Legal

Legal Documents

JMarkets Trading · KVK 98128175 · Opsplitting 19, 9502 PJ Stadskanaal, Groningen, The Netherlands

Effective: March 25, 2026 · Last updated: March 25, 2026 · Version 1.0

1. Agreement to Terms

These Terms and Conditions ("Terms") govern your relationship with the Daules application, website at daules.com, and all related services (collectively, the "Service") operated by JMarkets Trading, registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under number 98128175 ("we," "us," "our," or "Daules").

By creating an account, accessing, or using the Service, you agree to be bound by these Terms and accept all legal consequences. If you do not agree to these Terms in whole or in part, do not use the Service.

These Terms apply to all visitors, users, and others who access or use the Service. Supplementary terms, including the Risk Disclosure, Privacy Policy, and Billing and Refund Policy, form an integral part of this agreement.

2. Description of Service

Daules is a behavioral trading journal that uses artificial intelligence to analyze self-reported trading data and help users identify behavioral patterns. The Service includes:

Trade logging, import (CSV/JSON), and visualization
Behavioral DNA profiling (computed behavioral traits scored 0-100 across multiple domains)
AI-powered behavioral analysis (Mirror, distortion detection, chat, journal reflection, session analysis)
Dashboard visualization of trading behavior over time
Session tracking, pre-trade gating, daily/weekly/monthly review tools
Trading account management and optional broker verification

The Service is a self-reflection and pattern-recognition tool. It observes and describes behavioral patterns. It does not prescribe, recommend, or execute any action.

Daules does not provide any trading recommendations. Its functionality is limited to processing the user's trading data and allowing the user to draw conclusions therefrom.

3. Eligibility

You must be at least 18 years old to use the Service. By creating an account, you represent and warrant that:

You are at least 18 years of age
You have the legal capacity to enter into a binding agreement under the laws of your jurisdiction
Your use of the Service does not violate any applicable law or regulation
If acting on behalf of an entity, you have authority to bind that entity to these Terms

4. Account Registration and Security

When you create an account with us, you must provide information that is accurate, complete, and current at all times. Failure to do so constitutes a breach of the Terms, which may result in immediate termination of your account.

You are responsible for safeguarding the password that you use to access the Service and for any activities or actions under your password, whether your password is with our Service or a third-party service
You agree not to disclose your password to any third party
You must notify us immediately upon becoming aware of any breach of security or unauthorized use of your account at support@daules.com
Each user may register only once and maintain one account. Multiple accounts per individual are not permitted
You may not use as a username the name of another person or entity, a name subject to rights of another person or entity without authorization, or a name that is otherwise offensive, vulgar, or obscene

5. Subscriptions

A valid payment method, including credit card, is required to process payment for your subscription. You shall provide Daules with accurate and complete billing information. By submitting such payment information, you automatically authorize Daules to charge all subscription fees incurred through your account to your payment method.

Some parts of the Service are billed on a subscription basis ("Subscription"). You will be billed in advance on a recurring and periodic basis ("Billing Cycle"). Billing cycles are set either on a monthly or annual basis, depending on the type of subscription plan you select.

Should automatic billing fail to occur for any reason, Daules will issue an electronic invoice indicating that you must proceed manually, within a certain deadline date, with the full payment corresponding to the billing period.

For complete details on billing, cancellation, free trials, fee changes, and refunds, see the Billing and Refund Policy.

6. Acceptable Use

You agree not to use the Service to:

Engage in, facilitate, or conceal market manipulation, insider trading, wash trading, spoofing, or any illegal activity
Upload fabricated, falsified, or intentionally misleading trade data to manipulate AI analysis or behavioral scores
Attempt to reverse-engineer, decompile, disassemble, or extract the AI models, system prompts, training data, or proprietary algorithms used by the Service
Use the Service to generate, publish, or distribute content that constitutes financial advice, investment recommendations, or trading signals for third parties
Redistribute, resell, sublicense, or commercially exploit AI-generated analysis, Behavioral DNA data, or any output of the Service
Present AI-generated output as professional financial analysis, psychological assessment, or clinical evaluation
Scrape, crawl, or use automated tools (bots, spiders, scripts) to access the Service without written permission
Interfere with the Service's operation, security, performance, or other users' access
Circumvent rate limits, authentication, or access controls
Upload malware, viruses, or malicious code
Post content that is abusive, defamatory, obscene, fraudulent, deceptive, or in violation of copyright, trademark, or other intellectual property rights
Use the Service if you are under 18 years of age
Violate any applicable law, regulation, or third-party right

We reserve the right to block or remove communications or materials that we determine to be in violation of this section. We may suspend or terminate accounts that violate this policy, with or without notice, depending on severity.

7. Content

7.1 Your Content

The Service allows you to post, store, and otherwise make available certain information, text, graphics, screenshots, or other material ("Your Content"). You are responsible for the Content that you post to the Service, including its legality, reliability, and appropriateness.

You represent and warrant that: (i) the Content is yours or you have the right to use it and grant us the rights and license as provided in these Terms, and (ii) the posting of your Content on or through the Service does not violate the privacy rights, publicity rights, copyrights, contract rights, or any other rights of any person.

