Privacy Policy

Last updated: 4 November 2026

This Privacy Policy describes how Novix sp. z o.o. ("Company", "we", "us", or "our") handles information when you use the Novix Trader mobile application ("App"). We respect your privacy and are committed to protecting personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This Privacy Policy applies to all users of the App.

1. Data Controller

The data controller responsible for the processing of personal data is: Novix sp. z o.o. Registered office: Białystok, Poland Country of registration: Poland Website: https://novix.pro Contact email: nowonovix@gmail.com For any questions regarding this Privacy Policy or the processing of personal data, please contact us at the email address above.

2. About the Application

Novix Trader is a portfolio tracking application designed to help users monitor and manage information related to their investment portfolios. The App does not require users to create an account or register to use its core functionality. Depending on the features available, users may enter or manage portfolio information, including financial instruments, investment positions, transactions, and related portfolio data. The App is not a financial institution, broker, or investment advisor. Information displayed in the App is provided for informational purposes only and does not constitute financial, investment, or trading advice.

3. Information We May Process

The information processed by the App depends on the features you use and the permissions you grant.

3.1. Portfolio Information

When you use the portfolio tracking functionality, you may provide information such as:

• Names or symbols of financial instruments.
• Portfolio positions and quantities.
• Purchase prices and transaction dates.
• Portfolio values and allocation information.
• Other portfolio-related information you choose to enter.

This information is used to provide portfolio tracking and calculation functionality.

3.2. Technical Information

When you use the App, certain technical information may be processed to ensure its proper operation, security, and performance. This may include:

• Device model and operating system version.
• App version and language settings.
• Technical logs and diagnostic information.
• Crash reports and performance information.
• Device or app identifiers, where generated or made available by the operating system or integrated services.

The exact technical information processed depends on the device, operating system, and technical configuration of the App.

3.3. Information You Provide Directly

If you contact us by email, we may process:

• Your email address.
• The contents of your message.
• Information you voluntarily include in your communication.

We use this information solely to respond to your inquiry and provide support.

4. How We Use Information

We may process information for the following purposes:

• To provide the portfolio tracking functionality.
• To calculate and display portfolio-related information.
• To maintain and improve the App.
• To identify and resolve technical issues.
• To protect the App against misuse and security threats.
• To respond to support requests.
• To comply with applicable legal obligations.

We do not use portfolio information to provide personalized investment advice. We do not sell personal data to third parties.

5. Legal Basis for Processing

We process personal data only where a valid legal basis exists under the GDPR. Depending on the circumstances, the legal basis may include: Performance of a contract — Article 6(1)(b) GDPR Processing necessary to provide the functionality of the App that you choose to use. Legitimate interests — Article 6(1)(f) GDPR Processing necessary to maintain the App, ensure security, prevent misuse, and improve technical performance, provided that these interests do not override your fundamental rights and freedoms. Legal obligations — Article 6(1)(c) GDPR Processing necessary to comply with applicable legal requirements. Consent — Article 6(1)(a) GDPR Where consent is required for a specific processing activity, we will request it before processing the relevant personal data. You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

6. Storage of Portfolio Information

Novix Trader does not require account registration. Portfolio information may be stored or processed locally on your device or through other technical mechanisms necessary for the functionality you use. The storage method depends on the implementation of the relevant App feature. If information is stored locally on your device, deleting the App or clearing its data may result in the loss of that information. You should maintain your own backup of important portfolio information where appropriate.

7. Sharing of Information

We do not sell, rent, or trade personal data. Personal data may be disclosed only where necessary and permitted by applicable law, including:

• To technical service providers involved in operating or maintaining the App, where applicable.
• To service providers supporting security, diagnostics, or infrastructure, where applicable.
• To competent public authorities where disclosure is required by law.
• Where necessary to establish, exercise, or defend legal claims.

Any service provider processing personal data on our behalf must be subject to appropriate data protection obligations. We do not disclose portfolio information to brokers or financial institutions for the purpose of executing transactions.

8. Third-Party Services

The App may rely on services provided by third parties, including services associated with the operating system or app distribution platform. Such providers may process certain technical information in accordance with their own privacy policies and applicable laws. We encourage users to review the privacy policies of relevant third-party providers. We are not responsible for the independent privacy practices of third-party services that are not controlled by us.

9. International Data Transfers

Personal data may be transferred to or processed in countries outside the European Economic Area (EEA) where necessary for the operation of the App. Where such transfers are subject to the GDPR, we will ensure that an appropriate transfer mechanism is in place. This may include:

• An adequacy decision adopted by the European Commission.
• Standard Contractual Clauses approved by the European Commission.
• Other lawful transfer mechanisms permitted under applicable data protection legislation.

10. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy. Portfolio information stored locally on your device remains there until you delete it, clear the relevant application data, or uninstall the App, subject to the operating system's behavior. Information provided through email communications may be retained for as long as necessary to respond to your inquiry, maintain relevant records, or comply with legal obligations. Technical information is retained only for the period necessary to maintain the security and functionality of the App. When personal data is no longer necessary, it will be deleted or anonymized, unless retention is required by law.

11. Data Security

We take reasonable technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures are designed to provide a level of security appropriate to the nature of the information and the risks associated with its processing. However, no method of electronic transmission or storage can be guaranteed to be completely secure.

12. Your Rights Under the GDPR

If you are located in the European Economic Area, you may have the following rights under the GDPR:

• Right of access: to obtain confirmation of whether your personal data is being processed and access to that data.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of personal data where applicable.
• Right to restriction: to request restriction of processing in certain circumstances.
• Right to data portability: to receive certain personal data in a structured, commonly used, machine-readable format.
• Right to object: to object to processing based on legitimate interests.
• Right to withdraw consent: where processing is based on consent.

To exercise these rights, contact us at: nowonovix@gmail.com We will respond to your request in accordance with applicable data protection legislation. You also have the right to lodge a complaint with a competent supervisory authority. In Poland, the competent supervisory authority is: President of the Personal Data Protection Office (UODO) Website: https://uodo.gov.pl/

13. Children's Privacy

Novix Trader is not intended for children under the age of 16. We do not knowingly collect personal data from children under the age of 16. If we become aware that personal data has been collected from a child in circumstances where such processing is not permitted by applicable law, we will take appropriate steps to delete the information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the App, our data processing practices, or applicable legal requirements. The updated version will be published on our website or made available through the App. The "Last Updated" date at the beginning of this Privacy Policy indicates when the latest changes were made. We encourage users to review this Privacy Policy periodically.

15. Contact Us

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us: Novix sp. z o.o. Białystok, Poland Website: https://novix.pro Email: nowonovix@gmail.com