Privacy Policy

1. Controller

The controller responsible for data processing in connection with the "Confluo" app is:

2. Core Principle: Local Data Processing

Confluo stores all user data — including trading pairs, templates, checklists, trade journal entries, statistics and settings — exclusively on your local device (technically via the device's internal storage, "AsyncStorage"). There is no Xalveon Studios server that this data is transmitted to. We have no access to the content you store in the app.

There is accordingly no legal basis required for a transfer of this content to us, since no such transfer takes place.

3. Camera & Photo Library

Confluo requests access to the camera and photo library so you can attach screenshots to your trade journal entries. These images are stored exclusively on your local device and are not transmitted to us or to third parties. Access only occurs when you actively select or capture an image; you can revoke this permission at any time in your device's system settings.

4. Backup Export / Import

Confluo lets you export or import your data as a JSON file (e.g. for a backup or when switching devices). This export uses your operating system's native share/file functions (e.g. AirDrop, Mail, Files app) and remains entirely under your control. Xalveon Studios does not receive a copy of this file.

5. In-App Purchases (Pro Version)

Confluo uses Apple's (App Store) and Google's (Google Play) native in-app purchase systems for the purchase of the Pro version. Payment processing and the data required for it (e.g. payment method, purchase history) are processed exclusively by Apple or Google. Xalveon Studios only receives confirmation from Apple/Google that a purchase has taken place (in order to unlock Pro features), but no payment data.

The privacy policies of the respective platform also apply:

• Apple: apple.com/legal/privacy
• Google: policies.google.com/privacy

6. No Advertising, No Tracking, No Third-Party SDKs

As of the date of this policy, Confluo does not use any advertising networks (e.g. no AdMob), analytics or tracking services, or any other third-party SDKs for data collection. No usage data is transmitted to third parties for advertising or analytics purposes.

Should this change in a future version (e.g. through the addition of advertising or analytics tools), this privacy policy will be updated in advance accordingly and, where required, your consent will be obtained pursuant to Art. 6(1)(a) GDPR.

7. No User Account

Confluo does not require registration or a user account. No contact details such as name or email address are collected in order to use the app.

8. Important Note on Analysis Content

The confluence scores, checklists and statistics calculated by Confluo are based exclusively on the data you enter yourself. They do not constitute financial, investment or tax advice and are not transmitted to us.

9. Your Rights

Since all app content remains on your local device, you can exercise access, rectification and erasure of this data yourself at any time — e.g. via the app's settings, or by uninstalling the app (which removes all locally stored data).

Independently of this, you generally have the following rights under the GDPR with respect to us, to the extent we process personal data (e.g. when you email us):

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to lodge a complaint with a data protection supervisory authority

Contact for exercising your rights: jack@xalveon-studios.com

10. Changes to This Privacy Policy

This privacy policy may be updated if Confluo's features or applicable legal requirements change. The current version can always be found at this address and linked from within the app's settings.