FX PRIMER — PRIVACY POLICY

This Privacy Policy applies to personal data processed in connection with:

• the FX Primer website and product pages;
• FX Primer for MetaTrader 4 and MetaTrader 5;
• license activation, validation, security, and anti-abuse systems;
• the FX Primer online environment;
• Trend Pulse Screener;
• FX Primer AI Analysis;
• digital product delivery;
• checkout and order-related interactions;
• customer support;
• advertising, measurement, and website analytics technologies used by FX Primer.

This Policy does not govern third-party websites, brokers, MetaTrader services, payment services, or other third-party services that you access independently. Those providers may process personal data under their own privacy policies.

For purposes of applicable data protection law, FX Primer is the controller of personal data described in this Policy where we determine why and how that data is processed.

Certain third-party providers may act as processors or service providers on our behalf. Other providers, including payment, advertising, security, and technology providers, may also process certain information as independent controllers for their own lawful purposes.

Privacy requests can be sent to:

support@fxprimer.com

The information we collect depends on how you interact with FX Primer.

3.1 Contact and account information

We may process:

• email address;
• username;
• account identifiers;
• information you voluntarily provide to support;
• correspondence and attachments;
• account creation and status information.

3.2 Purchase and order information

When you purchase FX Primer, we or our service providers may process:

• name, where requested at checkout;
• email address;
• billing country or region;
• billing address, where required;
• order reference;
• selected product and platform;
• purchase amount;
• currency;
• transaction date and time;
• payment status;
• applicable tax information;
• discount or promotion information, where applicable;
• digital-delivery status.

FX Primer does not need to store your full payment card number or card security code. Payment details are processed by specialized payment providers such as Stripe.

3.3 License and activation information

To activate, validate, secure, and protect FX Primer licenses, we may process:

• FX Primer License Key;
• license status;
• selected platform;
• license creation, activation, validation, suspension, revocation, or expiration timestamps;
• software version;
• MetaTrader/platform version;
• device or installation identifiers where used;
• IP address;
• request and connection timestamps;
• validation results;
• technical request metadata;
• fraud, security, or anti-abuse indicators.

This information is used to provide legitimate access and to detect unauthorized license sharing, circumvention, fraud, abuse, or redistribution.

3.4 Online account and authentication data

When you create or use an FX Primer online account, we may process:

• License Key;
• username;
• authentication credentials in protected form;
• account status;
• login and authentication timestamps;
• IP address;
• account-recovery events;
• security logs;
• service-access records.

3.5 Trend Pulse Screener usage

We may process:

• selected market category;
• selected symbols;
• favorites;
• filters and sort preferences;
• selected market;
• request and refresh timestamps;
• technical status information;
• session information;
• IP address and standard network logs.

Market prices and indicator states are generally market information rather than information about you, although usage records can become personal data when linked to an account, IP address, or License Key.

3.6 AI Analysis usage

When you use FX Primer AI Analysis, we may process:

• selected symbol;
• selected timeframe;
• FX Primer market snapshot or module data used to generate the analysis;
• analysis request timestamp;
• generated analysis;
• request status and history;
• daily usage count;
• account or license identifiers needed to authenticate access and enforce usage limits;
• error and diagnostic information;
• technical request metadata.

The market-analysis payload is generally market information rather than personal information. Users should not submit sensitive personal information where it is not required.

AI Analysis requests may be routed through third-party AI infrastructure providers, including OpenRouter and one or more underlying model providers.

3.7 Technical and usage information

When you visit or use the Services, we or our technology providers may automatically process:

• IP address;
• browser type and version;
• operating system;
• device type;
• language;
• approximate geographic region derived from IP address;
• referring URL;
• pages visited;
• time and date of access;
• session duration;
• navigation and interaction events;
• error logs;
• network and security logs;
• cookie or similar identifiers.

3.8 Customer support

If you contact support, we may process:

• email address;
• name or username if provided;
• order reference or License Key where needed to identify your account;
• message contents;
• screenshots;
• attachments;
• technical details;
• support history.

Please avoid sending sensitive information that is not necessary to resolve your request.

3.9 Advertising and campaign data

Where advertising technologies are enabled, we may process or receive:

• page views;
• product views;
• CTA interactions;
• checkout initiation;
• purchase/conversion events;
• campaign attribution data;
• browser and device information;
• IP address;
• cookie or advertising identifiers.

