Privacy policy

1. Controller

The controller of your data is Proxima Creative Co. LLC, the company that operates OX212. For any privacy matter, write to us at access@ox212.com.

2. What data we use

• Your account: email, the name you want OX to call you, language and password (stored encrypted; nobody can see it).
• Your preparation: the trading accounts you register, their environment, currency and reference capital, and the limits you set.
• Your trading: trades, orders, positions, results, instruments and the state of the accounts you connect or import.
• Your connections: identifiers of your devices and platforms and the access permissions you give us (stored encrypted).
• Your interventions: pauses, their reasons, their outcome and their sealed records.
• Firm mode: when you switch it on, your locks, the sentence you write and your attempts to lift them. Used to make it work and for your own readings.
• Your conversations with OX and the messages you send to support.
• Health data: only if you connect your watch or band; sleep, recovery (heart rate variability, overnight heart rate), heart rate and activity, from Google (Fitbit and Pixel Watch) or Polar.
• Payments:
  • your country and the billing details handled by Stripe;
  • your plan, charges, refunds and disputes;
  • never your card number.
• Sign-in with Google or Discord (if you use it): your email and profile name.
• API keys and agents: the keys you create (stored encrypted) and the log of the calls they make.
• Referrals: if you arrived through a campaign or affiliate link, which one.
• The risk test on ox212.com (if you take it): your name, your email, your answers and what you tell us about your last bad session. You do not need to include health data.
• The newsletter (only if you tick the box): your email and proof of your permission (the text you accepted and when).
• Technical data: IP address, browser, access times and security logs.
• Visits to ox212.com, without cookies: to count visits without storing anything in your browser, our server computes from your IP address and browser an anonymous key that changes every day. The address is not stored. Basis: our legitimate interest in knowing how the website is used.

3. What we use it for and on what basis

• To provide OX212: read your trading, compare it with your limits, show you readings and alerts, answer you through OX and carry out the pauses you authorise. Basis: the contract you accept with the Terms of use.
• To pause your trading: in addition, your express permission, account by account, which you can withdraw at any time (with Firm mode, as soon as the lock in progress ends).
• To take your health data into account: your explicit, separate and revocable consent.
• To keep OX212 secure and prevent abuse. Basis: our legitimate interest in protecting the service and its users.
• To improve the product with aggregated or pseudonymised statistics. Basis: our legitimate interest; you can object by writing to us.
• To meet legal obligations where they exist.
• To charge you, issue your invoices and comply with tax law. Basis: the contract and our legal obligations.
• To prevent fraud and misuse of regional pricing. Basis: our legitimate interest.
• To email you the reading of your risk test (via Resend, from access@ox212.com) and keep your answers so we can help you if you write to us. Basis: your request when taking the test. If you do not sign up to OX212 or subscribe, we delete this data after 12 months.
• To send you Insights articles and OX212 news only if you tick the box. Basis: your consent. You can unsubscribe at any time with the link in each email or by replying "unsubscribe", and we stop writing to you. We never send third-party advertising.
• To improve OX212’s models with what we learn from many traders. We use pseudonymised trading and behaviour data, never health data. Basis: our legitimate interest. You can object with a switch in your settings and we will stop using it for this.
• Reports or indices for third parties: only aggregated data from groups of at least 20 people, from which nobody can be identified. Never health data. Never your individual data.
• Sharing your reading with a firm, academy or mentor: only with your express permission, which you can withdraw. If you allow a firm to pause your account, the firm receives confirmation of each pause: when, what was done and whether it completed.

4. What we never do

• We do not sell your data.
• We do not use it for advertising or share it with advertisers.
• We do not use your health data for anything other than your own readings.
• We do not allow our artificial intelligence providers to train their models on your data.

4a. Automated decisions

OX212 makes automated readings and, if you authorise it, can pause your trading when a rule that you defined is met. You can switch this off at any time (with Firm mode, as soon as the lock in progress ends), ask for a person to review a decision and give us your point of view. We never use these readings to decide anything about you that you did not activate yourself.

