Privacy Policy
Draft for review — please complete the highlighted placeholders before publication.
Last updated: 12.01.2026
1. Data controller
Controller: [LEGAL ENTITY NAME], registered address: [REGISTERED ADDRESS], contact: [PRIVACY CONTACT EMAIL]. Data Protection Officer, if applicable: [DPO DETAILS OR NOT APPLICABLE].
2. What this policy covers
This Privacy Policy explains how Pillinger Works processes personal data when you visit the website, create an account, use the platform, subscribe to a service, contact support, or otherwise interact with our services.
3. Services and data processing
Pillinger Works may provide services including Trading Journal Pro, My Expenses, educational content, broker-related features, support/helpdesk functionality and account/platform services.
4. Categories of data
Depending on how you use the platform, we may process account and identity data, contact details, authentication and session data, subscription and billing status, support communications, uploaded files and content, product usage information, security/audit information, and technical information such as IP address, browser and device information.
5. Purposes and legal bases
We process data as necessary to provide requested services and perform a contract; to comply with legal obligations; to protect the security and integrity of the platform; and, where appropriate, on the basis of legitimate interests or consent. The specific legal basis depends on the processing activity.
6. Accounts, authentication and sessions
We process the information needed to register, authenticate and maintain your account and session. We may also process security and audit information to prevent abuse and protect the platform.
7. Subscriptions, payments and Stripe
When you purchase a paid plan, payment information may be processed by Stripe or another payment provider identified during checkout. We receive and retain the information necessary to manage your subscription and billing relationship. We do not intend to store complete payment-card details on our own servers where the payment provider handles them.
8. Trading Journal Pro and My Expenses
If you use Trading Journal Pro or My Expenses, we process the information and files you choose to enter or upload in order to provide those features. Trading records, expense information and uploaded broker files should be treated as user-provided content. We do not use such content for personalised investment advice.
9. Support and communications
If you contact us or use the helpdesk, we process the information contained in your request and the account information needed to provide support, maintain service quality and document relevant support activity.
10. Retention
We retain personal data only for as long as necessary for the relevant purpose, to provide the service, meet legal/accounting requirements, resolve disputes, enforce agreements and protect our legitimate interests. Exact retention periods may vary by data category and applicable law.
11. Recipients and service providers
Data may be processed by service providers acting on our behalf, such as hosting, infrastructure, email, payment and security providers. We require appropriate safeguards and only disclose information as necessary for the relevant purpose or where legally required.
12. International transfers
Where personal data is transferred outside the European Economic Area, we will use a lawful transfer mechanism and appropriate safeguards where required by applicable data-protection law.
13. Cookies and similar technologies
The website may use cookies and similar technologies that are necessary for authentication, language selection, security, functionality and other purposes described in the applicable cookie information. Where consent is required, we will request it in accordance with applicable law.
14. Your GDPR rights
Subject to applicable conditions, you may have rights to access your data, correct it, request erasure, restrict processing, receive portable data, object to certain processing and withdraw consent where processing is based on consent. You may also complain to a competent supervisory authority.
15. Exercising your rights
You can contact us at [PRIVACY CONTACT EMAIL]. We may need to verify your identity before fulfilling a request. We normally respond within the applicable statutory period.
16. Security
We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration. No internet service can guarantee absolute security.
17. Children
Unless expressly stated otherwise, the platform is not intended for children who are not legally able to enter into the relevant agreement. Where educational services are offered to minors through a school or other organisation, the applicable contracting and safeguarding arrangements must be established separately.
18. Changes to this policy
We may update this Privacy Policy when our processing activities or legal requirements change. The latest version will be published on this page with its effective date.
19. Contact
Privacy contact: [PRIVACY CONTACT EMAIL]. Supervisory authority information: the competent data-protection authority for your circumstances, including the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) where applicable.