We may use Meta advertising technologies, including the Meta Pixel, for campaign measurement, attribution, audience creation, retargeting, and optimization.

We do not intentionally send your License Key, password, full card details, or AI Analysis content to Meta for advertising purposes.

Unless specifically required for a lawful purpose, FX Primer does not intend to collect special-category or highly sensitive personal data such as:

• government identity documents;
• biometric information;
• health information;
• racial or ethnic origin;
• political opinions;
• religious beliefs;
• trade union membership;
• sexual orientation;
• genetic information.

Do not submit such information unless it is specifically requested for a lawful and necessary reason.

We may collect information:

• directly from you;
• automatically through the website, authentication, security, and license-validation systems;
• from payment and digital-delivery providers;
• from advertising and measurement providers;
• from service providers supporting FX Primer;
• during fraud, abuse, or license-sharing investigations;
• from lawful sources necessary to protect our rights or Services.

We may use personal data to:

• provide and operate the Services;
• process purchases;
• deliver digital products;
• issue and associate License Keys;
• activate and validate licenses;
• create and maintain online accounts;
• authenticate users;
• provide Trend Pulse Screener;
• provide AI Analysis;
• enforce usage allowances;
• send service and transactional communications;
• provide support;
• process account recovery;
• prevent fraud, abuse, unauthorized access, and license sharing;
• investigate suspicious activity;
• secure FX Primer systems;
• enforce Terms and license agreements;
• troubleshoot technical issues;
• maintain logs and service reliability;
• improve usability and performance;
• understand website and product usage;
• measure advertising performance and attribution;
• deliver or measure advertising where legally permitted;
• comply with tax, accounting, regulatory, and legal obligations;
• respond to lawful requests;
• establish, exercise, or defend legal claims;
• manage a merger, acquisition, restructuring, or transfer of business assets.

Where GDPR, UK GDPR, or similar laws apply, we rely on one or more of the following bases.

Contract:

We process data where necessary to process purchases, deliver FX Primer, validate licenses, provide online tools, maintain accounts, and provide support.

Legitimate interests:

We may process data to prevent fraud and license sharing, secure the Services, troubleshoot problems, improve reliability, protect intellectual property, understand usage, and defend legal rights.

Legal obligations:

We may process data to comply with tax, accounting, consumer-protection, financial, regulatory, or lawful government requirements.

Consent:

Where required, we rely on consent for non-essential cookies, advertising technologies, certain analytics, and optional marketing.

FX Primer may use Stripe to process payments.

Stripe may process information including:

• name;
• email;
• billing details;
• payment method information;
• purchase amount;
• transaction information;
• IP and device information;
• fraud-prevention and authentication information.

Stripe may process data to complete transactions, authenticate payments, reduce fraud, comply with financial obligations, and provide payment-related services.

FX Primer does not need to receive or store your complete card number or CVC.

FX Primer may use SendOwl to manage and deliver digital products.

SendOwl may process customer information necessary to:

• associate a payment with the correct product;
• provide a secure download page;
• send delivery emails;
• manage download access;
• deliver ZIP files, documentation, software files, or license codes where configured;
• maintain delivery records.

Depending on configuration, SendOwl may receive your email address, order information, product purchased, and delivery status.

FX Primer may use Cloudflare for:

• website hosting;
• content delivery;
• DNS;
• performance;
• traffic routing;
• availability;
• security;
• protection from malicious traffic.

Cloudflare may process technical information such as IP address, request URL, browser/device details, timestamps, network information, and security logs.

FX Primer may use Supabase for:

• database services;
• authentication;
• APIs;
• Edge Functions;
• storage;
• license/account records;
• usage records;
• AI Analysis requests or outputs;
• Screener-related service data;
• technical logs.

The information stored depends on which FX Primer service is being used.

Supabase may process customer data on behalf of FX Primer. The physical region of primary project data depends on the Supabase region selected by FX Primer, and supporting subprocessors may process data subject to applicable safeguards.

FX Primer AI Analysis may use OpenRouter to route requests to supported AI model providers.

An AI request may include:

• selected symbol;
• selected timeframe;
• FX Primer module outputs;
• market context;
• analysis instructions.

