Privacy Policy & Cookie Statement. What is stored, where, and who else is involved.

This policy explains what personal data Vink (“Vink”, “we”, “us”) collects when you use vinkjournal.com and the Vink trading-journal application (the “Service”), why we collect it, who we share it with, and the rights you have under the EU General Data Protection Regulation (GDPR).

1. Who we are (data controller)

The controller responsible for your personal data is:

• Vink Journal, a sole proprietorship (eenmanszaak) under Dutch law
• Chamber of Commerce (KvK) number: 99781956
• VAT (BTW) number: NL005410553B66
• Address: Jan Steenstraat 6, 5143 GR Waalwijk, Nederland
• Privacy contact: privacy@vinkjournal.com

2. What data we collect

• Account data — your email address, an optional display name, and a securely hashed password. Your password is never stored in plain text.
• Content you create — the trades, accounts, tags, notes, mental-state entries, reviews, portfolio holdings, and screenshots you add to your journal. A review also keeps the figures it showed you when you saved it. Your own verdict on a trade (a good trade, a mistake, or bad luck) is kept with the trade, whether you gave it in a review or on the trade’s page. A focus you set from Stats is kept too: its words, the finding or rule it came from, and when you set it. If you answer “kept it?” from the phone before your review, that answer is kept with the focus it was about.
• Sleep, energy and stress ratings — only if you switch them on — three ratings from 1 to 10 in your mental journal’s morning plan. Because this can count as information about your health, we store it only with your explicit consent (see section 3).
• Settings you choose — your theme, your timezone, your review-reminder schedule, your daily loss limit, your email preferences, and what an accountability peer is allowed to see.
• Accountability connections — if you invite someone, the email address you invited and, once they accept — with a Vink account of their own, or with a code we email them — the connection between you, when they last opened your dashboard if they have no account, and any messages they send you. See section 5.
• Survey answers — if you answer one of our occasional surveys, what you answered, stored against your account so that each person answers once. Answering is always optional, and your answers are deleted with your account.
• Payment data — we never see your full card number. When you subscribe we create a customer record for you in our Stripe account (your email address and your Vink account ID), and Link’s checkout then collects your payment details directly from you — see section 5. In our own database we keep only a Stripe customer reference, a subscription reference and which plan you are on.
• Technical & usage data — data needed to run the Service securely, such as your IP address (for rate-limiting and abuse prevention), plus privacy-friendly performance and page-visit statistics that use no cookie and no persistent identifier (see section 10).
• When you last used Vink — a single timestamp on your account, updated at most once an hour while you are signed in. We use it for two things: to see how many people are actively using the Service and which features are worth building on, and to send you one reminder if you have not opened Vink for about two weeks (see section 3 — you can switch that off). It is overwritten each time, so it records that you were here, never a history of where you went. In our admin view it appears next to your account, with which features you have used — never what you wrote in them, and the mental journal only as a total across everyone. It is deleted with your account.
• Where you came from — if you reached Vink through one of our own short links (the kind we put under a video or in a profile), a cookie remembers which link for 30 days, and if you then create an account we record it on the account: the platform and the post. If you answer the optional “How did you hear about Vink?” question when you sign up, we keep that answer too. Neither is used for anything that touches you — no mail, no pricing, no feature reads it — only to learn which of our posts bring people in. Both are deleted with your account.
• The demo without an account — if you try the chart reader at /try, we keep the email address you give, the date, which short link (if any) brought you, how many reads you have used, whether the result mail has been sent, and — if you ticked the box for product updates — when we sent the one email asking you to confirm, and whether and when you did. The screenshot you drop is sent to the reader described in section 4, read, and discarded: it is not stored, and no trade is created. Before the demo starts, Cloudflare’s Turnstile checks that the form is being used by a person and not a script: it runs in your browser, Cloudflare sees your IP address and technical signals from your browser for that check, and we receive only whether it passed. We also refuse addresses at known throwaway email services. See sections 3 and 7 for what the address is used for and how long it is kept.
• Cookies and similar storage — see section 10.

