Privacy Policy
Last updated: February 2026
Data Controller
The data controller for this service is atech (Entreprise individuelle), SIRET 931 848 618 00019, based in Vannes, France. Contact: atech.contact@proton.me
Our Commitment
Cortex is committed to protecting your privacy. We collect minimal data and do not track individual users. This policy explains what information we collect, why, and on what legal basis.
Information We Collect and Legal Basis
We apply the principle of data minimization: we only collect data that is strictly necessary to provide the service.
| Data | Purpose | Legal basis (GDPR Art. 6) | Retention |
|---|---|---|---|
| Email address | Account authentication | Contract performance (Art. 6(1)(b)) | Until account deletion |
| Telegram user ID | Premium channel access management | Contract performance (Art. 6(1)(b)) | Until account deletion or unsubscription |
| Stripe customer ID | Subscription management | Contract performance (Art. 6(1)(b)) | Until account deletion |
| Server logs (IP, browser, timestamps) | Security, abuse prevention | Legitimate interest (Art. 6(1)(f)) | 30 days |
| Aggregated page views | Service improvement | Legitimate interest (Art. 6(1)(f)) | Indefinite (no personal data) |
We do not store payment card details. All payment data is processed and stored exclusively by Stripe in accordance with their privacy policy.
Analytics
We use Counter.dev, a privacy-friendly analytics service. Counter.dev does not use cookies and does not collect personal data. It only provides aggregated statistics about page views and traffic sources.
Hosting and Sub-processors
All data is processed and stored within the European Union. We use the following sub-processors:
- Hetzner Online GmbH (Germany) — Website and backend hosting
- Supabase Inc. (EU region) — Database, authentication, and user profiles
- Stripe Inc. (EU processing) — Payment and subscription management. Stripe acts as a data processor under a Data Processing Agreement (DPA).
- Telegram Messenger Inc. — Premium channel delivery (Telegram user ID shared only for channel access management)
- Counter.dev — Privacy-friendly aggregated analytics (no personal data)
No personal data is transferred outside the EU/EEA without appropriate safeguards (Standard Contractual Clauses).
Cookies
Cortex uses only essential cookies required for authentication (session management). We do not use tracking cookies and do not track you across websites or build user profiles.
Your Rights (GDPR)
Under the General Data Protection Regulation (EU 2016/679), you have the following rights:
- Right of access (Art. 15) — Obtain a copy of the personal data we hold about you
- Right to rectification (Art. 16) — Correct inaccurate personal data
- Right to erasure (Art. 17) — Delete your account and all associated data
- Right to data portability (Art. 20) — Receive your data in a structured, machine-readable format
- Right to restriction (Art. 18) — Restrict processing of your data in certain circumstances
- Right to object (Art. 21) — Object to processing based on legitimate interest
You can delete your account and all associated data at any time from your account page. For other requests, contact us at atech.contact@proton.me. We will respond within one month.
If you believe your rights have not been respected, you have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertes), the French supervisory authority: www.cnil.fr.
AI Processing
Cortex uses artificial intelligence models (Claude by Anthropic, Gemini by Google) to generate market observations. These models process publicly available market data only — no personal user data is sent to or processed by these AI models. The AI-generated observations displayed on the dashboard and Telegram channel are produced without any reference to individual user data.
Third-Party Links
Our website contains links to external services (Stripe, Telegram). We are not responsible for the privacy practices of these third-party websites. We encourage you to review their privacy policies.