You retain full ownership of all trade data, journal entries, reviews, notes, and other content you submit to the Service. We do not claim any ownership interest in Your Content.

By using the Service, you grant us a limited, non-exclusive, non-transferable license to process Your Content solely to provide and operate the Service features you use and to generate AI-powered behavioral analysis at your request. This license terminates when you delete your account.

7.2 AI-Generated Output

AI-generated analysis (Behavioral DNA scores, Mirror reports, chat responses, distortion observations, pattern labels) is generated for your personal use. You may use this output for your own purposes. You may not redistribute, resell, or sublicense AI output to third parties, present AI output as professional financial analysis or clinical assessment, or use AI output to create competing products or services.

7.3 Our Intellectual Property

The Service and all contents, including but not limited to software, AI models, system prompts, algorithms, behavioral trait definitions, scoring methodologies, text, images, graphics, user interface design, trademarks ("Daules," "Behavioral DNA"), and documentation are the property of JMarkets Trading and are protected by copyright, trademarks, database rights, and other intellectual property rights. You may display and copy portions of the material only for your own non-commercial use. Any other use is strictly prohibited.

These Terms grant you a limited, non-exclusive, non-transferable, revocable license to use the Service for your personal, non-commercial trading journal purposes. These Terms do not grant you a license to use any trademark of Daules or its affiliates.

8. AI-Generated Content Disclaimer

The Service uses artificial intelligence (powered by Anthropic's Claude API and internal behavioral models) to generate behavioral analysis. All AI-generated content is:

Clearly labeled as AI-generated within the application
Based on data you provide and may be incomplete, inaccurate, or misleading if input data is incomplete, inaccurate, or unrepresentative
Informational and reflective, not advisory or prescriptive
Subject to the inherent limitations of AI systems, including the possibility of errors, biases, hallucinations, or misinterpretations

You acknowledge and agree that AI-generated behavioral analysis may contain material errors, inaccuracies, or misleading observations. You will not rely on AI output as the sole or primary basis for any financial, trading, investment, or personal decision. Behavioral DNA scores and pattern labels are computational models, not clinical diagnoses or professional assessments.

For full risk information, see the Risk Disclosure.

9. Third-Party Links

The Service may contain links to third-party websites or services that are not owned or controlled by Daules. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You acknowledge and agree that Daules shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods, or services available on or through any such websites or services.

10. Copyright Policy

We respect the intellectual property rights of others. It is our policy to respond to any claim that Content posted on the Service infringes the copyright or other intellectual property of any person. If you are a copyright owner, or authorized on behalf of one, and you believe that copyrighted work has been copied in a way that constitutes copyright infringement, you must submit your notice in writing to support@daules.com with the subject line "Copyright Infringement" and include a detailed description of the alleged infringement. You may be held accountable for damages (including costs and attorneys' fees) for misrepresenting that any Content is infringing your copyright.

11. Limitation of Liability

Please read this section carefully. It limits our liability to you.

11.1 Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, COMPLETENESS, RELIABILITY, NON-INFRINGEMENT, OR COURSE OF PERFORMANCE.

JMARKETS TRADING, ITS SUBSIDIARIES, AFFILIATES, AND ITS LICENSORS DO NOT WARRANT THAT: (A) THE SERVICE WILL FUNCTION UNINTERRUPTED, SECURE, OR AVAILABLE AT ANY PARTICULAR TIME OR LOCATION; (B) ANY ERRORS OR DEFECTS WILL BE CORRECTED; (C) THE SERVICE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS; (D) THE RESULTS OF USING THE SERVICE WILL MEET YOUR REQUIREMENTS; OR (E) ANY TRADING IMPROVEMENTS WILL RESULT FROM USING THE SERVICE.

11.2 Exclusion of Consequential Damages

IN NO EVENT SHALL DAULES (JMARKETS TRADING), ITS DIRECTORS, EMPLOYEES, PARTNERS, AGENTS, SUPPLIERS, OR AFFILIATES BE LIABLE FOR ANY LOSS OR DAMAGE, DIRECT OR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION:

Loss of profits, revenue, or business
Trading losses or missed trading opportunities
Financial harm arising from reliance on AI-generated analysis
Loss or damage to electronic media or data, goodwill, or other intangible losses
Costs of procuring substitute services

RESULTING FROM (I) YOUR ACCESS TO OR USE OF THE SERVICE; (II) YOUR INABILITY TO ACCESS OR USE THE SERVICE; (III) ANY CONDUCT OR CONTENT OF ANY THIRD PARTY ON OR RELATED TO THE SERVICE; (IV) ANY CONTENT OBTAINED FROM OR THROUGH THE SERVICE; OR (V) THE UNAUTHORIZED ACCESS TO, USE OF, OR ALTERATION OF YOUR TRANSMISSIONS OR CONTENT, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), OR ANY OTHER LEGAL THEORY, WHETHER OR NOT WE HAVE BEEN INFORMED OF THE POSSIBILITY OF SUCH DAMAGE.

11.3 Liability Cap

OUR TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING FROM OR RELATED TO THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE GREATER OF: (A) THE AMOUNT YOU PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED EUROS (€100).

