FX Risk Engine mobile app — Privacy Policy
The FX Risk Engine app is a risk-monitoring tool for brokerages. It is offered by Count Technologies Envanter Sayım ve Bilişim Hizmetleri Ltd. Şti. ("Count Technologies", "we"). This policy explains what personal data the app processes, why, who receives it and what you can ask us.
1. Who we are
Count Technologies Envanter Sayım ve Bilişim Hizmetleri Ltd. Şti., Şahkulu Mah. Galipdede Cd. No:18/B, 34421 Beyoğlu, İstanbul, Türkiye. Contact: info@counttechs.com.
2. Who the app is for
The app is only for the staff of brokerages that hold an FX Risk Engine licence. There is no public sign-up: your employer creates your account and decides your role. The app is not meant for children or for the brokerage's own trading clients.
3. Two kinds of data, two roles
- Your own data as an app user (account, sign-in, device and notification data). We process it to run and secure the service. Count Technologies is the controller of this data.
- Data about your employer's trading clients shown in the app: trading account numbers, balances, equity, positions, trades, deposits and withdrawals, alerts, and client names and masked e-mail addresses where your employer's systems provide them. Your employer is the controller of this data. We process it only on your employer's instructions, under our agreement with them. Requests about this data go to your employer.
4. Data we process about you
| Category | What | Why |
|---|---|---|
| Account | Username, display name, role, e-mail address if your employer adds it; your password only as a one-way hash | To let you sign in and show what your role allows |
| Sign-in and security | Session cookies and tokens, IP address of each request, sign-in times, failed sign-in attempts | To keep accounts secure and investigate misuse |
| Device and notifications | Device type, operating system version, app version, the push token Apple or Google assigns to the app, your notification settings | To send the alerts you or your employer turn on |
| Settings | Your page layout, filters, light or dark theme | To show the app the way you set it |
| Logs | Server request and error logs | To keep the service running and fix faults |
We do not collect your location, contacts, photos, microphone or camera data, or advertising identifiers. We do not track you across other apps or websites, show ads or sell personal data. The app contains no analytics or crash-reporting tools.
5. Legal bases
We process your data to perform the service agreement with your employer and to give you access to it; for our legitimate interest in keeping the service secure and working; and where the law requires us to.
6. Who receives the data
- Hosting: OVHcloud, servers in Germany (EU).
- Push notifications: Apple Push Notification service (Apple Inc.) and Firebase Cloud Messaging (Google LLC) deliver alerts to your device. They receive the push token and the alert text.
- Telegram: if your employer's administrator turns on Telegram alerts, the service sends alert messages to the Telegram groups that administrator chooses. Telegram's own privacy policy applies there.
- Authorities: when the law requires it.
We do not share personal data with anyone else.
7. International transfers
Our servers are in Germany. Apple and Google may process push data in other countries, including the United States. For users in Türkiye these are transfers abroad under Article 9 of Law No. 6698 (KVKK); each provider's data processing terms with standard contractual clauses cover these transfers.
8. How long we keep it
- Account data: while your account is active and 12 months after it is closed.
- Security and server logs: 90 days.
- Push tokens: until you sign out, remove the app or the token stops working.
- Client data: as your employer's agreement with us sets.
9. Security
All traffic is encrypted in transit (TLS). Passwords are stored only as one-way hashes. Access is limited by role, and the servers sit in a professional data centre. Sign-in has a second step: a one-time code on your phone.
10. Your rights
You may ask to see, correct or delete your personal data, ask how it is used, object to processing, or ask us to limit it. Users in Türkiye have the rights in Article 11 of KVKK (see the KVKK notice); users in the EU have the rights in the GDPR. Write to info@counttechs.com; we answer within 30 days. For data about your employer's clients, contact your employer. You may also complain to your data protection authority (in Türkiye: the Personal Data Protection Authority, kvkk.gov.tr).
11. Changes
We will post any change here with a new effective date, and tell you in the app before a significant change takes effect.
12. Contact
Count Technologies Envanter Sayım ve Bilişim Hizmetleri Ltd. Şti., Şahkulu Mah. Galipdede Cd. No:18/B, 34421 Beyoğlu, İstanbul, Türkiye · info@counttechs.com