Privacy Policy
This policy explains what personal information Chalice Logica LLC (the Licensor) collects through the NERV website, the customer portal, the licence service and the NERV desktop application (NERV), why, who receives it, and what choices people have. The Licensor is the controller of the information described here, except where this policy says another company decides how it is used.
1. The short version
- NERV is local-first. The user's data, strategies, broker logins and vendor keys stay on the user's computer.
- The website holds accounts, licences, seats, releases and the waitlist. That is all.
- NERV's licence check sends a licence key, a salted machine hash and the app version. It sends nothing about trading: no orders, positions, accounts, charts, strategies, files or market data.
- The Licensor does not sell personal information and does not use it for advertising.
2. What the Licensor collects
| Information | Where it comes from | What it is used for |
|---|---|---|
| Name and email address | The purchase, passed on by Freemius, which creates the account | Creating and running the account; sending sign-in links and account notices; support |
| Licence record: plan, status, expiry, whether lifetime, and a one-way hash (SHA-256) of the licence key | Freemius and the licence service | Showing the licence in the portal; deciding whether the licence is valid |
| Seat record for each machine: a salted hash of a machine identifier, a machine name, the app version, the time of the last check, when a seat was freed, and seat moves | NERV, when it activates and checks in; Freemius; actions on the account page | Enforcing the 2-machine limit and the seat-move limit; letting the user free a seat; showing seats in the portal |
| Sign-in session: a session token, expiry time, the IP address and browser details at sign-in | The user's browser | Keeping the user signed in; security |
| Sign-in link: a short-lived token tied to the email address (valid for 5 minutes) | The sign-in form | Signing in without a password |
| Technical request data, such as IP address, time, address requested and result | The user's browser or NERV, when it contacts the website | Running and securing the service, limiting abuse and repeated requests, finding faults |
| Webhook records: the event type, an event id and times | Freemius | Keeping licences and seats in step with the sale; avoiding duplicate processing |
| Waitlist: the email address and the time it was submitted | The person, through the waitlist form on the website | Emailing the person about NERV's launch |
| Optional waitlist profile: answers to up to six multiple-choice questions (who the person is, years trading systematically, current stage, markets traded, current tools, operating system) and the website address of a hosted strategy platform the person uses, if they choose to give it (stored as the domain name only, with no page path or query). No name, phone number, employer or account size is asked for | The person, if they choose to answer the optional questions shown after joining | Understanding who is interested in NERV and planning the product. Not used to decide anything about the person |
| Messages the user sends to the Licensor (for example support emails) and the information in them | The user | Answering and keeping a record of the request |
The Licensor stores a hash of the licence key, not the key itself. The app computes the machine hash on the user's computer. The website receives and stores only that hash and the machine name the app sends.
[CONFIRM WITH APP TEAM — the exact fields the app sends on activation and check-in (licence key, machine hash, machine name, app version), how often it checks in, and whether any update or download request carries more]
What the Licensor does not collect
The Licensor does not receive the user's trading data, orders, positions, account balances, strategies, charts, saved files, broker logins, vendor keys or market data. NERV connects to the user's brokers and data vendors from the user's computer, and those connections are between the user and the vendor. Apart from the licence check and update or download requests, NERV is built not to send data to the Licensor. [CONFIRM — results of the clean-machine network test on the release build]
3. Cookies
The website uses a cookie to keep a signed-in user signed in. It does not use advertising cookies or analytics cookies. [CONFIRM AT PUBLICATION — that no analytics, advertising or other tracking tool has been added since this draft]
4. Why the Licensor uses the information, and the legal basis
For people in the European Economic Area or the United Kingdom, the legal bases are:
| Purpose | Legal basis |
|---|---|
| Running the account, licence and seats; sending sign-in links; providing downloads; support | Contract (GDPR Art. 6(1)(b)) |
| Emailing a person on the waitlist about NERV's launch | Consent (GDPR Art. 6(1)(a)), given by submitting the waitlist form. The person can withdraw it at any time by emailing the privacy contact in section 13. |
| Keeping the optional waitlist profile to understand interest and plan the product | Consent (GDPR Art. 6(1)(a)), given by choosing to answer the optional questions. The questions can be skipped, and skipping changes nothing. The person can withdraw consent at any time by emailing the privacy contact in section 13, and the answers are then deleted. |
| Security, preventing abuse and repeated requests, finding faults, keeping records to deal with disputes | Legitimate interests (Art. 6(1)(f)): running a secure service. People can object (section 8). |
| Keeping records the law requires of the Licensor itself, for example its accounting and tax records | Legal obligation (Art. 6(1)(c)). Freemius, as merchant of record, keeps the payment, tax and invoicing records for sales. The Licensor keeps only its own accounting and tax records, such as the payout statements Freemius sends it. |
Apart from emails about NERV's launch to people on the waitlist and the optional waitlist profile, the Licensor does not send marketing emails, and it does not rely on consent for any of the other purposes above. If that changes, this policy is updated first.