11.4 Consumer Protection Preservation

Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law, including: liability for death or personal injury caused by negligence, liability for fraud or fraudulent misrepresentation, liability for gross negligence or willful misconduct (opzet of grove schuld), or any mandatory consumer protection rights under Dutch law (Burgerlijk Wetboek), EU law (Unfair Contract Terms Directive 93/13/EEC, Consumer Rights Directive 2011/83/EU), or equivalent legislation in your jurisdiction.

12. Indemnification

You agree to indemnify, defend, and hold harmless JMarkets Trading, its principals, officers, directors, representatives, employees, contractors, licensors, licensees, suppliers, and agents from and against any claims, losses, damages, obligations, costs, actions, or demands. These include but are not limited to: (a) legal and accounting fees resulting from your use of the Service; (b) your breach of any of these Terms; (c) anything you post or upload to the Service; (d) any activity related to your account, including negligent or illegal conduct by you or any person accessing the Service using your account; and (e) your trading activities and investment decisions.

For EU consumers: This indemnification applies only to the extent that claims arise from your willful misconduct or intentional violation of these Terms. It does not apply to claims arising from normal use of the Service in accordance with these Terms, nor does it limit any mandatory consumer rights under applicable EU or national law.

13. Termination

13.1 Termination by Us

We may terminate or suspend your account in the following circumstances:

For material breach: If you materially violate these Terms (including the Acceptable Use policy), we may suspend or terminate your access immediately upon written notice to your registered email address.
For illegal activity: If your account is used for illegal activity, we may suspend access immediately and report to relevant authorities.
For convenience: We may discontinue the Service with at least 60 days' written notice, during which you may export your data.
For inactivity: If your account has been inactive for more than 24 months, we may close it with 30 days' prior notice and an opportunity to reactivate.

For EU consumers: Except in cases of material breach or illegal activity, we will provide reasonable notice (minimum 30 days) before termination, in compliance with the Unfair Contract Terms Directive (93/13/EEC).

13.2 Termination by You

You may close your account at any time through your account settings or by emailing support@daules.com. You may export your data before closure using the in-app export feature. Upon closure, your personal data is deleted in accordance with our Privacy Policy.

13.3 Survival

All provisions of the Terms that by their nature should survive termination shall survive, including without limitation: intellectual property provisions, warranty disclaimers, limitation of liability, indemnification, and dispute resolution.

14. Dispute Resolution

14.1 Informal Resolution First

Before initiating any formal proceedings, you agree to contact us at support@daules.com and attempt to resolve the dispute informally for at least 30 days.

14.2 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Netherlands, without regard to conflict of law principles.

14.3 Jurisdiction

Any disputes arising from these Terms or the Service shall be submitted to the competent court in the Netherlands.

For EU consumers: If you are a consumer in the EU, you retain the right to bring proceedings in the courts of your country of habitual residence under the Brussels I Regulation (EU No. 1215/2012). Nothing in these Terms affects your statutory rights as a consumer under applicable EU law. Mandatory consumer protection laws of your jurisdiction apply regardless of any other provision in these Terms.

14.4 EU Online Dispute Resolution

The European Commission provides an Online Dispute Resolution platform: https://ec.europa.eu/consumers/odr

15. Non-Waiver of Rights

If you breach any of these Terms and JMarkets Trading chooses not to immediately act, or chooses not to act at all, JMarkets Trading will still be entitled to all rights and remedies at any later date, or in any other situation, where you breach these Terms. JMarkets Trading does not waive any of its rights.

16. General Provisions

Entire Agreement: These Terms, together with the Risk Disclosure, Privacy Policy, and Billing and Refund Policy, constitute the entire agreement between you and Daules regarding the Service and supersede any prior agreements or understandings.
Severability: If any provision is held to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions remain in full force and effect.
Assignment: You may not assign, sublicense, or otherwise transfer any of your rights under these Terms. We may assign our rights and obligations in connection with a merger, acquisition, reorganization, or sale of substantially all assets, with notice to you.
Force Majeure: We are not liable for any failure or delay in performance due to circumstances beyond our reasonable control, including natural disasters, war, terrorism, government actions, pandemics, infrastructure failures, third-party service outages, or internet disruptions.
Notices: Notices to you will be sent to the email address associated with your account. Notices to us should be sent to support@daules.com.
Language: These Terms are drafted in English. If translated into another language, the English version prevails in case of conflict.

17. Changes to These Terms

We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material, we will make reasonable efforts to provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion. Your continued use of the Service after those revisions become effective constitutes acceptance of the revised Terms. If you do not agree to the new Terms, please stop using the Service.

