Privacy Policy

This Privacy Policy explains how Jara Trading ("we", "our", "I") collects, uses, stores, and protects personal data when you visit jara-trading.com ("the site"). This policy complies with the EU General Data Protection Regulation (GDPR).

1. Who is the data controller?

The data controller responsible for your personal data is João Jara, operating as Jara Trading, based in Lisbon, Portugal. You can contact me at [email protected].

2. What personal data do we collect?

Data you provide voluntarily

• Free EA request form: name, email, broker, MT5 account number, deposit amount, and any optional notes you include.
• Contact email: any data you choose to share when emailing me at [email protected].

Data collected automatically

• Google Analytics 4 (GA4): anonymized usage data, pages visited, approximate location (country/city), device type, browser, referrer, session duration. This data is processed by Google LLC.
• Netlify hosting logs: IP addresses, request headers, and timestamps for security and operational purposes (kept up to 30 days).

3. Why do we collect this data?

I collect data for the following purposes:

• To deliver the free EA: When you fill the free-ea request form, I need your name, email, broker, and MT5 account number to verify your account under my IB and email you the authorized EA file.
• To improve the site: GA4 helps me understand which content is useful and which pages aren't working well.
• To comply with affiliate disclosure obligations: Tracking which links you click helps me declare affiliate relationships transparently.
• To respond to your inquiries: If you email me, I keep the conversation history to provide consistent support.

4. Legal basis for processing

I process your personal data under the following GDPR legal bases:

• Consent (Art. 6.1.a): for analytics cookies (GA4) — you must accept the cookie banner.
• Performance of a contract (Art. 6.1.b): when you request the free EA, I need your data to fulfill that request.
• Legitimate interest (Art. 6.1.f): for basic site logs (security/operational), to detect abuse, and to maintain affiliate disclosure compliance.

5. Who has access to your data?

Your data is shared only with the following third parties, strictly for the purposes described:

• Netlify Inc. (USA) — hosts the website and stores form submissions. Netlify Privacy Policy.
• Google LLC (Google Analytics) — only if you consent to analytics cookies. Google Privacy Policy.
• Brokers (IC Markets, Roboforex) — only the MT5 account number you submit, to verify it is registered under my IB account. No other personal data is shared with brokers.

I do not sell, rent, or share your personal data with any other third party.

6. International data transfers

Netlify and Google process data in the United States. Both rely on the EU–US Data Privacy Framework and Standard Contractual Clauses as legal mechanisms for international data transfers under GDPR.

7. How long do we keep your data?

• Free EA form submissions: kept indefinitely while the client relationship is active, or until you request deletion.
• Email correspondence: kept for up to 3 years for support continuity, then deleted.
• Netlify access logs: 30 days.
• Google Analytics data: 14 months (default GA4 retention).

8. Your rights under GDPR

You have the following rights regarding your personal data:

• Right of access: request a copy of all data I hold about you.
• Right to rectification: correct inaccurate data.
• Right to erasure ("right to be forgotten"): request deletion of your data.
• Right to restrict processing: ask me to limit how I use your data.
• Right to data portability: receive your data in a machine-readable format.
• Right to object: object to processing based on legitimate interest.
• Right to withdraw consent: change your cookie preferences at any time using the "Cookie settings" link in the footer.

To exercise any of these rights, email [email protected]. I will respond within 30 days.

9. Cookies

This site uses two categories of cookies:

• Essential cookies: required for basic site function (none currently). Cannot be disabled.
• Analytics cookies (GA4): track aggregated visitor behavior. Loaded only after you accept the cookie banner. Cookie names include _ga, _ga_*. You can refuse these cookies at any time without affecting site functionality.

To change your cookie preferences, click the "Cookie settings" link in the footer of any page.

10. Right to lodge a complaint

If you believe your data is being mishandled, you have the right to file a complaint with the Portuguese Data Protection Authority:

Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134, 1º
1200-651 Lisboa, Portugal
www.cnpd.pt

11. Changes to this policy

I may update this policy occasionally. The "Last updated" date at the top will reflect the most recent change. Material changes will be announced in the site footer for at least 30 days.

12. Contact

For any questions about this Privacy Policy or your personal data, contact: [email protected]