SPECTARFX · GOLD

Privacy Policy

Last updated: 8 September 2026 · Version 1.0 (draft)

Draft — sections 1 and 2 are pending technical verification. Sections 1 and 2 describe our understanding of how the Software behaves, but the telemetry has not yet been verified in the code. In particular it is not yet confirmed whether the Software sends account balance, open positions, trade history or results to our servers; this policy currently states that it does not. Verification will be completed before the Software goes on sale, and no claim will remain in this policy that has not been checked.

This policy explains what personal data DMG TIM, d.o.o. (“we”) collects when you use Spectar FX Gold, why we collect it, and what rights you have. The data controller is DMG TIM, d.o.o., Frankopanska ulica 8, 1000 Ljubljana, Slovenia (reg. no. 6381529000, VAT SI86596462), reachable at [email protected].

What we never see: your broker password, your funds, and your ability to withdraw money. The Software runs on your own computer and connects to your broker with your own credentials, which stay on your machine. We cannot place a withdrawal, and we cannot log into your account.

1. What we collect [pending technical verification]

Data	Why	Legal basis
Email address	send your licence key, receipts, service notices	performance of a contract
MetaTrader account number	your licence key is bound to it, so it cannot be shared	performance of a contract
Machine identifier (a hash)	limits how many machines one licence runs on	legitimate interest — preventing licence abuse
Licence check logs (key, time, IP)	detect shared or abused keys, diagnose faults	legitimate interest
Support messages you send us	answer you	performance of a contract

Name and billing country: collected by our payment provider, not by us — see section 3 on roles.

2. What we do not collect [pending technical verification]

Your broker password or investor password.
Your card number — payment details go directly to the payment provider and never reach our servers.
Your balance, positions or trade history. Those stay between you and your broker; the Software reads them locally on your own machine to enforce the limits you set.
We do not use advertising trackers, and we do not sell or rent personal data to anyone.

3. Who we share data with — and who is responsible for what

Paddle.com Market Ltd — payment processing, invoicing, VAT/sales tax. Paddle acts as Merchant of Record and is an independent controller for billing data (name, billing address, country, payment details). We do not collect those data ourselves and do not receive payment details; we receive only the confirmation of purchase and the email address needed to deliver the licence. Paddle’s own privacy policy governs the data it controls.
Cloudflare, Inc. — website hosting and DNS. Processor.
Our email provider — sending licence keys and service notices. Processor.
Public authorities — only where we are legally required to disclose.

Some of these providers operate outside the EEA. Where that happens, transfers are covered by the European Commission’s Standard Contractual Clauses or an equivalent safeguard.

4. How long we keep it

Account and licence data: for the life of your subscription and 24 months after it ends.
Invoices and tax records: as long as tax law requires (typically 10 years under Slovenian law).
Licence check logs: 90 days.
Support correspondence: 24 months.

5. Your rights

Under Regulation (EU) 2016/679 (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2) you have the right to access your data, correct it, delete it, restrict or object to its processing, receive it in a portable format, and withdraw consent where processing is based on consent. To exercise any of these, email [email protected]; we answer within one month. You also have the right to lodge a complaint with the Slovenian Information Commissioner (Informacijski pooblaščenec) or with the supervisory authority in your own country.

6. Cookies

This website uses no advertising or analytics cookies. Cloudflare may set a strictly necessary cookie for security and to keep the site available. The checkout page is operated by Paddle and uses cookies necessary to process the payment; Paddle’s own privacy policy applies there.

7. Security

Licence keys are signed cryptographically. Traffic to and from our servers is encrypted in transit. Access to customer records is limited to people who need it to run the service. No system is perfectly secure; if a breach affects your rights we will notify you and the relevant authority as required by law.

8. Children

The Service is not offered to anyone under 18, and we do not knowingly collect data from children.

9. Changes

If we change this policy materially we will email subscribers and update the date above.

10. Contact

DMG TIM, d.o.o., Frankopanska ulica 8, 1000 Ljubljana, Slovenia — [email protected]