18. Pre-Contractual Information (BW 6:230m)

In accordance with Dutch law on distance contracts (Burgerlijk Wetboek, Boek 6, Title 5, Afdeling 2B), the following pre-contractual information is provided:

Identity: JMarkets Trading, a sole proprietorship (eenmanszaak) registered with the Dutch Chamber of Commerce
KVK number: 98128175
Address: Opsplitting 19, 9502 PJ Stadskanaal, Groningen, The Netherlands
Email: support@daules.com
Main characteristics of the Service: Behavioral trading journal with AI-powered analysis (see Section 2)
Price: As stated on the Pricing page, inclusive of applicable taxes
Payment method: Credit/debit card via Stripe (see Billing and Refund Policy)
Duration: Subscription renews monthly or annually until cancelled
Right of withdrawal: 14-day withdrawal period from date of purchase (see Billing and Refund Policy, Section 8.2)
Complaint procedure: Email support@daules.com. EU ODR: ec.europa.eu/consumers/odr

19. Contact

JMarkets Trading
Opsplitting 19, 9502 PJ Stadskanaal
Groningen, The Netherlands
KVK: 98128175
Email: support@daules.com

Effective: March 25, 2026 · Last updated: March 25, 2026 · Version 1.0

Trading involves significant risk of loss. Please read this entire disclosure carefully before using the Service.

1. General Risk Warning

Trading financial instruments, including but not limited to stocks, options, futures, forex, cryptocurrencies, contracts for difference (CFDs), and other derivatives, involves significant risk and may not be suitable for all investors. There is a possibility of losing all or more than the initial investment. It is important to use risk capital, which is money that can be lost without affecting one's financial security or lifestyle. Only individuals with sufficient risk capital should consider trading.

Past performance is not indicative of future results. No trading strategy, methodology, system, or behavioral analysis can guarantee profits or prevent losses.

2. Not Financial Advice

Daules is not a registered investment adviser, broker-dealer, financial planner, commodity trading adviser, or fiduciary in any jurisdiction.

Daules (JMarkets Trading, KVK 98128175) is not registered with or authorized by the Autoriteit Financiële Markten (AFM), De Nederlandsche Bank (DNB), the European Securities and Markets Authority (ESMA), the U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), the Commodity Futures Trading Commission (CFTC), the UK Financial Conduct Authority (FCA), or any equivalent regulatory authority in any jurisdiction.

Daules is not authorized under the Markets in Financial Instruments Directive II (MiFID II, EU Directive 2014/65/EU), the Alternative Investment Fund Managers Directive (AIFMD), or any equivalent regulation.

Nothing in the Service constitutes investment advice, financial advice, trading advice, tax advice, legal advice, or any other form of professional advice. All AI-generated behavioral analysis, Behavioral DNA scores, Mirror reports, pattern observations, chat responses, and any other output of the Service are for self-awareness and educational purposes only.

3. No Trade Recommendations

The Service does not and will never:

Recommend buying, selling, or holding any security, financial instrument, cryptocurrency, commodity, or derivative
Suggest specific trade entries, exits, or position sizes based on expected returns
Provide price targets, profit forecasts, or portfolio allocation guidance
Recommend trading strategies or timing for market entry or exit
Manage, direct, or influence your trading capital in any way
Provide signals, alerts, or notifications intended to trigger trade execution

Daules is a comprehensive suite of analysis tools designed to support traders in making their own informed decisions. We do not provide recommendations regarding the purchase or sale of securities, nor do we offer trading or investing advice. The platform, along with its features, capabilities, and data, is provided on an "as-is" basis without any warranty.

4. Behavioral Analysis Limitations

AI-generated behavioral insights are computational observations derived from patterns in your self-reported data. They are not:

Psychological diagnoses, clinical assessments, or professional evaluations
Predictions of future behavior, trading performance, or market outcomes
Guarantees that behavioral changes will produce better trading results
Substitutes for professional financial, psychological, or medical counseling

Behavioral DNA scores reflect statistical patterns in historical data you provide. They may be incomplete, inaccurate, or misleading if the underlying data is incomplete, inaccurate, or unrepresentative. Correlation between behavioral patterns and trading outcomes does not imply causation.

5. AI System Limitations

The AI systems used by the Service (powered by Anthropic's Claude API and internal models) are subject to inherent limitations:

AI may generate incorrect, misleading, or contradictory observations ("hallucinations")
AI output quality depends entirely on the data you provide
AI does not have access to real-time market data, news, economic indicators, or information beyond what you input
AI analysis reflects correlations, not causations
AI models may have biases inherited from training data that could affect the nature of observations
AI cannot account for market conditions, black swan events, liquidity, slippage, or execution factors

6. Hypothetical and Historical Performance

Hypothetical performance results have inherent limitations. No assurance is given that any account will or is likely to achieve profits or losses similar to those shown. There can be significant differences between hypothetical performance results and actual trading outcomes.

Hypothetical results are typically prepared with the benefit of hindsight and do not involve financial risk. They cannot fully account for the impact of financial risk in actual trading. Factors such as the ability to withstand losses or adhere to a specific trading program can materially affect actual trading results.

Any performance statistics, win rates, loss rates, R-multiples, or other metrics displayed in the Service are historical calculations based on data you have entered. They describe past results only and are not projections of future performance.

7. Testimonial Disclosure

Testimonials or user experiences featured on the Daules website, application, or marketing materials may not represent the experiences of all users. They do not guarantee future performance or success. Individual results vary. Trading involves risk and may not be suitable for every individual.

