Legal

Privacy Notice

Last updated: April 2026. This Privacy Policy explains how Waving Knowledge, Limited (“Waving Knowledge”, “we”, “us”) handles personal data when you use London5. London5 is a local-first desktop application: most of your data lives on your own device and never reaches our servers.

1. WHO WE ARE

Waving Knowledge, Limited is a company registered in Portugal, with offices at LACS Cascais, Estr. Malveira da Serra 920, 2750-834 Cascais, Portugal, and acts as the data controller for the personal data described below. You can contact us at privacy@wavingknowledge.com. We have not appointed a Data Protection Officer; if that changes, this section will be updated.

2. WHAT DATA WE PROCESS

London5 processes the following categories of personal data, most of which is stored only on your device:

  • Enrollment data: market preferences, data-source choice, broker-API or news-feed credentials you provide, network configuration, and the machine specifications (CPU, RAM, GPU) detected during setup.
  • Acceptance record: an email address you provide at enrollment to identify the person who accepted these terms, along with a content hash and timestamp of the disclaimer and privacy policy you accepted. Stored locally in the engine database for legal-audit purposes, and also transmitted to london5.com so that we can send you a confirmation message and record whether you have confirmed it (see §4 and §5).
  • Email confirmation tokens: a unique, time-limited token associated with the email you provided, generated and stored by london5.com to validate the confirmation link sent to your inbox.
  • Network-shared content (Londron): if you opt in to share content with londron.com, the data you have selected to share — opportunities you identify, research outputs, completed trades and “negotiations”, notes, and any associated context such as symbol, timestamp, and your visibility choice — is transmitted to and stored by londron.com and may be made available to other users of that network.
  • Trading and analytical data: positions, orders, fills, and performance metrics of any account you connect; AI-generated signals, scores, and research outputs based on your activity.
  • Conversational data: chat messages you exchange with the AI assistant, including prompts and responses.
  • Settings and preferences: appearance, locale, layout, feed subscriptions, routing rules, and any other configuration you save.
  • Diagnostic data: application logs and crash reports stored locally; we do not collect them automatically.
  • Account/billing data (only if and when paid tiers exist): name, email, billing address, payment-method tokens handled by our payment processor.

We do not intentionally process special categories of personal data (health, ethnicity, political opinions, etc.). If you input such information into the chat or research tools, you do so on your own initiative and at your own risk.

3. HOW AND WHY WE USE IT — LEGAL BASES

PurposeLegal basis (GDPR)
Provide London5’s core functionality (run the engine on your device, store your settings, generate signals)Performance of contract — Art. 6(1)(b)
Send and verify the email-confirmation message that gives legal effect to your acceptance of these termsPerformance of contract — Art. 6(1)(b)
Transmit content you have explicitly opted in to share to londron.com and make it visible to other users according to your settingsConsent — Art. 6(1)(a) — withdrawable at any time
Connect to third-party data, broker, or AI providers you have configuredPerformance of contract — Art. 6(1)(b)
Diagnose crashes and bugs from logs you choose to shareConsent — Art. 6(1)(a)
Detect, prevent, and respond to security incidents and abuseLegitimate interests — Art. 6(1)(f)
Comply with legal obligations (tax, accounting, regulatory requests)Legal obligation — Art. 6(1)(c)
Process payments (if applicable)Performance of contract — Art. 6(1)(b)
Send service announcements, security notices, or material updates to these termsLegitimate interests — Art. 6(1)(f)
Marketing communications (if any)Consent — Art. 6(1)(a) — withdrawable at any time

4. WHERE YOUR DATA IS STORED

London5 is local-first. The vast majority of your data — enrollment, positions, trades, chat history, settings, logs — is stored on your own device, in files under your user library directory. Waving Knowledge does not receive, mirror, or back up that data unless you explicitly send it to us (for example, by attaching a log file to a support request).

Two specific flows do leave your device and reach Waving Knowledge services:

  • Email confirmation (london5.com) — the email address you provide at enrollment, along with the resulting confirmation status, timestamp, and verification token, is transmitted to and stored by london5.com so we can send you a confirmation message and prove that the person who accepted these terms controls that mailbox.
  • Network sharing (londron.com) — only if you opt in: the specific items you choose to share (opportunities, research, completed negotiations, notes, etc.) are transmitted to and stored by londron.com and exposed to other londron.com users in line with the visibility settings you select. Opting out, or unsharing individual items, removes the items from new visibility, but copies that other users have already viewed or saved cannot be retracted.

When you use a feature that requires a network call to a non-Waving Knowledge provider (broker API, data feed, AI provider), the relevant subset of your data is transmitted directly from your device to the third party you chose. It does not pass through Waving Knowledge servers.