3. How we use your data and our legal basis

• To provide the Service (create your account, store and display your journal, calculate your trading statistics) — legal basis: performance of our contract with you.
• To process screenshots with AI (see section 4) — legal basis: performance of our contract.
• To share your figures with a peer you invite, and to email them (the invitation, and loss-limit alerts where you both switch them on) — legal basis: performance of our contract with you, because you asked for it. Your mental journal is shared only with your explicit consent, given separately for each peer, which you can withdraw at any time (section 5). For the person you invite, we rely on our legitimate interest in delivering your invitation and, if they choose to view without an account, in sending them the code they ask for and keeping them signed in on their device; we use their address for nothing else.
• To show how your sleep, energy and stress relate to your trading — only if you switch this on under Settings → Mental journal. Legal basis: your explicit consent (art. 9(2)(a) GDPR), and we record when you gave it. You can withdraw it at any time with the same switch; switching it off deletes every rating you saved. These ratings are used only for your own statistics: they are never shown to an accountability peer and never sent to our AI provider.
• To keep the Service secure (authentication, rate-limiting, preventing abuse) — legal basis: our legitimate interest in keeping the Service and its users’ accounts safe.
• To understand how the Service is used (which features people actually use, so we can improve them and retire what nobody wants) — legal basis: our legitimate interests.
• To take payment for your subscription, and to meet the tax and accounting obligations that follow — legal basis: performance of our contract and legal obligation.
• To send account emails (email verification, password resets, security notices, confirmations of your subscription, cancellation and withdrawal, and the reminder before a trial ends) — legal basis: performance of our contract.
• To handle a withdrawal or a refund request — the statement you send us (your name, email address and, if you give it, your contract number), the date and time we received it, and what we did with it — legal basis: legal obligation (the withdrawal rules in the Dutch Civil Code) and performance of our contract (any other refund you ask us for). You can use this without an account or signing in.
• To keep a record of support exchanges and of the emails we send — legal basis: our legitimate interests in handling follow-up questions, investigating delivery problems and abuse, and defending legal claims (periods in section 7).
• To ask you how Vink is working — occasional short surveys or research requests about your use of the Service — legal basis: our legitimate interests in understanding and improving it. We send these only after offering you the choice — when you created your account, or in the app — and only if you did not opt out. Answering is always optional, and every such message carries a way to opt out. Opting out never affects the account emails above.
• To tell you what has changed in Vink — occasional short product-update notes — legal basis: our legitimate interests in keeping the people who use the Service informed about it. We send these only after offering you the choice — when you created your account, or for accounts from before that, in the app — and only if you did not opt out; every one carries an unsubscribe link, and you can also turn them off in Settings, as a separate switch from the surveys. We record which of these notes you have already been shown, so you are not told the same thing twice.
• To help you get started, and to remind you if you go quiet — in the first week of your trial, at most two short emails: one about a day after it starts if you have not logged a trade yet, and one about a week in summing up what you logged (read from your trades); and, if you have not opened Vink for about two weeks, one email saying your journal is still there — legal basis: our legitimate interests in helping you keep up a habit you signed up for. The first-week notes are sent once each, ever; the quiet reminder is one message per spell away, not a series; none contains promotion. They are one switch. We send them only after offering you the choice — when you created your account, or in the app for older accounts — and only if you did not opt out; every one carries an unsubscribe link, and you can turn them off in Settings.
• To run the demo at /try and send you its result — reading the screenshot you drop, and emailing you what it read, once — legal basis: performance of a contract (you asked for the demo). Your address goes on our product-update list only if you tick the second box on that form and then confirm with the button behind the link in the one email we send to ask — the demo does not check that an address belongs to the person typing it, so ticking the box alone puts it on no list. If you do not confirm, nothing else is sent. Legal basis: your consent, withdrawable at any time through the same link, or the unsubscribe link in every such email.
• To keep the demo from being run by scripts — the Turnstile check and the throwaway-address refusal described in section 2 — legal basis: our legitimate interest in protecting the service from automated abuse, since every demo read is paid for.
• Other marketing email — we do not send it unless you have asked us to. If that ever changes it will be on the basis of your consent, opt-in and withdrawable.

You need to give us your email address and a password to create an account; without them we cannot provide the Service. Everything else you enter is up to you. You are not required by law to give us any personal data.

4. Automatic extraction from your screenshots

When you upload a screenshot for automatic extraction, the image is sent to Anthropic PBC (USA), which reads the chart to suggest the trade details. Anthropic acts as our processor under a data-processing agreement, may not use it to train its models, and deletes it from its systems within 30 days unless it must keep it longer to comply with the law or investigate misuse of its service. The transfer to the United States is covered by the European Commission’s Standard Contractual Clauses. Crop out anything you would rather not have processed, such as an account number. If you prefer not to use AI extraction, you can enter trades manually.

Extraction only suggests values; nothing is saved until you review and confirm it. We do not make decisions about you based solely on automated processing, including profiling, within the meaning of article 22 GDPR.

5. Who we share data with

We do not sell your personal data. It goes to three kinds of recipient: the service providers that help us run Vink, our payment provider, and, only if you choose it, an accountability peer you invite.

Service providers (processors)

These handle your data only on our instructions, each under a data-processing agreement:

• Vercel Inc. (USA) — hosting, and privacy-friendly site statistics; the functions that handle your data run in Frankfurt, Germany;
• Neon (USA; part of Databricks) — our database, holding your journal, located in Frankfurt, Germany;
• Cloudflare, Inc. (USA) — storage of your screenshots, in Western Europe, and the check that the demo at /try is used by a person (Turnstile);
• Anthropic PBC (USA) — reading screenshots you submit for extraction; and
• Resend (USA) — sending our emails.

We will update this list before we add or replace a provider.

Market prices. For your portfolio, our server asks Yahoo Finance and CoinGecko for the prices of the symbols you hold, and Yahoo Finance for the results of a symbol search you type. They receive only the symbols and the search text, from our server — never your name, your account, your IP address or how much you hold.

Our payment provider

Payment is handled through Stripe Managed Payments: your purchase is processed by Stripe’s affiliate Sold through Link, LLC(“Link”) as merchant of record. For the sale, Link is not our processor: Link and its Stripe affiliates collect your name, billing details and card data directly from you at checkout, decides and remits the applicable tax, carries out its own fraud, anti-money-laundering and identity checks, and issues your receipt and invoice in its own name. Link’s own terms state that Stripe and the businesses it sells for are independent controllers of this data, so for it Link’s privacy policy governs, not this one. You can see and manage your orders and payment methods at link.com.

Separately, when you subscribe we create a customer record for you in our own Stripe account (your email address and your Vink account ID). In that account Stripe makes available to us your email address, billing country and address, your subscription status, your invoices, and the type and last four digits of your card — never the full card number. For that information Stripe acts as our processor.

Accountability peers (people you invite)

Vink lets you invite someone to keep you accountable. Nothing is shared until you send an invitation and they accept it, and you can end the connection at any time from Accountability. While a connection is active, that person gets a read-only view which includes:

• your name and the email address on your account;
• whether you are within your daily loss limit today, and your run of days within it;
• summary statistics for the period — number of trades, win rate, profit factor, net R;
• a performance curve over time. The instrument names are removed, but the curve is drawn from your individual trades, so it shows the timing and relative size of each result;
• discipline signals — how often you followed your plan, which risk-related emotions you tagged, and how recently you reviewed;
• only if you switch it on, a short list of recent trades showing the instrument, date and time, direction, and outcome;
• and, only if you switch it on for that peer, your mental journal for the period: each day’s before and after feeling (1–10), the change between them, and the emotions you picked — and, only with a second switch, the notes you typed.

Your mental journal is never shared unless you choose it for a peer. How you feel about your trading can be sensitive, so it is off for every peer, including new ones, and you switch it on for each person separately under Accountability → Visibility; we record when you did. Switching it off, or removing the peer, stops it from their next visit. Your sleep, energy and stress ratings are never part of what a peer sees, even when you share your mental journal.

You control two further things per peer: whether they see cash amounts (with this off, they see R-multiples and percentages but no monetary figures), and the time period their view covers. A peer can send you short written messages. We email a peer when you reach your daily loss limit only if you and that peer have both switched this on — it is off unless you do. We never show a peer your screenshots, your written notes, or your reviews.