8. Your Responsibility

You are solely responsible for:

All trading and investment decisions you make, whether or not influenced by information from the Service
Evaluating the merits and risks of any trade or investment
Verifying the accuracy of any data you input into the Service
Consulting with a qualified, licensed financial professional, tax advisor, and/or attorney before making any financial decisions
Understanding the specific risks of the instruments you trade
Complying with all applicable laws and regulations in your jurisdiction regarding trading and investments

9. Specific Instrument Risks

Futures and Forex: Trading futures and forex involves significant risk and may not be suitable for all investors. Leverage can work against you as well as for you. Investors may lose all or more than their initial investment.
Options: Options involve risk and are not suitable for all investors. The risk of loss in trading options can be substantial.
Cryptocurrencies: Cryptocurrency markets are highly volatile, largely unregulated, and subject to unique risks including but not limited to technology failures, regulatory changes, and market manipulation.
CFDs: CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. Between 74% and 89% of retail investor accounts lose money when trading CFDs (source: ESMA, based on broker disclosures required under MiFID II). You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money. Check with your broker for their specific retail loss percentage.
Prop Firm / Funded Accounts: Evaluation and funded trading account results may differ materially from live personal trading due to differences in risk parameters, psychological pressure, and capital constraints.

10. No Guarantees

Daules makes no guarantees, representations, or warranties of any kind regarding the outcome of any trading activity, the accuracy of behavioral analysis, or the effectiveness of any behavioral pattern identification. Use of the Service does not guarantee improved trading results, consistency, risk management, or profitability. The Service is a tool for self-awareness. It shows you patterns. What you do with that information is entirely your responsibility.

11. Consult Professionals

We strongly encourage users to consult with appropriate professionals in finance, taxation, accounting, and legal matters before making any financial decisions. Information presented within the platform or associated with it should not be considered as investment, tax, accounting, or legal advice.

Effective: March 25, 2026 · Last updated: March 25, 2026 · Version 1.0

The short version. Your data is yours. You can export, correct, or delete it at any time. We do not sell your data. Anthropic (our external AI provider) does not train on your data. Our own internal machine learning models do train on your trade data to personalize your analysis. We do not give financial advice.

1. Data Controller

JMarkets Trading, registered with the Dutch Chamber of Commerce (KVK) under number 98128175, located at Opsplitting 19, 9502 PJ Stadskanaal, Groningen, The Netherlands ("we," "us," "our") operates the Daules behavioral trading journal at daules.com and associated services (the "Service"). We are the data controller responsible for your personal data under the EU General Data Protection Regulation (GDPR), the Dutch GDPR Implementation Act (Uitvoeringswet AVG, UAVG), the UK General Data Protection Regulation (UK GDPR), and applicable data protection laws.

Data Protection Contact:
Email: privacy@daules.com
For data subject access requests, use the subject line "DSAR Request."

Data Protection Officer: Given the current scale of our operations, we have not appointed a Data Protection Officer under GDPR Art. 37. We monitor whether our processing activities meet the threshold requiring DPO appointment as the service grows. All data protection inquiries are handled directly by the data controller at privacy@daules.com.

2. Data We Collect

2.1 Account Data

Email address — required for authentication and account recovery
Display name — optional, used for personalization
Profile photo — optional, stored in encrypted cloud storage
Authentication metadata — session tokens, login timestamps, two-factor authentication status

2.2 Trade Data (User-Provided)

You provide trade data by manual entry or CSV/JSON import. Trade data includes:

Trade execution details: symbol, direction (long/short), entry price, exit price, stop loss, take profit, position size, profit/loss, R-multiple, duration, session timing
Self-reported behavioral context: pre-trade emotion, confidence level, urgency, clarity, planned entry status, FOMO flag, revenge flag, forced entry flag, thesis statement, invalidation notes
Post-trade data: post-trade emotion, exit type, system adherence rating, deviation notes
Media: trade screenshots you upload

2.3 Trading Account Metadata

Information about your trading accounts: account name, type (evaluation, funded, personal), broker name, currency, balance, status, evaluation parameters, and payout history.

2.4 Journal Entries, Reviews, and Notes

Free-form text you write: journal entries, daily/weekly/monthly reviews, session notes, pre-trade theses, and post-trade reflections.

2.5 Payment Data

Payment processing is handled entirely by Stripe, Inc. We never see, receive, or store your credit card number, CVV, or bank account details. We store only: Stripe customer ID, subscription ID, plan type, billing cycle dates, and trial status.

2.6 Technical and Usage Data

Technical data: IP address, browser type, device type, operating system, screen resolution, referral URL
Usage analytics: Feature interactions, page views, and session duration collected through PostHog (see Section 9: Cookies)

