Information on the processing of personal data (GDPR)

Last updated: 29 September 2026

This is the short notice required by Art. 13 GDPR. The full description — what data, why, and how we protect it — is in the Privacy Policy.

1. Data controller

Cogmedia Sp. z o.o.

ul. Starzyńska 21, Kiekrz, 62-090 Rokietnica, Poland

NIP (tax ID): 7812029954 · REGON: 520783809 · KRS: 0000942497

District Court Poznań – Nowe Miasto i Wilda in Poznań, 9th Commercial Division of the National Court Register · share capital: PLN 5,000.00

Contact for personal data matters: contact@traderaiassistant.com.

2. Purposes and legal bases

  • Contract (Art. 6(1)(b)) — your account, service features (journal, Milo's analyses and conversations, integrations), subscription, support, answering an access request.
  • Legal obligation (Art. 6(1)(c)) — invoices, accounting, tax, complaints.
  • Legitimate interests (Art. 6(1)(f)) — security, abuse prevention, usage limits, quality control of AI answers, correspondence, establishing and defending legal claims.
  • Consent (Art. 6(1)(a)) — the newsletter and sharing progress with a mentor. You can withdraw consent at any time.

Milo (the AI assistant) analyses your trades and notes to give you feedback — this is profiling. We make no decisions based on it that have legal effects on you (Art. 22 GDPR).

3. Data recipients

We share your data only with those we need to run the service, and only as much as is needed:

  • Server, database and hosting provider — data centre in the EU. This is where the app, sign-in and the traderaiassistant.com website run, where the database and the files you add (e.g. screenshots) are stored, and where server logs record IP addresses and browser details.
  • Cloud backup provider — data centre in the EU. Stores encrypted copies of the database.
  • Google Ireland Ltd (and Google group companies) — in three roles:
    • the Gemini AI model that Milo runs on — it receives your conversations with Milo, trade descriptions, notes and screenshots sent for analysis; Google also provides text-to-speech for voice notes;
    • our business email — your correspondence with us (e.g. to contact@);
    • sign-in with a Google account, if you choose it — Google passes us your email address, name and account ID.
    Google does not host the app or the database.
  • Provider for sending emails from the app — delivers automatic messages: email address confirmation, the password reset link and messages about using your account. It receives your email address, name and the content of that message.
  • Stripe Payments Europe Ltd — payment and subscription processing. You give your card details directly to Stripe — we never see them. For fraud prevention and its own legal obligations, Stripe acts as a separate controller.
  • Technical tooling providers for AI features — monitoring the quality and correctness of AI answers, and auxiliary scoring models. They receive only what is needed for that purpose.
  • Accounting office — invoice and payment data, to the extent required by tax and accounting law.

Separately — only if you switch it on yourself:

  • TopstepX — when you connect your account, we read data from it (trades, account status), and if you turn on the daily lockout, we send the lockout request. The platform never places orders.
  • TradingView — when you connect your account, Milo reads the market data you ask for. An alert in TradingView is created only after you click.
  • Other brokers or exchanges — if you connect an account, read-only.
  • An AI provider with your own key (Anthropic or OpenAI) — the key is optional. If you connect one, the content needed for the analysis goes to the provider you chose, on your account and under its terms.
  • Your mentor or group — if you join a mentor's group and agree to share your progress.

External services have their own terms and privacy policies, which also apply to you.

We may also disclose data to public authorities where the law requires it. We do not sell data or share it with advertisers.

We will provide the current list of entities processing data on request sent to contact@traderaiassistant.com.

4. Transfers outside the EEA

Our servers, database, files and backups are in the EU. Some recipients, however, belong to corporate groups based in the USA — above all Google and Stripe — and data may reach companies in those groups outside the European Economic Area. This also applies to the email sending provider, some technical tooling providers and services you connect yourself.

Such transfers rely on a European Commission adequacy decision (the EU-U.S. Data Privacy Framework — for entities certified under it) or on standard contractual clauses approved by the Commission. You can get a copy of these safeguards by writing to us.

5. Retention

Account data and your content — for as long as you have an account (after deleting your account you have 7 days to change your mind, then we delete it). Billing data — for the period required by tax law (as a rule, 5 years). Newsletter — until you unsubscribe. Contact form messages — until the matter is closed. Details in the Privacy Policy.

6. Your rights

You have the right to access, rectify and erase your data, restrict its processing, port it, object to processing based on legitimate interests (including profiling), and withdraw consent (Art. 15–21 GDPR). Data export and account deletion are in the app's Settings; for anything else, write to contact@traderaiassistant.com. We'll reply within one month at the latest.

Providing data is voluntary, but needed to create an account and buy a plan.

7. Right to lodge a complaint

If you believe we are breaching the GDPR, you can lodge a complaint with the supervisory authority:

President of the Polish Data Protection Authority (UODO)

ul. Stawki 2, 00-193 Warsaw, Poland

uodo.gov.pl

If you live in another EU country, you can also complain to the authority there. But write to us first — it's usually quicker to sort out.