Privacy Policy

1. Data Controller and Legal Basis

1.1. Law and Jurisdiction: The processing of personal data is governed by the laws of the United States and the General Data Protection Regulation (GDPR) of the European Union, as our services are available to users in the EU/EEA.

1.2. Identity of the Data Controller: The Data Controller for your personal data is: Pagüer Management LLC, located at 1209 MOUNTAIN ROAD PL NESTE N ALBUQUERQUE,NM 87110. You can contact us at info@paguertrading.com.

1.3. Legal Basis for Processing (GDPR): The primary legal basis for processing your email is the performance of a contract (Article 6.1.b of the GDPR), which is necessary to provide you with access to the service and manage your account and subscription.

2. Information We Collect

2.1. Registration Data: We collect only your email address for account creation and management. We do not collect sensitive personally identifiable information (full name, postal address, identity documents, etc.).

2.2. Payment Data: Card payments are securely processed by Stripe. Stripe directly collects the data required for the transaction (card number, expiration date, name, and billing address). We do not store, process, or have access to your sensitive credit or debit card information. We only receive a payment token and necessary billing information from Stripe.

3. Use of Information and Analytics

3.1. Purpose of Processing: Your email is used to:

• (a) Provide access to the service.
• (b) Manage your subscription or license status.
• (c) Send service-related communications (changes to Terms, outage notices, security alerts).
• (d) Billing management.

3.2. Web Analytics (Public Site): We use Google Analytics to analyze traffic, visitor behavior, and the performance of our homepage and public landing pages. This analysis is performed anonymously and does not apply to User behavior once they have logged into the private area of the Platform.

3.3. Future Implementation of In-App Analytics: Any future implementation of User behavior analysis tools within the application will be communicated by updating this Policy, ensuring the opportunity to exercise your rights to object or limit processing.

4. Sharing Data with Third Parties

4.1. Data Processors: We share the minimum necessary information with third parties acting as 'Data Processors' to provide our services:

• (a) Stripe, Inc.: For secure payment processing and billing.
• (b) Google Analytics: For performance analysis of our public website.

It is guaranteed that all processors are subject to EU Standard Contractual Clauses (SCCs) or legal frameworks (such as the EU-U.S. Data Privacy Framework) for data transfers to countries outside the European Economic Area (EEA), ensuring a level of protection compatible with the GDPR.

5. User Rights (GDPR)

5.1. Exercise of Rights (GDPR): As a User under the protection of the GDPR, you have the following rights regarding your personal data: (a) Right of Access. (b) Right to Rectification. (c) Right to Erasure ('Right to be Forgotten'). (d) Right to Restriction of Processing. (e) Right to Object. (f) Right to Data Portability.

5.2. Procedure: To exercise any of these rights, please send a clear and detailed request to our privacy contact email: info@paguertrading.com. We will respond to your request within one month, as required by the GDPR.

5.3. Right to Lodge a Complaint: You have the right to lodge a complaint with the competent data protection authority in the EU member state where you habitually reside or the authority where the alleged infringement occurred.