3. How We Use Your Data

Processing Activity	Legal Basis (GDPR Art. 6)
Account creation and authentication	Contract (Art. 6(1)(b))
Trade logging, journaling, dashboards	Contract (Art. 6(1)(b))
AI behavioral analysis (DNA, Mirror, Chat, distortion detection)	Contract (Art. 6(1)(b)) — core feature
Behavioral profiling (DNA scores, pattern detection)	Contract (Art. 6(1)(b))
Training internal machine learning models (state-outcome prediction, distortion classification, anomaly detection) on your trade data and behavioral signals	Contract (Art. 6(1)(b)) — core feature that improves your personal analysis over time
Training population-level ML models using aggregated data across users to improve pattern detection accuracy for all users	Contract (Art. 6(1)(b)) — integral to providing accurate behavioral analysis
Payment processing	Contract (Art. 6(1)(b))
Transactional emails (verification, password reset)	Contract (Art. 6(1)(b))
Product analytics (feature usage, page views via PostHog). Legitimate interest: understanding how the product is used to improve features and fix issues. Balancing test: data is anonymized, does not include trade data or journal content, and the impact on user privacy is minimal. You may opt out in account settings.	Legitimate interest (Art. 6(1)(f))
Security, abuse prevention, rate limiting. Legitimate interest: protecting the Service and all users from unauthorized access, abuse, and attacks. Balancing test: processing is limited to technical identifiers (user ID, IP, request metadata) and is necessary to maintain service integrity. The security interest of all users outweighs the minimal privacy impact.	Legitimate interest (Art. 6(1)(f))
Tax and financial record retention	Legal obligation (Art. 6(1)(c))

4. How Our AI Works

4.1 What the AI Sees

When you use AI features, the following data is sent to our AI provider:

Summarized trade data: symbol, direction, profit/loss, timing, duration, behavioral flags, self-reported context
Journal and review text you have written
Computed behavioral signals derived from your trade patterns

4.2 What the AI Does NOT See

Your email address or name
Your payment information
Your broker credentials
Your IP address or device information

4.3 Who Processes It

AI analysis is performed by Anthropic, PBC (San Francisco, CA, USA) through their Claude API. Anthropic acts as a data processor on our behalf.

Anthropic does not train on your data. Under Anthropic's API Terms and our Data Processing Agreement, data submitted through the API is not used to train, improve, or develop Anthropic's AI models. Anthropic may retain API data for up to 30 days solely for trust and safety monitoring, after which it is deleted.

4.4 Internal Machine Learning Models

In addition to the external AI provider (Anthropic), Daules trains and operates its own internal machine learning models. These models run on our infrastructure, not on Anthropic's.

State-outcome prediction: Gradient-boosted decision trees that learn from your trade data (pre-trade state, behavioral flags, timing) to predict outcome patterns. Trained on your data to personalize analysis.
Distortion classifier: Detects discrepancies between what you write in journal entries and what your trade data shows. Trained on labeled examples across the user base.
Anomaly detection: Autoencoder models that identify unusual behavioral patterns (e.g., sudden changes in position sizing, timing, or risk behavior). Trained per user.
Sequence models: Pattern detectors that identify behavioral sequences (revenge cascades, tilt states, FOMO chains) from trade timing and outcomes.

How training works: A nightly process runs at 03:00 UTC. It collects trade data and behavioral signals, trains updated models, validates them against prior performance, and promotes improved models to active use. Models that do not improve are discarded.

What data is used: Your trade execution data, self-reported behavioral context (emotions, flags, confidence), journal text features, and computed behavioral signals. Your email, name, payment information, and IP address are never used in model training.

Per-user vs. population models: Some models (state-outcome, anomaly) are trained on your individual data to personalize your experience. Others (distortion classifier) are trained on aggregated data across users. Both types of training are integral to the Service you subscribe to: per-user models personalize your analysis, and population models establish behavioral baselines that make individual analysis meaningful. The legal basis for all ML training is contract performance (GDPR Art. 6(1)(b)).

4.5 Behavioral Profiling Disclosure (GDPR Art. 13(2)(f))

Daules performs automated profiling as defined under GDPR Art. 4(4). Your trade data is processed to evaluate behavioral aspects including decision-making patterns, emotional regulation, risk management tendencies, and consistency over time.

This profiling does not produce legal effects or similarly significant effects on you (Art. 22(1)). It does not determine eligibility for any product or service, affect your credit score, restrict your access to any feature, or execute any trade. You have the right to request human review of any AI-generated assessment by contacting privacy@daules.com.

5. Third-Party Sub-Processors

Sub-Processor	Purpose	Location	Transfer Mechanism
Anthropic, PBC	AI behavioral analysis (Claude API)	United States	EU-US DPF / SCCs
Supabase, Inc.	Database, authentication, file storage	United States / EU	EU-US DPF / SCCs
Stripe, Inc.	Payment processing	United States	EU-US DPF / SCCs
Resend, Inc.	Transactional email	United States	SCCs
PostHog, Inc.	Product analytics	United States / EU	EU-US DPF / SCCs
Functional Software (Sentry)	Error monitoring	United States	SCCs
Upstash, Inc.	Rate limiting	United States	SCCs
Vercel, Inc.	Hosting and CDN	United States / Global	EU-US DPF / SCCs

We have executed Data Processing Agreements (DPAs) in accordance with GDPR Art. 28 with all sub-processors listed above. Each DPA requires the sub-processor to process personal data only on our documented instructions, implement appropriate technical and organizational security measures, and assist with data subject rights requests.

We will notify you of material changes to sub-processors by updating this Privacy Policy. For material additions, we will provide email notification at least 14 days before the new sub-processor begins processing your data.