OpenRouter then routes the request to an available model provider and returns the generated output.

OpenRouter states that prompt and response content is not stored by default unless certain optional logging/data-use settings are enabled. Request metadata may still be processed to operate the service.

Underlying model providers may have different practices regarding retention, logging, evaluation, or model improvement, and the provider used for a request may vary due to routing or fallback mechanisms.

Where available, FX Primer may use privacy-preserving, limited-retention, or zero-data-retention configurations.

FX Primer does not intentionally include passwords, payment card details, or unrelated personal information in AI Analysis prompts.

FX Primer may advertise through Meta platforms, including Facebook and Instagram, and may use Meta Business Tools such as Meta Pixel.

Where enabled, Meta may receive information about activity on the FX Primer website, including:

• page visits;
• product views;
• checkout-related events;
• purchase or conversion events;
• referring URL;
• browser/device information;
• IP address;
• cookie or advertising identifiers.

We may use this information to:

• measure advertising effectiveness;
• attribute conversions;
• optimize campaigns;
• create or measure advertising audiences;
• retarget users where legally permitted.

FX Primer does not sell personal data to Meta for monetary consideration.

However, certain privacy laws may classify disclosures through advertising technologies as "sharing", "targeted advertising", or similar regulated activity. Where applicable, you may have the right to opt out.

FX Primer and its providers may use cookies, pixels, local storage, and similar technologies.

Essential:

Used for security, authentication, sessions, fraud prevention, and website operation.

Preferences:

Used to remember settings such as language or user preferences.

Analytics/performance:

Where enabled, used to understand performance, errors, and general interaction.

Advertising:

Where enabled, used for campaign measurement, conversion attribution, audience creation, retargeting, and advertising optimization.

Where applicable law requires consent, FX Primer will seek consent before activating non-essential advertising or tracking technologies.

You may manage or withdraw optional choices through the cookie or consent controls made available on the website. You may also block or delete cookies through your browser, although essential functionality may be affected.

We may disclose personal data where reasonably necessary to:

Service providers:

Including Cloudflare, Supabase, Stripe, SendOwl, OpenRouter/model providers, Meta, and other technical or security providers.

Professional advisers:

Including lawyers, accountants, tax professionals, auditors, or other advisers where necessary.

Authorities:

Where required by law, court order, lawful government request, or where necessary to investigate fraud or protect rights and safety.

Business transfers:

In connection with a merger, acquisition, restructuring, financing, or transfer of business assets.

FX Primer does not sell personal data for monetary consideration.

The use of advertising technologies such as Meta Pixel may, depending on applicable law, be considered "sharing" personal information or targeted advertising.

Where applicable, you may opt out through available cookie/privacy controls or by contacting:

support@fxprimer.com

FX Primer serves users internationally and uses providers that may process data in multiple countries.

Personal data may therefore be processed outside your country, the EEA, the UK, or Switzerland.

Where required, international transfers may rely on safeguards such as adequacy decisions, Standard Contractual Clauses, UK transfer mechanisms, Data Processing Agreements, or other lawful transfer mechanisms.

We retain data only for as long as reasonably necessary for the purposes described in this Policy or as legally required.

Account data:

May be retained while the account is active and for a reasonable period afterward for security, dispute resolution, or legal obligations.

License data:

May be retained for the license relationship and afterward where needed to establish purchase history, prevent reuse or sharing, investigate abuse, enforce license terms, or resolve disputes.

Transaction records:

May be retained for periods required by tax, accounting, financial, or consumer-protection laws.

Security logs:

May be retained for a reasonable period to detect abuse and investigate incidents.

AI Analysis:

Requests, results, or metadata may be retained where needed to provide history, enforce usage limits, troubleshoot issues, improve reliability, or protect the Service. Third-party AI providers may apply their own retention periods.

Support:

Support communications may be retained where reasonably necessary for service history, dispute resolution, and support quality.

When information is no longer required, it may be deleted, anonymized, or securely disposed of.

FX Primer uses reasonable administrative, technical, and organizational measures designed to protect personal data.

Measures may include:

• encrypted connections;
• access controls;
• authentication;
• restricted administrative access;
• managed cloud security;
• logging and monitoring;
• fraud and anti-abuse controls;
• separation of public and privileged credentials.