5. WHO WE SHARE DATA WITH

Waving Knowledge does not sell your personal data. Categories of recipients:

  • Waving Knowledge services — london5.com (sends your email confirmation, stores confirmation status) and londron.com (peer network for content you opt in to share), each operated by Waving Knowledge, Limited or its affiliates.
  • Other londron.com users — limited to content you have explicitly opted in to share, in accordance with the visibility settings you select for each item.
  • Third-party data, broker, exchange, custodian, payment, and AI providers that you enable through plugins or integrations. These act as independent controllers under their own terms and privacy policies. Examples: Finnhub, Polygon, Tiingo, Alpaca, OpenAI, Anthropic, Stripe (only as applicable).
  • Hosting and infrastructure providers for any optional hosted services we offer (e.g., update server, future cloud-sync features). These act as our processors under written agreements.
  • Professional advisers (accountants, lawyers, auditors) bound by confidentiality, where strictly necessary.
  • Authorities when required to do so by valid legal process, or to protect our rights, safety, or property.

6. INTERNATIONAL TRANSFERS

Some third-party providers you connect to (notably AI providers and several news/data feeds) are located outside the European Economic Area, including in the United States. When data is transferred outside the EEA, we rely on the following safeguards as applicable: European Commission adequacy decisions, Standard Contractual Clauses (SCCs), or the recipient’s certification under an approved transfer framework. You can request a copy of the safeguards for any specific transfer.

7. HOW LONG WE KEEP DATA

Because most data lives on your device, you control retention for that portion. You can delete it at any time by removing the relevant files, by clearing individual records inside London5, or by using Settings → Reset Setup Wizard, which clears your enrollment and locally stored configuration.

For data on Waving Knowledge services:

  • Email confirmation records (london5.com): your email address and confirmation status are retained while your acceptance of the terms remains in force. Unconfirmed verification tokens expire after a short period and are then deleted. You may request deletion of your confirmation record at any time (see §8); doing so will invalidate your acceptance and may require you to re-enroll.
  • Network-shared content (londron.com): retained for as long as you keep the item shared. You can unshare items individually at any time. Once you delete your londron.com presence, content you authored is removed from public visibility, though prior cached copies, references, or screenshots held by other users are outside our control.

For other data we do receive (e.g., support correspondence, billing records), we retain it only as long as necessary for the purpose it was collected and for any statutory retention period (typically up to ten years for accounting and tax records under Portuguese law).

8. YOUR RIGHTS UNDER GDPR

You have the following rights with respect to personal data we hold about you:

  • Access — obtain a copy of your data (Art. 15).
  • Rectification — correct inaccurate or incomplete data (Art. 16).
  • Erasure (“right to be forgotten”) — request deletion (Art. 17).
  • Restriction of processing — limit how we use your data (Art. 18).
  • Portability — receive your data in a structured, machine-readable format (Art. 20).
  • Objection — object to processing based on legitimate interests or for direct marketing (Art. 21).
  • Withdraw consent at any time, where processing is based on consent (Art. 7(3)).
  • Lodge a complaint with the Portuguese supervisory authority — Comissão Nacional de Proteção de Dados (CNPD) — or with the supervisory authority of your country of residence.

To exercise any of these rights, write to privacy@wavingknowledge.com. We will respond within one month, as required by GDPR.

9. AUTOMATED DECISION-MAKING AND PROFILING

London5 uses third-party artificial intelligence services that you configure, together with rule-based local logic, to generate trading signals, scores, opportunity ranks, news triage, and research summaries based on your data. London5 does not host, train, or operate any AI model of its own — all AI processing is performed by external providers (cloud APIs you connect, or local runtimes you install). These outputs constitute profiling within the meaning of Art. 4(4) GDPR. They are intended as informational tools only; no trade is placed automatically without your prior configuration and consent. Decisions with legal or similarly significant effects on you are not made solely by automated means.

The third-party AI provider you select acts as an independent data controller for any data routed to it. You should review that provider’s own privacy policy and terms of service, and choose providers and deployment options (cloud vs. local) consistent with your privacy preferences and applicable law.

If you enable a feature that automates order placement (e.g., direct broker integration with auto-execute), you must explicitly configure and authorise it; the automation runs locally on your device, under parameters you control.

10. SECURITY

We design London5 to keep your data on your device. Locally, your data is protected by your operating system’s user account controls; we recommend you keep your device, OS, and London5 up to date and use full-disk encryption (FileVault on macOS) and a strong account password. For credentials and API keys you enter, we use the platform keychain where available.

For data transmitted to Waving Knowledge services: connections to london5.com and londron.com use TLS in transit. Email-confirmation links use unique, time-limited tokens. Network-shared content on londron.com is access-controlled by your chosen visibility settings.

No system is perfectly secure. If we become aware of a personal-data breach affecting data we hold, we will notify the CNPD within 72 hours and notify you without undue delay where required by law.

11. CHILDREN

London5 is not intended for, and may not be used by, persons under the age of 18. We do not knowingly process data of minors. If you believe a minor has provided us data, please contact privacy@wavingknowledge.com so we can delete it.

12. COOKIES AND LOCAL STORAGE

The London5 desktop application uses local storage on your device (SQLite databases, files, and localStorage in the embedded web view) to persist your settings and state. It does not use third-party tracking cookies or advertising identifiers.

If we operate a public website (london5.com or similar), separate cookie-policy disclosures will apply on that website.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The “Last updated” date at the top reflects the most recent revision. For material changes we will notify you in-app or by email (where you have provided one) before the change takes effect. Continued use of London5 after a change is published constitutes acceptance of the updated policy.

14. HOW TO CONTACT US

For any privacy-related questions, requests, or complaints: