Privacy Notice
Last updated: 15 November 20026
1. Who is responsible
Dmitriy Novikov, trading as Consigliere, 95 Sterling Road, Samrand Business Park, Centurion, South Africa, 0187, South Africa, is the controller (under the GDPR) and responsible party (under South Africa's Protection of Personal Information Act, POPIA) for the personal data described here.
Privacy contact: support@consigliere.biz (subject "Privacy").
2. The short version
Honest Polygon is built so that your work stays with you:
- you can use the course and the free app without an account;
- your journal, paper sessions and course progress are stored on your device, and, if you turn on sync, in your own Google Drive, Dropbox or OneDrive. We do not run a database of users' work;
- we keep only what is needed to sell and activate licences and to answer you.
3. What we collect and why
| Data | When | Purpose | Legal basis |
|---|---|---|---|
| Name, email, country, order ID, amount, tax details | You buy a licence or renewal | Deliver and manage your licence, provide support, keep tax records | Performance of contract; legal obligation |
| Licence ID, random device IDs, activation dates | You activate a licence | Enforce the 3-device limit, let you move the licence between devices | Performance of contract |
| Email address | You subscribe to our newsletter | Send product news; you can unsubscribe in every email | Consent |
| Your messages and email address | You contact support | Answer you | Legitimate interest; performance of contract |
| Encrypted access token to your cloud storage | You use the remote AI-assistant connector | Read and write your journal in your cloud on your instruction | Performance of contract |
| Aggregate site statistics (pages viewed, country, browser), no cookies, no personal profiles | You visit consigliere.biz | Understand which pages are useful | Legitimate interest |
| IP address and request details in server logs, kept briefly | Any request to our servers | Security and abuse prevention | Legitimate interest |
Payment card details are collected by Paddle, not by us. Crypto payments are processed by NOWPayments; we receive the payment status, amount and your email.
4. What we do not collect
- We do not receive your journal, trades, paper sessions or course progress, except when you use the remote AI-assistant connector. Then our server processes them only to carry out the request and writes the result back to your cloud storage; it does not keep a copy.
- We never receive your passwords for cloud services, exchanges or AI assistants.
- We do not sell personal data or use it for advertising.
5. Services you connect yourself
- Cloud storage (Google, Dropbox, Microsoft): the app accesses only its own folder in your account, under the provider's privacy terms.
- AI assistants (such as Claude, ChatGPT or GitHub Copilot): when you connect Honest Polygon, your assistant receives the results of the tools it calls, which may include parts of your journal and paper sessions. Those results are handled under your assistant provider's privacy terms.
- Exchanges: market data is downloaded directly by your device from exchanges' public interfaces; the exchange can see your IP address.
6. Who receives personal data
- Paddle.com (Merchant of Record for card purchases);
- NOWPayments (crypto payments);
- Cloudflare (website, licence server, remote connector, statistics);
- Google Workspace (our email);
- professional advisers (such as our tax practitioner) and authorities, where required by law.
Some of these providers process data outside South Africa and outside your country, including in the United States and the European Union. We use providers that offer appropriate safeguards, such as Standard Contractual Clauses.
7. How long we keep data
- Purchase and licence records: for the life of your licence, and at least 5 years after the last transaction, as required by South African tax law.
- Remote-connector access token: until you disconnect the connector or your update period ends.
- Support emails: 3 years.
- Newsletter address: until you unsubscribe.
- Server logs: up to 30 days.
8. Your rights
Depending on where you live, you have the right to: access your data, correct it, delete it, restrict or object to its processing, receive it in a portable format, and withdraw consent at any time. Write to support@consigliere.biz; we reply within one month.
You can complain to your local data protection authority or to the Information Regulator of South Africa (https://inforegulator.org.za).
9. Security
We use encrypted connections (HTTPS) everywhere, sign licences cryptographically, encrypt stored access tokens, and limit the data we keep to what is listed here.
10. Cookies and local storage
The website and app use no tracking or advertising cookies. The app stores your data and settings in your browser's local storage on your device so that it works offline; this data does not leave your device unless you turn on sync or use the remote connector.
11. Children
The Service is not intended for anyone under 18.
12. Changes
We will publish any changes on this page with a new date and notify licence holders of material changes by email.