from individuals under 18.

WEB The Website is publicly accessible (no signup) and does not knowingly collect personal data from anyone, including minors. We recommend parental supervision for children browsing financial content.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us and we will delete such information.

13. International Data Transfers

APP App data is stored in the EU (eur3 region). Where Google Firebase routes traffic outside the EU, standard contractual clauses apply.

WEB Google Analytics may transfer Website analytics data to the US under the EU–US Data Privacy Framework, which the European Commission has deemed to provide an adequate level of protection.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the new version at kmfjournal.com/privacy-policy and inside the App, and update the "Last updated" date.

For material changes affecting how we process your data, we will provide prominent notice. Your continued use after changes are posted constitutes acceptance.

15. Contact Us

For questions about this Privacy Policy or to exercise your data rights:

Email: kmf45.ai@gmail.com, contact@kmfjournal.com
Controller: K.M.F. Development
Location: Romania (European Union)

We will respond within 30 days.