Your peer does not need a Vink account. If they have none, opening your invitation sends a six-digit code to the address you invited — never to one typed on the page, so a forwarded invitation opens nothing. The code works for 10 minutes; entering it keeps that browser signed in to your dashboard, and only yours, for 30 days. They see exactly what a peer with an account sees, under the same settings. Your Accountability page shows which peers have no account and when they last opened your dashboard, and removing a peer ends their access on their next visit.

6. International transfers

Some of our providers are based in, or can access data from, the United States. Where the provider is certified under the EU-US Data Privacy Framework — Vercel, Neon, Cloudflare, Resend and Stripe — the transfer relies on the European Commission’s adequacy decision of 10 July 2023, and these providers’ agreements also contain the Commission’s Standard Contractual Clauses. For Anthropic the transfer relies on the Standard Contractual Clauses. You can ask us for a copy of the relevant safeguards at privacy@vinkjournal.com.

7. How long we keep your data

We keep your account and journal data until you delete it — including after a subscription ends, because a lapsed account stays readable rather than being removed (Terms section 9). When you delete your account, your journal is permanently deleted — your trades, screenshots (including the image files themselves), tags, accounts, reviews, portfolio, any accountability connections, any survey answers you gave, and the record of which product updates you were shown. This happens immediately, not on a queue.

Some things deliberately outlive your account, and you should know which — and for how long:

• Support correspondence — if you have emailed our support address, that exchange is kept, with your account no longer linked to it, for 24 months after the last message in it.
• A log of the emails we have sent you — things like password resets and verification links — for 12 months, so we can investigate delivery problems and abuse.
• Invoices, accounting records and the customer record in our Stripe account — for seven years, which is the retention period Dutch tax law requires of us (fiscale bewaarplicht, art. 52 AWR). We cannot delete these on request during that period. Link’s own records are Link’s: ask Link to access or delete them. If you ask Link to delete your data, Link may also delete the copy held in our Stripe account; we keep the accounting records the law requires in our own books.
• Your email choices — each time you choose whether to receive product updates, surveys and the inactivity reminder (at sign-up, in the app, in Settings or through an unsubscribe link), we keep a record of what you chose, when, and which wording you were shown, together with your email address, for five years — also after you delete your account — so we can prove what you agreed to.
• The confirmation of your contract — that we sent it, when, and which version of these Terms it carried — for seven years, with the billing records above, as the record of what was agreed.
• A withdrawal or refund request you made — for seven years, with the billing records above, as the record that it reached us in time and was honoured. If you delete your account, it is kept with your account no longer linked to it.
• An invitation you sent that was never accepted — the invited address is deleted 30 days after the invitation expires.
• A peer who views without an account — their address, their loss-limit email choice, when they last viewed and their messages are kept while the connection exists, and deleted when you remove them, when they stop, or when you delete your account. A code is deleted once it is used or replaced, and is useless after 10 minutes.
• An email address you gave the demo at /try — for 90 days, then deleted by the retention job, unless you create an account with it first, in which case the demo record is deleted at that moment and the account carries on under this policy.
• IP addresses used for rate-limiting — kept only for the length of the limit (at most 24 hours) and deleted within a day after that.
• A security log — when something looks like an attack or abuse (repeated failed sign-ins, a forged request, a flood of form submissions, reaching a usage limit) and when you sign in on the phone app, we record what happened and when, with the IP address and, if you were signed in, your account — for 30 days, to detect and investigate abuse. Entries linked to your account are deleted when you delete it.
• Backups — a deleted account can persist in our database provider’s backups until they expire, which is at most 30 days.
• Hosting request logs — our host keeps a log of requests to the Service, including your IP address, for 12 hours, to run and secure it.

If you want support correspondence or the email log removed sooner, email us at privacy@vinkjournal.com and we will do it unless we are required to keep it.