We do not sell your personal data. We do not share your trade data, journal entries, behavioral analysis, or Behavioral DNA scores with any third party for their own commercial purposes.

6. International Data Transfers

Your personal data may be transferred to the United States for processing by our sub-processors. These transfers are protected by:

EU-US Data Privacy Framework (DPF): Where sub-processors have self-certified (Implementing Decision (EU) 2023/1795)
Standard Contractual Clauses (SCCs): Module 2 (Controller to Processor) per Commission Decision (EU) 2021/914
UK International Data Transfer Agreement (IDTA): For transfers from the UK

Transfer Impact Assessments have been conducted for each cross-border transfer. Available upon request to privacy@daules.com.

7. Data Retention

Data Category	Retention Period
Account data, trade data, journals, reviews	Active account + 30 days after deletion
Behavioral DNA snapshots	Active account + 30 days
AI call logs (metadata)	12 months, then auto-purged
Product analytics (PostHog)	12 months, then auto-purged
Error logs (Sentry)	30 days
Rate limiting data (Upstash)	1 hour (auto-expires)
Temporary tokens (password reset, 2FA)	15 minutes (auto-expires)
Payment and billing records	7 years (Dutch tax law, Algemene wet inzake rijksbelastingen)
Data at Anthropic API	Up to 30 days (safety retention), then deleted
Backups containing personal data	60 days after account deletion
Anonymized, aggregated behavioral patterns	Indefinite (not personal data)

8. Data Security

Encryption in transit: TLS 1.2+ on all connections
Encryption at rest: AES-256 on all database storage
Row-Level Security: PostgreSQL RLS on every table, filtered by authenticated user ID
Authentication: Secure session management with HTTP-only cookies. Optional two-factor authentication.
Rate limiting: All API endpoints rate-limited per user
Access control: Production database access restricted to authorized personnel via RBAC

9. Cookies and Tracking

9.1 Strictly Necessary (No Consent Required)

Authentication session cookie (Supabase Auth)
CSRF protection token
Cookie consent preference

9.2 Analytics (Consent Required for EEA/UK)

PostHog: Product analytics tracking feature usage and page views. Does not track trade data or journal content. Opt out in account settings or via browser extension.

9.3 What We Do NOT Use

No advertising cookies, retargeting pixels, social media tracking pixels, or third-party marketing trackers. No cross-site tracking or real-time bidding.

10. Your Rights

10.1 Rights for All Users

Access: Request a copy of all personal data we hold about you
Correction: Correct inaccurate or incomplete data
Deletion: Delete your account and all associated data
Data portability: Receive your data in a structured, commonly used, machine-readable format (CSV/JSON) via the in-app export feature, and transmit it to another controller
Opt out of product analytics: Disable PostHog tracking in your account settings or via a browser extension

10.2 Additional Rights for EEA, UK, and Swiss Residents

Under the GDPR, UK GDPR, and Swiss Federal Act on Data Protection (nFADP/revDSG, in force since September 1, 2023), you also have the right to:

Restriction of processing (Art. 18)
Data portability (Art. 20) — structured, commonly used, machine-readable format
Object to processing (Art. 21) — for legitimate interest processing
Withdraw consent (Art. 7(3)) — without affecting lawfulness of prior processing
Automated decision-making (Art. 22) — right to human review of AI assessments
Lodge a complaint with your local supervisory authority. In the Netherlands: Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). In the UK: ico.org.uk

10.3 California Residents (CCPA/CPRA)

California residents have the right to know, delete, correct, and opt out of sale/sharing of personal information. We do not sell or share personal information as defined under the CCPA. Contact privacy@daules.com with subject "CCPA Request."

10.4 Other US State Privacy Laws

Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and other states with comprehensive privacy laws have similar rights. Contact privacy@daules.com.

10.5 Response Times

GDPR/UAVG: 30 days (extendable by 60 days with notice). CCPA: 45 days (extendable by 45 days). UK GDPR: 30 days.

11. Children's Privacy

The Service is not directed at individuals under 18. We do not knowingly collect personal data from anyone under 18. If we learn we have collected data from a person under 18, we will delete it within 72 hours.

12. Data Breach Notification

In the event of a personal data breach, we will notify the Autoriteit Persoonsgegevens within 72 hours where required under GDPR Art. 33, and notify affected individuals without undue delay if the breach is likely to result in high risk to rights and freedoms (GDPR Art. 34).

13. Do Not Sell My Personal Information

We do not sell your personal information. We do not share personal information for cross-context behavioral advertising. We honor the Global Privacy Control (GPC) signal.

14. Changes to This Policy

Material changes: email notice at least 30 days before taking effect. Non-material changes: updated on this page with a new date.

15. Contact

JMarkets Trading
Opsplitting 19, 9502 PJ Stadskanaal
Groningen, The Netherlands
KVK: 98128175
Privacy: privacy@daules.com
General: support@daules.com

Lead Supervisory Authority: Autoriteit Persoonsgegevens
Bezuidenhoutseweg 30, 2594 AV Den Haag, The Netherlands
autoriteitpersoonsgegevens.nl

EU Online Dispute Resolution: https://ec.europa.eu/consumers/odr

Effective: March 25, 2026 · Last updated: March 25, 2026 · Version 1.0

1. Accepted Payment Methods

We accept credit card and debit card payments processed through Stripe, Inc. All payment information is handled directly by Stripe. We never see, store, or have access to your full card number, CVV, or bank account details.

