Draft
M$M$ Privacy Policy
DRAFT. This text is pending review by a lawyer. It is not final and is not a binding contract until its final publication.
This is the governing version.
Last updated: [DATE]
1. Controller
[COMPANY NAME], Tax ID [TAX ID], registered address [ADDRESS]. Privacy email: [PRIVACY EMAIL]. [Data protection officer, if appointed: DPO DETAILS].
2. What data we process
| Category | Examples | Where it comes from |
|---|---|---|
| Identification and contact | Name, email, Telegram username, country | You |
| Verification (KYC) | Identity document, selfie, date of birth, country of residence | You, through the verification provider |
| Wallet | Public address of your Solana wallet for receiving Payouts | You |
| Simulated trading activity | Orders, trades, balances, rule indicators | Generated when you use the Dashboard |
| Payments and purchases | Orders, amounts, payment method, transaction identifiers | You and the payment gateways (we do not store card numbers) |
| Affiliates | Code, Referrals, commissions, payment details | You and the affiliate system |
| Support | Conversations with the support chat (including the AI assistant), emails, tickets | You |
| Technical | IP address, device, browser, access logs, cookies | Your device |
We do not process special categories of data. The Services are not directed at persons under 18.
3. Purposes and legal bases
| Purpose | Legal basis (Art. 6 GDPR) |
|---|---|
| Creating your profile, giving you access to the Simulated Accounts and applying the rules | Performance of the contract |
| Calculating and paying Payouts and commissions | Performance of the contract |
| Verifying identity, age and country; preventing fraud and complying with international sanctions | Legal obligation and legitimate interest in preventing fraud |
| Handling support requests and complaints | Performance of the contract |
| Risk alerts via Telegram or email ("you have 2% left before the daily loss limit") | Performance of the contract (you can switch them off) |
| Marketing communications and waiting list | Consent (you can withdraw it at any time) |
| Public transparency dashboard and leaderboard | Legitimate interest, only with aggregated data or pseudonyms that you choose; never email, real name or full wallet address |
| Security, basic analytics and service improvement | Legitimate interest |
| Accounting and tax | Legal obligation |
4. Automated decisions
4.1. The risk engine automatically decides whether an account is breached by applying the published rules (drawdown, daily loss, scalping, gambling). This is necessary for the performance of the contract and is based only on data that you can see on your Dashboard.
4.2. You have the right to obtain human intervention, to express your point of view and to contest the decision, in accordance with clause 15 of the Terms.
4.3. The support AI assistant does not approve or refuse Payouts and does not take decisions about your account; in the event of a dispute, it escalates to a person.
5. Who we share your data with
Only with providers that process it on our behalf (processors) or where required by law:
| Provider (planned) | Purpose | Location / safeguard |
|---|---|---|
| Supabase (database) | Data hosting | [EU region if chosen; otherwise, standard contractual clauses] |
| Vercel (website) | Website hosting | United States — Data Privacy Framework / standard clauses |
| Anthropic (Claude API) | Support assistant | United States — standard clauses / DPF [confirm] |
| Confirmo (crypto payments) | Collections and payments | Ireland (EU) |
| Paytiko and its acquirer (card) | Card collections | [To be confirmed] |
| KYC provider | Identity verification | [To be confirmed] |
| Telegram | Alerts bot (if you enable it) | Subject to Telegram's policy |
| Advisers, auditors and authorities | Legal obligations | Spain / EU |
We do not sell your data.
6. Data on the blockchain
Payouts are sent over the Solana network. Transactions are public and permanent: anyone can see the destination address, the amount and the date. We cannot delete them. In our transparency dashboard we never link an address to your identity.
7. How long we keep your data
| Data | Period |
|---|---|
| Profile and trading activity | While you have an account and for [5] years afterwards, for claims |
| KYC and anti-money laundering | The applicable statutory period [10 years, to be validated] |
| Invoicing | 6 years (Código de Comercio, the Spanish Commercial Code) / 4 years (tax legislation) |
| Support conversations | [2] years |
| Waiting list and marketing | Until you withdraw your consent |
| Technical logs | [12] months |
8. Your rights
Access, rectification, erasure, objection, restriction, portability and the right not to be subject to decisions based solely on automated processing without human intervention. Write to us at [PRIVACY EMAIL] with proof of identity. If you are not satisfied with our response, you can lodge a complaint with the Agencia Española de Protección de Datos (AEPD, the Spanish Data Protection Agency) (aepd.es).
9. Security
Encryption in transit, role-based access control, audit logs and minimal access to KYC data. We will never ask you for your seed phrase or your private key.
10. Cookies
We use necessary technical cookies and, only with your consent, analytics and affiliate cookies (to attribute Referrals). Details in the Cookie Policy [PENDING].
11. Changes
If we make material changes to this policy, we will notify you by email and on the Dashboard.