8. How we protect your data

Passwords are never stored in plain text. They are salted and hashed with a deliberately slow algorithm, chosen so that a stolen database would be expensive to attack rather than merely encoded. Connections are encrypted in transit with TLS. Your screenshots are private to your account and served only through an authenticated, owner-scoped proxy, never via public links. Access to production systems is limited.

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• correct inaccurate data;
• erase your data (“right to be forgotten”);
• receive a portable copy of your data;
• restrict or object to certain processing; and
• withdraw consent where processing is based on consent.

You can exercise two of these directly in the app at any time: Settings → Export my data (portability) and Settings → Delete account (erasure). Both keep working if your subscription ends and your account becomes read-only — that is a commitment in our Terms, section 9. The export is a JSON file containing your account details and settings, every trade with its notes and mental-state entries, your mental journal and tilt checks, your tags, accounts (with their prop-firm rules and risk), rotations, reviews and portfolio, your accountability peers and what each one sees, your support-form messages, your survey answers, the findings you pinned or dismissed, the focuses you set from Stats and your “kept it?” answers; screenshot image files are not in it, so ask us if you want those too. For any other request, contact us at privacy@vinkjournal.com.

We answer requests free of charge, without undue delay and within one month of receiving them. If a request is complex, or we receive many, we may extend this by up to two further months; we will tell you within the first month and explain why. To protect your account, we will ask you to send the request from the email address on your account, or otherwise confirm it is you; we only ask for what we need to verify your identity. If a request is manifestly unfounded or excessive, we may refuse it or charge a reasonable fee, and we will explain why. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl).

Your right to object

Where we rely on our legitimate interests — the entries that say so in section 3 — you have the right to object to that processing at any time, on grounds relating to your particular situation. If you do, we stop, unless we can show compelling legitimate grounds that override your interests or we need the data to establish, exercise or defend legal claims.

For anything in the nature of direct marketing — which includes the product-update notes and the inactivity reminder in section 3 — the right is absolute and needs no reason. Use the unsubscribe link in the message, or the switch in Settings, or simply tell us, and we stop. To object to any other processing, email us at privacy@vinkjournal.com.

10. Cookies and similar storage

We store a small amount of information on your device, all of it our own (first-party) and none of it for advertising or for following you across other sites:

• Signing in — a cookie that keeps you logged in (30 days, or until you sign out).
• Viewing as an accountability peer without an account — a cookie for each dashboard you opened with an emailed code, keeping you signed in to that one view (30 days, or until you choose “Forget this device”).
• Your timezone — set automatically so that “today” means your day for the daily loss limit (1 year).
• Choices you make in the app — theme, which account and view you last used, chart and calendar settings, whether amounts are hidden, and that you dismissed a banner (up to 1 year).
• Which of our links you came through — if you arrived by one of our short links, a cookie names the platform and the post for 30 days, so an account you create in that time can be credited to it (section 2). It carries no identifier of you.
• The demo session — if you use the demo at /try, a cookie remembers which demo record is yours for 30 days, so your second read and your result mail find the same record without asking for the address again.
• Unsaved drafts — if you are part-way through a trade or review, a copy is kept in your browser’s local storage so a refresh does not lose it; it is deleted when you save, and after 7 days at the latest. It never leaves your device.

The demo page at /try also loads Cloudflare’s Turnstile check (section 2), which reads technical information from your browser only to tell a person from a script, as part of the security of the demo you asked to use; it is not used for advertising or to follow you across sites.

Because all of this is strictly necessary for the service you asked for, or only remembers a choice you made, the law does not require your consent and we show no consent banner. To count visits and measure page speed we use Vercel’s web analytics, which stores nothing on your device; to tell visits apart for one day it uses a hash of the request that Vercel discards after 24 hours, and we only see totals. You can clear this storage in your browser at any time; clearing the sign-in cookie signs you out.

11. Children

You must be 18 or older to use Vink. We do not knowingly collect data from anyone under 18; if you believe a minor has created an account, tell us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. We’ll change the “last updated” date above and, for material changes, notify you by email or in the app. If we want to use your data for a new purpose that is not compatible with the ones above, we will tell you before we start, and ask for your consent where the law requires it.

13. Contact

Questions about this policy or your data? Email us at privacy@vinkjournal.com.