2. Billing Process

When you sign up for a recurring subscription plan, you will be billed every calendar month or annually from the date of purchase until you cancel. You will be billed in advance on a recurring basis at the beginning of each billing cycle.

Should automatic billing fail for any reason, we will notify you via email. You must complete payment manually within the deadline indicated. If payment is not received, your access to paid features may be suspended.

3. Subscription Plans

The Service may be offered under free and paid subscription plans. Features, limitations, and pricing for each plan are described on our Pricing page. By subscribing, you authorize recurring charges to your payment method until you cancel.

4. Free Trial

JMarkets Trading may, at its sole discretion, offer a subscription with a free trial for a limited period. At any time and without notice, JMarkets Trading reserves the right to modify the terms of the free trial offer or cancel such offer.

If offered, free trials convert to a paid subscription at the stated price unless cancelled before the trial ends. We will remind you via email before the trial expires.

Free trial limitations may include restricted access to certain features, as described at the time of signup.

5. Upgrading and Switching Subscriptions

You may upgrade or switch your subscription plan at any time from your account settings. When upgrading:

The amount due for the new subscription will be prorated based on the number of days remaining in your current billing period
You will gain immediate access to the upgraded plan's features

When downgrading:

The change takes effect at the end of your current billing period
You retain access to higher-tier features until the period expires

Contact support@daules.com if you need help changing your subscription.

6. Fee Changes

JMarkets Trading may modify subscription fees at any time. Any fee change will become effective at the end of the then-current billing cycle. We will provide at least 30 days' prior notice of any fee change to give you an opportunity to cancel your subscription before the change takes effect.

Your continued use of the Service after the fee change comes into effect constitutes your agreement to pay the modified fee. Price changes do not apply retroactively to the current billing period.

We value continued support. Subscribers with uninterrupted subscriptions continue to enjoy their current rate. However, if a subscription lapses or is cancelled and later restarted, the current published rate will apply.

7. Cancellation Policy

You may cancel your subscription at any time. To cancel:

Go to your account settings and click "Cancel Subscription," or
Email support@daules.com

Cancellation is effective at the end of the current billing period. You retain access to paid features until the period expires. No dark patterns. No retention loops. One action to cancel.

JMarkets Trading is not responsible for continued charges should you forget to cancel. It is your responsibility to confirm cancellation.

8. Refund Policy

8.1 General Policy

Paid subscription fees are generally non-refundable. We do not offer prorated refunds for partial billing periods, except where required by applicable law.

8.2 EU Right of Withdrawal

If you are a consumer in the European Union, you have a 14-day right of withdrawal from the date of purchase under the Consumer Rights Directive (2011/83/EU) and Dutch law (Burgerlijk Wetboek, Boek 6, Afdeling 2B).

If you begin using the Service immediately upon purchase, you expressly consent to the performance of the Service beginning before the withdrawal period expires, and you acknowledge that you lose your right of withdrawal once the Service has been fully performed during that period.

To exercise withdrawal within 14 days, you may use the following model withdrawal form or any other clear statement:

Model Withdrawal Form

To: JMarkets Trading, Opsplitting 19, 9502 PJ Stadskanaal, The Netherlands (support@daules.com)

I hereby give notice that I withdraw from my contract for the provision of the Daules service.

Ordered on / received on: [date]

Name of consumer: [your name]

Address of consumer: [your address]

Email address associated with account: [your email]

Signature (only if sent on paper): _______________

Date: [date]

If eligible, reimbursement will be provided within 14 days using your original payment method. If services commenced during the withdrawal period, you may be charged a reasonable amount proportional to the services already provided.

8.3 Technical Issues

If you experience a technical issue that prevents you from using the Service for a material portion of your billing period, contact support@daules.com. We will work to resolve the issue. If we cannot resolve it within a reasonable time, we may issue a credit or refund at our discretion.

8.4 Refunds Required by Law

Refunds are always provided where required by applicable consumer protection law in your jurisdiction, including but not limited to mandatory EU consumer rights.

9. Account Deletion and Data

Upon cancellation and account deletion:

You may export all your data (trades, journals, reviews) in CSV/JSON format before deletion
Personal data is deleted within 30 days of deletion request
Backups containing your data are purged within 60 days
Payment and billing records are retained for 7 years as required by Dutch tax law
Anonymized, aggregated data (not personal data) may be retained indefinitely

For full details, see the Privacy Policy.

10. Disputes and Chargebacks

If you believe a charge is incorrect, please contact support@daules.com before initiating a chargeback with your bank or card issuer. We will investigate and resolve billing disputes promptly. Chargebacks initiated without prior contact may result in account suspension pending resolution.

11. Contact

For billing questions, cancellation assistance, or refund requests:

JMarkets Trading
Opsplitting 19, 9502 PJ Stadskanaal
Groningen, The Netherlands
KVK: 98128175
Email: support@daules.com