Legal

Privacy policy

Last updated

This site is a static set of pages. It sets no cookies and runs no analytics unless you allow the visit counter described below. Apart from that and the contact form, nothing here talks to a server.

What is collected

Nothing by the pages themselves. The web server that hosts it keeps standard access logs (IP address, requested page, browser identification, time) for security and error diagnosis, as every web server does. Those logs are not used for profiling and are not shared.

When you contact me

If you email info@kestutisbalciunas.com or message me on Telegram, I keep the correspondence for as long as it is needed to answer you and to deliver any work we agree on, and for the period accounting rules require for invoices. It is not added to the newsletter list: that list is separate and only ever gets addresses that asked for it through the signup form. You can ask me to delete your correspondence at any time.

Analytics, only with your consent

On your first visit a small notice asks whether I may count the visit with Google Analytics 4. Nothing is loaded and no cookie is set until you click Allow; if you click No thanks, only that choice is stored in your browser and the question is not asked again. With your consent, Google Analytics (Google Ireland Limited) records the pages you view, your approximate location and the type of device, using cookies named _ga and _ga_ followed by an identifier, kept for up to two years; IP addresses are shortened before storage and no advertising features are enabled. The legal basis is your consent (GDPR Article 6(1)(a)), which you can withdraw at any time: change your analytics choice, or delete the cookies in your browser.

The contact form

When you send the spec-request form, your name, email address, optional Telegram handle, the options you pick, your message and any files you attach go to a small program I run on Cloudflare Workers at the address contact.kestutisbalciunas.com. It checks the submission with Cloudflare Turnstile, a bot check that shows no puzzles and does not track you across sites, keeps a copy in Cloudflare KV storage for up to twelve months so that nothing is lost if an email fails, and delivers it to info@kestutisbalciunas.com through Resend, an email delivery service. If the email address is valid you receive one confirmation with a reference number. Sending this form never subscribes you to anything; the newsletter has its own form and its own tick box.

The program also records your IP address and country with each submission, and counts submissions per IP address for one hour, to stop abuse of the form. The legal basis is the steps taken at your request before a contract (GDPR Article 6(1)(b)) and my legitimate interest in keeping a record of enquiries and keeping the form usable. Cloudflare and Resend act as processors under their own data processing terms. Write to info@kestutisbalciunas.com if you want a submission deleted before the twelve months are up.

The newsletter and the free indicator pack

If you ask for the free toolkit guide, the notice printed immediately above the send button states that sending the form also signs you up for occasional emails about the tools I build, and the exact wording you were shown is stored with your address. The same Cloudflare Worker checks the submission with Turnstile and then adds your email address, and your first name if you gave one, to my list at GetResponse, which sends the emails and acts as a processor under its own data processing terms. The legal basis is your consent (GDPR Article 6(1)(a)).

So that the consent can be shown later if it is ever questioned, the Worker stores the exact wording you agreed to, the version of that wording, the time, your IP address and the page you signed up from, for three years, in Cloudflare KV. The same four facts are stored beside your address in GetResponse. Every email carries a one-click unsubscribe link and my postal address; unsubscribing removes you from the list, and the signup form cannot add you back without a new tick. Write to info@kestutisbalciunas.com if you would rather I deleted the record as well.

When you buy a TradingView or NinjaTrader indicator

Payment is taken by Stripe or by PayPal on their own pages, under their own privacy policies. They send me your name, your email address, the amount and the product, so that I can match a payment to an access request and keep the accounting records the law requires. I never receive your card number.

After payment you send me your email address and, for a TradingView indicator, your TradingView username, or, for a NinjaTrader indicator, the email address you log in to NinjaTrader with, through a Google Form. Google processes that form on my behalf. I use that detail for one thing: adding it to the access list of the TradingView script, or creating the licence record in NinjaTrader's Vendor Dashboard, where NinjaTrader Group, LLC processes it under its own privacy policy to verify the licence inside the platform. I keep a record of which username or account holds which licence for as long as the licence runs, so that I can restore or move your access if you ask.

Buying an indicator does not add you to the newsletter.

Third parties you may choose to visit

Links on this site lead to MQL5.com, Upwork, LinkedIn, X and Telegram. Each of those services has its own privacy policy, which applies once you are there. Purchases of my Market products are handled entirely by MQL5.com; I never see your payment details.

Your rights

Under the GDPR you can ask what personal data I hold about you, ask for it to be corrected or deleted, and complain to the Lithuanian State Data Protection Inspectorate. Write to info@kestutisbalciunas.com.