Providing the name and email address and the licence and seat information is needed to hold an account and use a licence. Without them, the Licensor cannot provide the licence service.
The Licensor does not make decisions about people by automated means that have legal or similarly significant effects. The licence service does apply fixed rules automatically: it accepts or refuses an activation or check-in depending on the licence status and the seat and move limits.
5. Who receives the information
The Licensor shares information only with the companies below, to run the service, and with authorities where the law requires it.
- Freemius sells NERV as merchant of record. It handles payment, tax and invoicing and shares the purchaser's name, email and licence details with the Licensor. Freemius's own privacy policy applies to what it collects (see freemius.com/privacy). For the account and licence information that Freemius passes to the Licensor, the Licensor is the controller and Freemius is the processor under Freemius's data processing agreement (see freemius.com/terms/dpa). For payment, tax and invoicing, Freemius acts as merchant of record under its own privacy policy. [OWNER ACTION — confirm the Freemius data processing agreement is accepted for the NERV product in the Freemius dashboard]
- Cloudflare hosts the website and licence service, the account database, and the stored installer files, and delivers pages over its network. Cloudflare acts as the Licensor's processor under its customer data processing addendum (see cloudflare.com/cloudflare-customer-dpa). Pages are served from Cloudflare locations near the visitor. The database and file storage are in the location Cloudflare assigns to them. [OWNER ACTION — confirm in the Cloudflare account that the data processing addendum is accepted, and note the database and storage locations (the project does not pin one)]
- Resend sends the Licensor's email, such as sign-in links. It receives the recipient's email address and the message. Resend acts as the Licensor's processor under its data processing addendum (see resend.com/legal/dpa), which states that its primary processing takes place in the United States. Resend is an independent controller of its own account and usage records. See also resend.com/legal/privacy-policy.
The Licensor does not sell personal information and does not share it with third parties for cross-context behavioural advertising. The Licensor uses no advertising or analytics vendor. Any addition updates this policy first.
6. Transfers outside the user's country
The Licensor is based in the United States, and its providers process information in the United States and in other countries where they operate. Where information about people in the European Economic Area or the United Kingdom is transferred to a country without an adequacy decision, the Licensor relies on the standard contractual clauses in its data processing agreements with Freemius, Cloudflare and Resend (European Commission Implementing Decision 2021/914, with the UK Addendum for the UK). Cloudflare and Resend also state that they comply with the EU-US Data Privacy Framework. The Licensor does not itself hold a Data Privacy Framework certification.
7. How long the Licensor keeps information
- Sign-in links expire after 5 minutes. Sessions end at their expiry time or when the user signs out.
- Account, licence and seat records are kept while the account is active, and after a licence ends for 13 months, for accounting, security and dispute purposes. They are then deleted or anonymised.
- Technical request logs are kept for the period Cloudflare's own log setting allows (3 to 7 days at the time of writing). Webhook records are kept for 13 months with the account records.
- Waitlist records (email address and join time) are kept until the launch emails are sent, and for at most 24 months after the person joined. They are then deleted. A person who withdraws consent is removed on request.
- The optional waitlist profile is kept with the waitlist entry and deleted with the waitlist entry, on the same schedule. Removing a person from the waitlist removes their answers. The answers are not sold, not shared with anyone for their own purposes, and not used for advertising. They are stored with the Licensor's hosting provider (Cloudflare) like the rest of the waitlist.
