Privacy Policy

1. Who we are

BlackCandle Pulse is the data controller for the personal data described here. We follow the Kenya Data Protection Act 2019 and, for users in the European Economic Area and the United Kingdom, the GDPR. Contact: [email protected].

2. What we collect

• Account details: name, email address, password (stored only as a secure hash), time zone and notification settings.
• Subscription details: plan, billing period, payment status and invoices. Card and M-Pesa details are handled by our payment provider; we don't store full card numbers.
• Trading data from the EA or your uploaded reports: MT5 login number, broker and server, balance, equity, margin, open positions, closed deals, stop loss changes, deposits and withdrawals.
• Your journal: notes, tags, setups and screenshots you add.
• Telegram: if you link it, your Telegram chat ID and username. We never see your contacts or other chats.
• Device and usage data: browser, device type, approximate location from your IP address, sign-in times and the pages you use.
• We never ask for or collect your broker password.

3. Why we use it

• To run your account and the features of your plan, including analysis, the Trading Coach, alerts and the EA (contract).
• To bill you and handle failed payments (contract and legal obligation).
• To keep accounts secure, detect misuse and enforce licence limits (legitimate interest).
• To send product news, only if you opt in (consent). You can opt out at any time.
• To improve Pulse using aggregated, de-identified statistics (legitimate interest).

4. Who we share it with

We don't sell personal data. We share it only with service providers who process it for us under contract:

• hosting and database providers
• our email delivery provider, for account, billing and notification emails
• our payment provider
• Telegram, to deliver messages you asked for

5. International transfers

Some providers store data outside Kenya. When they do, we use safeguards required by law, such as standard contractual clauses, and choose providers with strong security.

6. How long we keep it

• Account and trading data: while your account is open. Trading data older than your plan's history window is hidden, not deleted, so it returns if you upgrade.
• After you close your account: deleted within 30 days, except what we must keep by law, such as invoices.
• Notification delivery records: 13 months.
• Security logs: 12 months.

7. Your rights

You can ask us to:

• give you a copy of your data, including an export of your trades and journal
• correct inaccurate data
• delete your data
• restrict or object to some uses, including direct marketing
• move your data to another service

8. Security

Data is encrypted in transit and at rest. Passwords are hashed. Staff access is limited to what their role needs, requires two-factor sign-in and is logged. Staff only view your trading data when you have asked for support.

9. Cookies

We use cookies needed to sign you in and keep the service secure. We don't use advertising cookies. If we add analytics cookies, we will ask for your consent first.

10. Complaints

Contact us first at [email protected]. You can also complain to the Office of the Data Protection Commissioner in Kenya, or to your local data protection authority.