Privacy Policy
Effective date: 13 April 2026
This Privacy Policy describes how SC Scalable Codes SRL ("we", "us", "our"), operator of InvestingStrategy.online, collects, uses, stores and protects your personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Romanian data protection law.
1. Data Controller
The data controller is SC Scalable Codes SRL, registered in Romania with company number RO47411827, having its registered address at 25 Mircea Eliade Street, 077190 - Voluntari, IF, Romania. You can contact our data protection point of contact at support@investingstrategy.online.
2. Personal Data We Collect
| Category | Data points | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account data | Name, email address, encrypted password, OAuth provider ID | Account creation and authentication | Art. 6(1)(b) — contract performance |
| Subscription data | Subscription plan, billing cycle, payment status (no card data — handled by payment provider) | Billing and access control | Art. 6(1)(b) — contract performance |
| Platform usage data | Tickers tracked, portfolio entries, alert preferences, signal history | Delivering the core service | Art. 6(1)(b) — contract performance |
| Money management alert data | Portfolio holdings cost basis, current market price at check time, computed P&L percentage, alert thresholds set by you | Comparing your portfolio positions against your own configured profit-take and stop-loss thresholds; sending informational alerts when thresholds are crossed | Art. 6(1)(b) — contract performance |
| Legal consent data | Timestamps of disclaimer and risk disclosure acceptance | Legal compliance and dispute resolution | Art. 6(1)(c) — legal obligation |
| Technical / log data | IP address, browser type, session identifiers, error logs | Security, fraud prevention, service improvement | Art. 6(1)(f) — legitimate interests |
| Communication data | Email open/click events, support correspondence | Service communications and support | Art. 6(1)(b) / Art. 6(1)(f) |
3. How We Use Your Data
We use your personal data exclusively to:
Provide, maintain and improve the Platform;
Process your subscription and manage billing;
Send transactional emails (signal change alerts, account notifications);
Comply with legal and regulatory obligations;
Detect and prevent fraud, abuse and security incidents;
Monitor your portfolio positions against your configured money management thresholds and deliver informational alerts by email when those thresholds are crossed (Pro plan only).
We do not sell your personal data to third parties. We do not use your data to train machine learning models for sale or licensing to third parties.
4. Data Sharing
We share your data only with:
Payment processor — for subscription billing (they handle card data; we receive only payment status);
Email service provider — for transactional emails;
Cloud infrastructure provider — for hosting and data storage;
OAuth providers (Google, Apple) — only when you choose social login;
Authorities — when required by law or court order.
All third-party processors are bound by data processing agreements and may not use your data for their own purposes.
5. Data Retention
We retain your account data for as long as your account is active plus 3 years thereafter for legal compliance purposes. Log and technical data are retained for a maximum of 12 months. Legal consent records are retained for 5 years from the date of consent.
6. Your Rights
Under GDPR you have the right to:
Access — request a copy of your personal data;
Rectification — correct inaccurate or incomplete data;
Erasure — request deletion of your data ("right to be forgotten");
Restriction — request that we limit processing of your data;
Portability — receive your data in a structured, machine-readable format;
Objection — object to processing based on legitimate interests;
Withdraw consent — where processing is based on consent, withdraw it at any time.
To exercise any of these rights, contact us at support@investingstrategy.online. We will respond within 30 days. You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) at www.dataprotection.ro.
7. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration or destruction. Passwords are stored using industry-standard hashing. Data in transit is encrypted using TLS.
8. Cookies
For information about how we use cookies, please refer to our Cookie Policy.
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or via a prominent Platform notice at least 14 days before the change takes effect.