Privacy policy

Data controller

Responsible person : Fillnovo

Contact : dev@fillnovo.xyz

Data collected

• Account: email address, password hash (scrypt, never the password itself), language, time zone, plan, date and version of the terms accepted.
• Google sign-in, if you use it: Google identifier and email address. No other access to your Google account is requested.
• Sessions: creation and expiry dates. Neither IP address nor browser is kept.
• Activity: last visit and one marker per day the application is opened, without the pages visited.
• Security: failed sign-ins (email and IP address hash), rate counters and known origins, as SHA-256 hashes. An IPv4 address hash can be reversed by trial and error: this is minimization, not anonymization.
• Journal: accounts, executions, positions, funding, capital movements, notes, tags, setups, risk plans, checklists, saved filters, entered rates, rules, screenshots and PDF reports.
• Sources: encrypted API keys, public wallet addresses, sync status, imported files and hashes of attachments received by email.
• Two-factor authentication, if you enable it: encrypted secret and hashes of the backup codes.
• Notifications, if you enable them: preferences and the subscription address provided by your browser.
• Affiliate program: referral code, clicks aggregated per day with no IP address, link between referrer and referred user, commissions, transfer references and payout details, encrypted and accessed only to make the transfer.
• Billing, if you subscribe: Stripe customer ID, subscription status and due dates, amount, taxes, currency and date of each payment. No card numbers.

Purposes and legal bases

• Providing the journal, syncs, exports and reports: performance of the contract.
• Protecting the service (rate limits, detection of failed sign-ins, audit): legitimate interest and security.
• Keeping track of commissions and payouts: accounting obligations and operation of the affiliate program.
• Collecting the subscription and keeping payment records: performance of the contract and accounting obligations.
• Sending notifications: your choice, which you can withdraw at any time.

No data is sold, no advertising is shown and no third-party analytics tool is used.

Retention periods

• Account and journal: until the account is deleted. No automatic deletion for inactivity.
• Sessions: until expiry, 30 days, or 1 day without “remember this device”.
• Failed sign-ins: 1 day. Rate counters: end of their window. Known origins of an account: 30 days after the last successful sign-in.
• Reset links: 1 hour. Address confirmation links: 24 hours. Sign-in step with code: 5 minutes.
• Unconfirmed imports, including raw rows: 30 days. Completed syncs and hashes of attachments received by email: 90 days.
• Unsuccessful connection requests: 30 days at most, then the key is erased. Demo accounts: 24 hours.
• Identifiers of payment events received from Stripe: 90 days.
• Audit: 12 months. Payments and settled referrals: 10 years after the end of the accounting year; outstanding commissions are retained until settled. After account deletion, remaining records are detached from the account or pseudonymised. Stripe retains invoices under its own obligations.
• Server logs: IP address, date, requested path and browser, retained for 14 days for security. Encrypted backups: 7 days on the server and 30 days for the backup copy; deletions must be reapplied before a backup is returned to service.

Processors and recipients

Host : OVHcloud

OVH SAS — 2 rue Kellermann, 59100 Roubaix, France · Contact

Email sending (SMTP) : OVHcloud (MX Plan)

• Google: only if you choose “Continue with Google”.
• Stripe: payment, invoices and subscription management, if you subscribe. Stripe receives your email address and payment data.
• Platforms you connect: they receive your key or address at the time of reading, under their own terms.
• Your browser's notification service, if you enable notifications. Email receiving service, if you use email import.

Stripe and connected platforms may process data outside the European Union. Stripe's safeguards are described in its data processing agreement. The countries and safeguards of platforms depend on the service chosen; read their policies before connecting them.

Stripe — Data Processing Agreement

Cookies and local storage

Essential cookies and an optional referral cookie, without audience measurement:

• Session: keeps you signed in, 30 days at most, or until the browser is closed.
• Language: remembers the chosen language, 1 year.
• Referrals: code stored for 30 days only after your consent. Manage or withdraw consent through “Manage cookies”. Your choice, including refusal, is stored for 180 days.
• Sign-in flow: Google, 10 minutes; two-factor authentication code step, 5 minutes.

Your browser also keeps the theme, privacy mode, drafts and views saved offline. All of this, except the theme and privacy mode, is purged on sign-out and on account deletion.

API keys

Keys are encrypted (AES-256-GCM) and are never displayed or returned by the application, to anyone, administrators included. The server uses them only to read your history or test a connection. A key attached to a connection request is erased as soon as the request ends.

Limitation: anyone with access to both the server and the encryption key can technically decrypt them. Use a read-only key, which you can revoke with the platform.

Administration sees volumes (number of accounts and executions), never your trades, notes or screenshots.

Security

Passwords and tokens are stored only as hashes. No security measure is absolute: enable two-factor authentication to strengthen your account.

Your rights, export and deletion

• Access and portability: Settings, Data export (CSV, JSON, ZIP archive with your screenshots). No connection secret is exported.
• Rectification: most data can be edited in the application; the email address is changed in Settings.
• Erasure: Settings, Danger zone. The journal, files, keys, connections and shares are removed. If you cannot access the account, write to the contact above.
• Objection and restriction: write to the contact above. You may also lodge a complaint with the competent supervisory authority (in France, the CNIL).