No internet-based system can be guaranteed completely secure.

FX Primer may analyze technical signals such as:

• IP addresses;
• device/installation identifiers;
• number of environments;
• validation frequency;
• connection patterns;
• geographic/network anomalies;
• license usage history.

These signals may be used to detect unauthorized license sharing, fraud, circumvention, or abuse.

Automated systems may flag unusual activity for internal review. Where usage strongly indicates prohibited sharing or abuse, a license may be suspended or terminated in accordance with the applicable license terms.

FX Primer uses automated systems to:

• generate market analysis;
• enforce usage allowances;
• authenticate requests;
• monitor security;
• identify potentially abusive license activity.

FX Primer AI Analysis is designed to interpret market information, not to evaluate personal characteristics or make decisions about individuals.

We do not intend to use AI Analysis to make solely automated decisions about users that produce legal or similarly significant effects.

Depending on your location, you may have rights including:

• access;
• correction;
• deletion;
• restriction;
• objection;
• portability;
• withdrawal of consent;
• objection to direct marketing;
• opt-out of certain targeted advertising or data sharing;
• non-discrimination for exercising privacy rights;
• complaint to a competent privacy authority.

These rights may be subject to lawful exceptions.

Where GDPR, UK GDPR, Swiss law, or similar law applies, you may have rights to:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• portability;
• withdrawal of consent.

You may also complain to your competent data protection authority.

Where applicable, U.S. state privacy laws may give you rights to:

• know categories of personal information collected;
• know purposes and categories of recipients;
• access;
• correct;
• delete;
• obtain a portable copy;
• opt out of sale;
• opt out of sharing or targeted advertising;
• limit certain uses of sensitive information where applicable;
• appeal certain privacy decisions;
• receive non-discriminatory treatment.

FX Primer does not sell personal data for monetary consideration.

Email:

support@fxprimer.com

Clearly describe your request.

We may request reasonable information to verify identity and protect accounts, which may include:

• account username;
• purchase email;
• order reference;
• License Key or partial License Key;
• other information reasonably necessary to locate the relevant record.

We will respond within the timeframe required by applicable law.

Certain information may need to be retained despite a deletion request where required for legal obligations, fraud prevention, security, license enforcement, or legal claims.

If FX Primer sends optional promotional emails, you may unsubscribe using the method provided in the message or by contacting support.

Operational emails may still be sent when necessary, including:

• order confirmation;
• download delivery;
• license information;
• security notices;
• account recovery;
• service changes;
• support messages.

The Services may contain links to third-party sites, payment providers, MetaTrader/broker services, social platforms, or other services.

FX Primer does not control the privacy practices of independent third parties. Review their privacy policies before providing information.

FX Primer is not directed to children and does not knowingly collect personal data from children where prohibited by law.

If you believe a child has provided personal information without appropriate authorization, contact:

support@fxprimer.com

We may update this Privacy Policy to reflect changes in:

• FX Primer products and Services;
• service providers;
• advertising or analytics technologies;
• security practices;
• legal or regulatory requirements;
• data-processing activities.

The updated Policy will be posted with a revised "Last Updated" date.

For questions, privacy requests, or concerns:

FX Primer

support@fxprimer.com

Cloudflare Website hosting, CDN, DNS, traffic routing, performance, and security.

Supabase Database, authentication, backend APIs, Edge Functions, storage, account/license records, usage data, and service data.

Stripe Payment processing, transaction handling, payment authentication, and fraud prevention.

SendOwl Digital product delivery, secure downloads, delivery emails, digital files, and license-code delivery where configured.

OpenRouter and AI Model Providers Routing and processing AI Analysis requests and generating analysis outputs.

Meta Platforms Facebook/Instagram advertising, Meta Pixel, attribution, measurement, retargeting, and campaign optimization where enabled and legally permitted.

FX Primer aims to:

• collect only information reasonably needed to operate, secure, sell, deliver, and support FX Primer;
• avoid storing full payment card details when specialized payment processors handle them;
• avoid intentionally sending sensitive account/payment information to AI providers;
• use license information to protect legitimate users and prevent unauthorized sharing;
• use advertising technologies transparently and provide legally required choices;
• protect information using reasonable security measures;
• provide privacy rights where applicable;
• retain data only for as long as reasonably necessary or legally required.