Privacy Policy

1. Who We Are

Romeox Capital LLC DBA BreakEven Trail is a Florida limited liability company operating at 7950 NW 53rd Street, Suite 337, Miami, FL 33166, United States. We develop and distribute BreakEven Trail™, a trade management tool for the NinjaTrader® 8 platform (accessible from the Indicators menu).

Our payment processor and Merchant of Record is Lemon Squeezy (Lemon Squeezy, Inc.), which processes all purchases on our behalf and manages its own privacy practices in accordance with its Privacy Policy. Stripe is used by Lemon Squeezy as the underlying payment infrastructure.

2. Data We Collect

3. How We Use Your Data

We use the information we collect solely to:

• Process your purchase and activate your NinjaTrader® software license;
• Send you license confirmation and installation instructions;
• Respond to your support requests;
• Comply with legal obligations (tax records, fraud prevention);
• Monitor and improve the security and reliability of our services.

We do not sell, rent, or share your personal information with third parties for marketing purposes.

4. Data Sharing

We share limited personal data only with the following parties and only as necessary:

• Lemon Squeezy — Merchant of Record for all purchases. Processes payment data under their own privacy policy.
• NinjaTrader Group, LLC — We transmit your NinjaTrader account email to the NT Ecosystem API solely to create your product license. This transmission occurs via a secure, encrypted server-to-server connection.
• HostGator / Newfold Digital — Our hosting provider stores website files and server logs on servers located in the United States.
• Google LLC — Google Analytics 4 and Google Tag Manager receive anonymized website usage data (pages visited, session duration, device type). Google may process this data in the United States. See Google's Privacy Policy.
• Meta Platforms, Inc. — Meta Pixel receives anonymized event data (page views, button clicks) to measure advertising effectiveness. See Meta's Privacy Policy.
• TikTok, Inc. — TikTok Pixel receives anonymized event data for advertising attribution. See TikTok's Privacy Policy.

We do not sell your personal data to third parties or share it with data brokers.

5. Cookies

Our website uses the following categories of cookies:

• Essential cookies — Required for the Lemon Squeezy checkout overlay (lemon.js). Cannot be disabled without breaking the purchase flow.
• Analytics cookies — Set by Google Analytics 4 (via GTM) to measure aggregate website usage. These cookies do not identify you personally.
• Advertising cookies — Set by Meta Pixel and TikTok Pixel to measure ad campaign effectiveness. These cookies may track your visit across websites.

You may disable non-essential cookies in your browser settings or via your browser's consent controls. Disabling advertising cookies will not affect your ability to purchase or use our software. Disabling essential cookies may affect the checkout experience.

EU/EEA residents: we rely on legitimate interest as the legal basis for all non-essential cookies in accordance with the ePrivacy Directive. You may opt out of tracking at any time via your browser privacy settings or Google's opt-out tools at tools.google.com/dlpage/gaoptout.

6. Data Retention

We retain order and license records for seven (7) years to comply with US tax law. Support email communications are retained for two (2) years. Server logs are retained for ninety (90) days. Your NinjaTrader account email is retained only as part of the license activation log for as long as the license remains active.

7. Your Rights

Depending on your location, you may have rights regarding your personal data, including:

• Access — Request a copy of the personal data we hold about you;
• Correction — Request correction of inaccurate data;
• Deletion — Request deletion of your data, subject to our legal retention obligations;
• Restriction — Request that we restrict processing of your data;
• Portability — Request your data in a portable format.

EU/EEA residents (GDPR): You have the right to lodge a complaint with your local supervisory authority.

California residents (CCPA): You have the right to know what personal information is collected, to request deletion, and to opt out of the sale of personal information. We do not sell personal information.

To exercise any of these rights, contact us at support@breakeventrail.com. We respond within 30 days.

8. Security

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, disclosure, or destruction. All data transmissions between our webhook server and the NinjaTrader API are encrypted via TLS. Webhook payloads from Lemon Squeezy are authenticated via HMAC-SHA256 signature validation before processing.

No method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to using industry-standard practices.

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the effective date at the top of this page. Continued use of our website or software after such changes constitutes your acceptance of the updated policy. The current version is always available at breakeventrail.com/legal/privacy.

10. Contact