1. Who is responsible
This is who is responsible for your personal data on this site and when you subscribe:
- Niko Solidaki, trading as Chaldea Labs
- Biblioteksgatan 4, 435 30 Mölnlycke, Sweden
- Email: daro@chaldealabs.com
Questions about your personal data? Email us at daro@chaldealabs.com.
2. What we collect when you subscribe
When you subscribe, the payment runs through Stripe's checkout, on Stripe's own pages.
Stripe collects your name, your email address, your payment method and your billing address. Stripe then keeps your subscription for us: what you subscribe to, its price, its status and your payments.
From Stripe we get your name, your email address, your billing address, what you subscribe to, whether the subscription is running, and your payments. We never see your full card details.
We use these details to deliver the strategy and its updates, to take the monthly payment, to send you receipts and confirmations, and to answer you about the subscription. We use the country of your billing address to check that we may sell to you: we do not sell to residents of the United States. The legal basis is the contract with you.
Stripe handles the subscription and the payments for us as our processor (personuppgiftsbiträde). For some purposes of its own, such as preventing fraud and meeting its own legal duties, Stripe decides itself how it uses the data. Stripe is a company in the USA and the EU. You can read how Stripe handles personal data in Stripe's privacy policy.
If you choose Klarna in the checkout, Klarna handles your details as a company of its own, under Klarna's privacy notice. We then get from Klarna only what we need for the subscription: your name, your email address, your country, what you subscribe to and your payments.
3. The emails we send you
Straight after your first payment we send your licence key and the link to download the add-on. Then, every month, we send the month's measured result. We also send confirmations, for example when you cancel, and the notices the terms of sale promise, such as a change to a price or to a strategy. All of them go to the address you gave at checkout. We send no other emails.
These emails are the subscription itself. The legal basis is the contract with you.
We send them through an email service that handles your address for us as our processor.
4. Manage subscription
Manage subscription takes you to Stripe's customer portal. You log in with the email address you subscribed with, and Stripe emails you a link to sign in.
In the portal you can cancel, change your payment method and see your invoices. Stripe runs the portal for us. What you change there reaches us as a change to your subscription.
5. The licence and the add-on's check
A strategy comes as an add-on for NinjaTrader 8 with a licence key. Our licence store holds, for each subscription: your email address, the ids Stripe gave your subscription, your customer record and your checkout, the strategy, your licence key, whether the subscription is paid up, whether you ticked the terms box on Stripe's payment page (the record of your confirmations, which our first email repeats), the machine ids of the computers that use the key (two at most) with the add-on's version on each, and times: when the licence was made, when the paid period ends, when the add-on last checked, and when we confirmed a cancellation by email with the day it said the subscription ends.
We keep this to deliver the strategy, to let it run on your computers while you pay for it, and to stop it when the subscription ends. The legal basis is the contract with you.
When the add-on starts, and once a day while it runs, it sends us your licence key, a machine id, and its own name and version. The machine id is a one-way code made from your computer's name and your Windows user name; we cannot turn it back into either. The add-on never sends market data and never account data: no prices, no orders, no positions, no balances, no broker login. It prints what it sends in NinjaTrader's Output window when it starts.
Our server answers whether the licence is valid and sends the strategy's current version. It never sends market data or account data either, and never settings, instructions to trade or commands.
Netlify keeps the licence store for us as our processor, in the EU (Frankfurt). The small programs that answer the add-on's check also run at Netlify, whose servers may be in the USA; Netlify takes part in the EU-US Data Privacy Framework.
We keep the licence while your subscription runs, and through the few days of grace after a late or failed payment. When the subscription ends, we delete the licence key, your email address and the machine ids. What stays is bookkeeping: the ids of the subscription and of its checkout at Stripe, the strategy and the dates, which the Accounting Act makes us keep.
6. If you withdraw from a contract
The form at Withdraw from contract is sent through Netlify Forms. It holds what you enter: your name, your email address, the strategy, the date you subscribed and any message.
Netlify stores the form for us as our processor, on servers in the USA. Netlify takes part in the EU-US Data Privacy Framework.
We use the form to handle your withdrawal and to send you the confirmation. The legal basis is our legal duty to handle withdrawals.
We keep the form until the case is closed, and then delete it from Netlify. The records of the withdrawal and of any refund are part of our accounts. The Swedish Accounting Act (bokföringslagen) makes us keep those for seven years.
7. What the website itself collects
The website is static and is hosted by Netlify.
Netlify's servers log the requests they answer. For each request the log holds your IP address, the page you asked for, the time and your browser. Netlify uses the logs to run and protect the service, and keeps them for a short time.
Netlify is a company in the USA. It takes part in the EU-US Data Privacy Framework. You can read more in Netlify's privacy policy.
The site itself sets no cookies, and it runs no analytics and no advertising scripts. The support chat loads only when you press the Support button; it is described below.
The site keeps one setting in your browser's local storage: chaldea:motion, the motion level you chose with the Motion button (on, calm or off). It is written only when you press the button. It never leaves your browser. A setting you choose yourself needs no consent.
While you visit, the browser tab also keeps a few short notes in its session storage, for example whether the 3D planets can run on your device. They never leave your browser either, and they are gone when you close the tab.
8. When you write to us
If you email us, we keep the correspondence as long as we need it to answer you and to keep a record of the matter.
9. The support chat
The Support button at the bottom right of every page opens a chat. Nothing of the chat loads until you press the button: before that, no script of the chat's runs and no cookie of its is set.
The chat is run for us by tawk.to Inc., a company in the USA. When you press Support, your browser fetches the chat from tawk.to's servers, and tawk.to sets cookies to keep your conversation together. What you write, a name or an email address if you give one, your IP address and your browser go to tawk.to, which stores them so that we can read and answer you. tawk.to processes this data on our instructions under its data processing agreement, with the EU's standard contractual clauses for the transfer to the USA; its own policy is at tawk.to/privacy-policy.
We keep chats as we keep email: as long as we need them to answer you and to keep a record of the matter. If you would rather not use the chat, write to us by email instead.
10. How long we keep data
- The details we need to deliver the strategy: as long as your subscription runs. Then we delete what the law does not make us keep.
- The licence, its key and the machine ids: while your subscription runs and its days of grace. Then we delete them.
- Records of your subscription, payments and refunds: seven years, as the Accounting Act requires. Then we delete them.
- A withdrawal form: until the case is closed.
- Emails you send us: as long as we need them to answer you and keep a record of the matter.
- Netlify's server logs: a short time, as Netlify decides.
11. Your rights
The GDPR gives you rights over your personal data. You have the right to:
- get a copy of the personal data we hold about you (access),
- have data that is wrong corrected,
- have your data deleted,
- have the use of your data restricted,
- get your data in a form you can take to someone else (portability), and
- object to how we use your data.
The rights apply as the GDPR gives them, so some have limits. For example, we must keep the records of a subscription and its payments for the seven years the law requires.
To use your rights, email us at daro@chaldealabs.com.
If you think we handle your personal data wrongly, you have the right to complain to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) at imy.se.
12. Changes
We change this page when the way we handle personal data changes. The date at the top of the page says when it last changed.