1. Who is responsible for your data
[Company legal name], [Registered address] is the controller of the personal data described here. For questions or to exercise any right below, message the Telegram bot — that is the channel we monitor. [Placeholder: data protection contact email, and whether an EU representative under GDPR Art. 27 is appointed.]
2. What we hold, and why
- Your name — to address you in messages. Basis: performing our contract with you.
- Your email address — it is your web sign-in identifier. Basis: contract.
- Your phone number — how you first registered and how we identify you across Telegram and the portal. Basis: contract.
- Your Telegram ID — the address signals are delivered to, and the anchor that proves an account is yours when you sign in or reset a password. Basis: contract.
- Your declared investment budget and risk profile — the numbers we size your signals from. You type them; we do not verify them. Basis: contract.
- Your positions and trade confirmations — what you told us you bought or sold, at what price, so the portal can show your P&L and produce your CSV export. Basis: contract.
- Sign-in and delivery logs — timestamps, IP address, and whether a message was delivered. Basis: our legitimate interest in keeping accounts secure and diagnosing failures.
We do not hold your broker credentials, your account numbers, or your money. We place no trades: every order is entered by you, at your own broker, so we have no connection to it and nothing to store about it. We do not ask for identity documents. We do not knowingly collect data from anyone under 18.
3. Where your data goes
- Telegram — every signal and code we send you passes through Telegram, so Telegram processes your Telegram ID and the message content under its own privacy policy.
- Our hosting provider — [Placeholder: provider and region] runs the servers and the database.
- Market data providers — receive symbols only, never anything about you.
- Our AI assistant provider — if you send the bot a free-text question instead of a command, Anthropic (Claude) receives that question along with your budget, your open positions, your closed-trade totals and your recent signals, so the answer can be about your actual account rather than generic advice. Your name, email, phone number and Telegram ID are not sent — the figures travel without anything that names you. Nothing is sent unless you ask a question; commands like /portfolio are answered on our own server. For questions about market news, Claude may also run a web search through Anthropic's search service; only the search terms it writes (typically a ticker and a topic) go to that service, and the reply lists the sources it used.
- What that provider does with it. Under Anthropic's commercial terms, data sent through their API is not used to train their models, and inputs and outputs are deleted from their systems within 30 days. Two exceptions they state: content their automated systems flag as a policy violation is kept up to 2 years (safety classification scores up to 7 years), and they may retain data where the law requires it. Training can only happen if a customer submits feedback or bug reports to them — we send neither. Their policy is published at privacy.claude.com; we last checked it on 12 September 2026 and will re-check before this document takes effect.
- [Placeholder: payment processor, if any.]
We do not sell your data, we do not share it with advertisers, and we do not use it to train models about you.
4. International transfers
Some of these providers are outside the EEA — the AI assistant provider above among them. Where that is the case, transfers are made under the European Commission's Standard Contractual Clauses (2021/914), together with the technical measures described below (encryption in transit, access limited to the operator). You can ask us for a copy of the safeguards in place for a specific provider.
5. If you are in the EU or the UK
You have the right to: access a copy of your data; rectify anything wrong; erase your data ("be forgotten"); restrict or object to our processing, including processing based on legitimate interests; portability of the data you gave us, in a machine-readable form; and to withdraw consent where we rely on it, without affecting what came before.
Your closed-trade history is already exportable yourself, at any time, from Settings → Export your records. For anything else, message the bot; we will answer within one month. You may also complain to your national supervisory authority — in the UK, the Information Commissioner's Office.
We make no automated decisions that produce legal effects for you. Position sizing is arithmetic applied to the budget you declared, not a profile built about you.
6. How long we keep it
- Account details (name, email, phone, Telegram ID, budget): while you are subscribed, and for [Placeholder: 12] months afterwards in case you come back.
- Signals, positions and trade records: [Placeholder: 6] years, because they are the record of what we told you and what you told us — the same period tax and dispute rules generally require.
- Sign-in and delivery logs: [Placeholder: 90] days.
- Password reset codes: minutes. They expire 15 minutes after they are issued, are stored only as a hash, and are destroyed once used.
An erasure request removes the account data; we may keep the minimum needed for legal or accounting obligations, and we will tell you what that is.
7. How we protect it
Passwords are stored as bcrypt hashes, never in readable form — we cannot see yours, which is why a reset sends a code rather than your old password. Reset codes are hashed too, expire in 15 minutes, are single-use, and stop working after five wrong guesses. Sessions are signed cookies, HttpOnly, and carried over TLS once the portal is public. Access to the database is limited to the operator.
[Placeholder: breach-notification commitment — GDPR requires notifying the supervisory authority within 72 hours and affected people without undue delay where the risk is high.]
8. Cookies
One cookie: your sign-in session. It is strictly necessary for the portal to work, sets no identifier for advertising, and is not shared. We run no analytics, no tracking pixels and no third-party advertising.
9. Governing law
This notice is governed by the data protection law of [Jurisdiction], alongside the GDPR where it applies to you. Nothing here removes a right you have under the law of the country you live in.
10. Changes
If we change how we use your data in a way that matters, we will tell you through the bot before it takes effect.