5. Who we share it with

Only with providers we need for OX212 to work, acting on our instructions:

• Supabase: database and access management.
• Netlify: application hosting.
• Anthropic (Claude): the language model OX uses to answer your open questions and to prepare draft support replies, which a person always reviews before sending. It only receives the data each answer needs.
• ElevenLabs: the voice of your audio brief, if you use it.
• Resend: sending OX212 emails (notifications and support replies).
• Raiola Networks: the ox212.com mailboxes where we receive what you write to us, in the European Union.
• Apple, Google or Mozilla, depending on your device: delivering the push notifications you turn on. The content travels encrypted and only your device can read it.
• Google / Fitbit: only if you connect your health data.
• Link, a Stripe company (Sold through Link, LLC): handles payments as the seller to you and is independently responsible for payment, billing and purchase-support data.
• Google and Discord: only if you sign in with them.
• Polar Electro Oy (Finland): only if you connect your Polar watch. It sends us your sleep, recovery and activity data, and is independently responsible for the data in your Polar account.
• GitHub: hosts the public mirror of our seals, which contains only fingerprints without personal data.

We also exchange data with the platforms and brokers you connect (for example Tradovate, NinjaTrader or MetaTrader), only to read your account and, if you authorise it, pause it. We may also disclose data if the law requires us to.

6. International transfers

Proxima Creative Co. LLC and several of our providers are in the United States, so your data may be processed there. When it leaves the European Economic Area we do so with safeguards recognised by European law, such as the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses.

7. How long we keep it

• While you have your OX212 account.
• If you delete it, we erase your data within 30 days, except:
  • backups, which disappear in their normal cycle (maximum 90 days);
  • invoices and charges, which we keep for as long as tax law requires (up to 6 years);
  • proof of your acceptances and permissions (what you accepted and when), which we keep pseudonymised for 5 years so that we can defend ourselves if there is a claim.
• We do keep what no longer identifies you: anonymous statistics and patterns from many traders, without your name, account or health data, which cannot be linked back to you. We use them to improve OX212.
• Security logs are kept for a maximum of 12 months.
• If you withdraw your health permission, we erase your stored health data immediately.
• If you withdraw a pause permission, we stop pausing that account from that moment. With Firm mode, you can withdraw it as soon as the lock in progress ends.

7a. If you live in the United States: health data

Some state laws, such as Washington’s My Health My Data Act, give consumer health data special protection. Our Consumer Health Data Policy explains:

• what health data we use (sleep, activity, heart rate and what we infer from them);
• what we use it for (only your own readings);
• where it comes from (your watch or band, via Google, including Fitbit and Pixel Watch, or Polar);
• who we share it with: nobody except the providers that store it for us; we never sell it;
• how to ask to see it, delete it or withdraw your permission.

Collecting it requires your consent, and sharing it with any third party would require a separate one, which we do not ask for today because we do not share it.

8. Your rights

You can download your data (a file with everything that is yours, in JSON and CSV) or delete your account yourself from Settings › Security and privacy. For your other rights, or if you prefer, write to us.

You can ask us to access, correct, delete or export your data in a standard format, to restrict or object to its use, and you can withdraw your consents at any time. Write to access@ox212.com from your account email and we will answer within one month at most. If you think we are not handling your data properly, you can complain to the data protection authority of your country; in Spain, the Agencia Española de Protección de Datos (aepd.es).

9. Security

We encrypt communications, keep the access permissions to your platforms in an encrypted vault, limit who can access data and log sensitive actions. No system is perfect; if an incident affecting your data occurred, we would notify you as the law requires.

So that nobody, not even us, can rewrite your history without it showing, every hour we seal its fingerprints and anchor them in Bitcoin with OpenTimestamps, an open standard. Only salted fingerprints reach those public servers and Bitcoin: numbers that reveal nothing about you. Never your data. If you delete your account, we also delete the salt, and those fingerprints can no longer be linked to you.

10. Cookies

The application only uses technical cookies, essential to keep you signed in and remember your preferences. We do not use third-party analytics or advertising cookies, so we do not ask your permission for them.

11. Minors

OX212 is not intended for anyone under 18 and we do not knowingly collect their data.

12. Changes

Each version is dated. If we change something important, we will tell you and ask you to accept it again.

13. Contact

For any privacy question, write to us at access@ox212.com.