- Support messages are kept for 12 months after the request is closed.
The user's trading data, strategies, files and logins are not held by the Licensor, so the Licensor has nothing of that kind to keep or delete. They remain on the user's computer.
8. Rights
People in the European Economic Area or the United Kingdom
These people have the right to access their information, to have it corrected, to have it erased in some cases, to restrict its use in some cases, to receive information they provided in a portable format, and to object to processing based on legitimate interests. Where processing relies on consent, they can withdraw it at any time.
The Licensor responds without undue delay and in any event within one month of receiving a request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. The Licensor tells the person of any extension within the first month, with the reasons. These periods come from Article 12(3) of the GDPR.
People also have the right to lodge a complaint with a supervisory authority, in particular in the Member State where they usually live, work, or where the alleged infringement took place (GDPR Art. 77). People in the United Kingdom can also complain to the Information Commissioner's Office (ico.org.uk). The Licensor does not currently offer NERV to people in the EEA or the United Kingdom. Before it does, it appoints an EU representative and a UK representative (GDPR and UK GDPR Art. 27) and names them in this policy.
People in California
The California Consumer Privacy Act applies to a for-profit business that does business in California and meets one of three tests: annual gross revenue above $26,625,000 (the amount the California Privacy Protection Agency set from 1 January 2025), buying, selling or sharing the personal information of 100,000 or more California residents or households, or earning 50% or more of annual revenue from selling or sharing personal information. The Licensor does not currently meet any of them and does not sell or share personal information. [OWNER — confirm these facts at publication, and re-check the revenue figure each January of an odd-numbered year when the Agency adjusts it]
The Licensor gives the following to anyone who asks, in California or elsewhere, whether or not the law requires it: to know what information the Licensor collects, uses and discloses; to ask for deletion; to ask for correction; and not to be treated worse for asking. The Licensor confirms receipt within 10 business days and responds within 45 calendar days, and may extend that once by a further 45 days with notice to the person. It verifies the request by email to the address on the account, and may ask for written proof of permission when someone asks on another person's behalf.
People elsewhere
Other US state laws (for example Virginia's, which applies to businesses that process the personal data of at least 100,000 consumers in a year, or 25,000 consumers and more than half their revenue from selling it), Brazil's LGPD (which applies to processing that offers goods or services to people in Brazil) and Canada's PIPEDA (which applies where an organisation has a real and substantial connection to Canada) may or may not reach the Licensor. The Licensor therefore treats a request from any person in the same way, wherever the person lives, within the time limits above and in the EEA and UK section, unless a law that applies to the Licensor requires something different.
How to make a request
Email [privacy@ (NERV domain)] from the email address on the account. The Licensor may ask for further information to confirm who is asking. Requests are free of charge unless they are manifestly unfounded or excessive.
9. Security
The Licensor uses reasonable technical and organisational measures. Pages and licence requests travel over encrypted connections. Licence keys are stored only as a one-way hash. Licence files are digitally signed so that NERV can check them on the user's computer. Access to the back office is limited to the Licensor's staff. No system is perfectly secure, and the Licensor cannot promise absolute security. If a breach of security affects personal information, the Licensor notifies the people affected and the authorities where the law requires it, without undue delay. Under the GDPR the Licensor notifies the supervisory authority within 72 hours of becoming aware of a breach, where feasible, unless the breach is unlikely to result in a risk to people (Art. 33(1)).
10. Children
NERV and this website are for people aged 18 or over. The Licensor does not knowingly collect information from anyone under 18, and in particular from children under 13. If the Licensor learns that it has done so, it deletes the information.
11. Links to other sites and vendors
Brokers, data vendors and other services that the user connects to from NERV have their own privacy practices. This policy does not cover them.
12. Changes to this policy
The Licensor will post any change to this policy on this page, with a new date, and will give notice by email for a material change. See also the End-User Licence Agreement and the Third-Party Licenses.
13. Contact
Chalice Logica LLC, a California limited liability company. Email: [privacy@ (NERV domain)]. A postal address for privacy requests is available on request.