Privacy Policy
Last updated
1. Who is responsible for your data
The data controller is [COMPANY_LEGAL_NAME], [REGISTERED_ADDRESS], Italy (VAT [VAT_NUMBER]). For any privacy question or to exercise your rights, contact [email protected].
2. What we collect and why
We collect only what we need to run the service. Each purpose below has its own legal basis under GDPR Article 6.
| Data | Why we process it | Legal basis | Kept for |
|---|---|---|---|
| Account data — email, username, display name, password hash, language | Creating and running your account, authenticating you | Performance of a contract (Art. 6(1)(b)) | Life of the account, then 30 days |
| Two-factor authentication secrets and recovery codes | Securing your account at your request | Performance of a contract (Art. 6(1)(b)) | Until you disable 2FA |
| Login sessions — IP address, user agent, timestamps | Keeping you signed in, showing you your active sessions, detecting account takeover | Legitimate interest in platform security (Art. 6(1)(f)) | 12 months |
| Content you create — notebooks, datasets, strategies, posts, comments | Providing the features you use and sharing content as you direct | Performance of a contract (Art. 6(1)(b)) | Until you delete it or close your account |
| Cloud compute usage — run duration, hardware type, cost | Enforcing plan limits, billing, and showing you your usage | Performance of a contract (Art. 6(1)(b)) | 24 months (billing records: 10 years, see below) |
| Billing data — plan, subscription status, invoices, partial card details held by Stripe | Taking payment, issuing invoices, meeting tax obligations | Contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)) | 10 years, as Italian tax law requires |
| Audit logs — who changed what and when | Security, fraud prevention, and demonstrating compliance | Legal obligation and legitimate interest (Art. 6(1)(c), (f)) | 24 months |
| Error diagnostics — stack traces, browser and OS version, the URL where an error happened | Finding and fixing faults | Legitimate interest in a working product (Art. 6(1)(f)) | 90 days |
| Product analytics — pages viewed, features used, coarse country | Understanding which features are worth building on | Your consent (Art. 6(1)(a)) — collected only if you accept analytics cookies | 14 months |
| Support correspondence | Answering your question and keeping a record of it | Legitimate interest in supporting users (Art. 6(1)(f)) | 24 months after the ticket closes |
3. What we do not do
4. Content you choose to publish
CandleSniff has social features. Anything you post publicly — a published notebook, a strategy, a post, a comment, your profile — is visible to others and may be indexed by search engines. Think of that material as public. You control the visibility of each item, and you can change it or delete it at any time, though copies may persist in caches or in other users’ screenshots beyond our control.
5. Notebooks and cloud execution
When you run a notebook on Cloud CPU or Cloud GPU, your code and any data it loads are sent to Modal Labs, who run it in an isolated container on our behalf. The container is destroyed when the run ends. We do not read the contents of your notebooks except where you ask us to in support, or where we must investigate a specific abuse report.
Do not put credentials, personal data about other people, or anything you are contractually forbidden to export into a cloud notebook.
7. International transfers
Some processors are in the United States. Where data leaves the EEA we rely on the European Commission’s Standard Contractual Clauses, or on an adequacy decision such as the EU–US Data Privacy Framework where the processor is certified under it. You can ask us for a copy of the safeguards in place by emailing [email protected].
8. How we protect your data
- Passwords are hashed; we never store them in a readable form.
- Sensitive fields such as broker API credentials are encrypted at rest with keys we rotate.
- Traffic is encrypted in transit with TLS.
- Access to production data is limited to staff who need it, and every administrative action is written to an audit log.
- Two-factor authentication is available on all accounts, and we recommend you turn it on.
If a breach occurs that is likely to result in a risk to your rights, we will notify the supervisory authority within 72 hours and tell you directly where the risk is high.
9. Your rights
Under GDPR you have the right to:
- Access — get a copy of the personal data we hold about you. There is a self-service export in your account settings.
- Rectify — correct data that is wrong or incomplete.
- Erase — have your data deleted. Closing your account triggers this; we keep only what tax law obliges us to keep.
- Restrict — ask us to pause processing while a dispute about accuracy or legitimate interest is resolved.
- Port — receive your data in a structured, machine-readable format, or have it sent to another provider.
- Object — object to processing based on legitimate interest, including profiling.
- Withdraw consent — where processing rests on consent, withdraw it at any time. Analytics consent can be changed from the cookie settings link in the footer. Withdrawal does not affect processing already carried out.
Email [email protected] to exercise any of these. We respond within one month, and will tell you if we need longer because the request is complex.
If you think we have handled your data badly, you can complain to the Garante per la protezione dei dati personali, or to the supervisory authority where you live.
11. Children
CandleSniff is not for people under 18 and we do not knowingly collect their data. If you believe a minor has an account, tell us and we will remove it.
12. Changes to this policy
If we change how we use your data in a way that affects you, we will email you or show an in-app notice before the change takes effect. The date at the top of this page always reflects the latest revision.