Customer App Privacy Policy
Version v4-2026-10-10 · Effective 11/10/2026Customer App Privacy Policy
Legal Document
This policy explains how we collect, use, and protect your information when you use the The Market Robo mobile app (Customer App). Purchases are made on our website; the app is for managing licenses, sessions, orders, and support.
Table of Contents
Introduction
Information We Collect
How We Use Your Information
Information Sharing and Disclosure
Data Security
Your Rights and Choices
Cookies and Tracking Technologies
Contact Information
Children's Privacy
International Data Transfers
Changes to This Privacy Policy
Compliance with Laws
Data Protection Officer
1. Introduction
This Privacy Policy applies to the The Market Robo mobile application (the "App" or "Customer App") operated by TMKR GLOBAL LLC ("we," "us," "our," or "Company"). The App lets you manage trading robot licenses, view and control sessions, see order history, and contact support. Purchases of licenses are made on our website (themarketrobo.com), not in the App. This policy explains how we collect, use, disclose, and safeguard your information when you use the App.
This notice covers our website (themarketrobo.com), the TheMarketRobo customer app on iOS, Android and the web, the vendor and commissioner app, and the services behind them. trade-hub (trade.themarketrobo.com and its API trade.themarketrobo.xyz) has its own privacy notice, which you can read in trade-hub and on our website.
By using the App, you agree to the collection and use of information in accordance with this policy. We will not use or share your information with anyone except as described in this Privacy Policy. For our website and other services, see our general Privacy Policy (/privacy-policy).
Company Information
Legal Entity: TMKR Global, LLC
Legal Form: Limited Liability Company
Identification Number: 400450098
Registration Date: October 22, 2025
Registering Authority: LEPL National Agency of Public Registry, Georgia
2. Information We Collect
2.1 Personal Information
When you register for an account, we may collect:
Name and email address
Authentication credentials (password, tokens)
Profile information and preferences
2.2 License, Session, and Order Information
The App displays data linked to your account that is also used for trading robot management. We collect and show:
Trading performance data (profits, losses, win rates)
License information and usage statistics
Order history and transaction references (payments are made on our website; the App does not collect payment card details)
Session data and trading activity
Note: The App does not process payments. Purchases are made on our website, where payment card information and billing are handled by the payment provider (merchant of record). We only receive transaction references and order confirmations; the App displays your licenses, sessions, and order history linked to your account.
2.3 Device and Usage Information
When you use our apps or website, our servers record each request in an access log. The record holds:
the time;
the address requested, as a route, never the data you sent;
the result and how long it took;
a request identifier;
your IP address and your browser's or app's user agent;
a pseudonymous reference to your account.
We also keep:
an application log of errors and events, which never holds request bodies;
a security log of sign-in and authorisation outcomes;
an audit log of account, order, payment, credit and administrative actions.
§5.2 says how long each is kept.
On our website we use Vercel Web Analytics and Vercel Speed Insights, which count page views and measure how fast pages load. The customer app and the vendor and commissioner app contain no analytics or crash-reporting software.
2.4 Location Information
We use your IP address to deliver the service and to protect it. We do not work out your precise location from it. In our searchable logs the IP address is kept for 14 days, for security investigations. The archived copy holds only a salted hash of it.
2.5 Device Permissions
Depending on your platform and the features you use, the App may ask for OS-level permissions. You can review or change these at any time in your device settings.
Push notifications: To send account, session, and order-related alerts when you opt in.
Photos / media library: So you can choose images for your profile (for example, a profile picture), as explained in the system permission prompt.
Internet and network access: Required to reach our services, authenticate, and sync your licenses, sessions, and orders.
Sign in with Google or Sign in with Apple: When you choose these options, the sign-in flow may open your browser or system UI; Google and Apple process authentication data under their own policies (see Section 4.2).
2.6 User-authored content
User-authored content is what you write yourself: support tickets and messages, reviews and ratings, and the text you enter in free-text fields.
How long we keep it. We keep it for as long as your account exists. When you delete your account or ask us to erase it, we erase it or de-identify it. The exception is a record the law requires us to keep, such as an order; we keep that with your identity removed where we can.
If you use trade-hub, its notice covers the strategies, filters, orders and AI Strategy Builder conversations you create there. Your AI Strategy Builder conversations are de-identified 30 days after you last used them, and a copy of an AI call that an administrator captured to diagnose a fault is deleted 30 days after it was captured.
3. How We Use Your Information
We use collected information for the following purposes:
3.1 Core Functionality
Providing trading robot management and monitoring services
Authenticating user accounts and maintaining security
Coordinating payment processing (handled by the payment provider used at checkout) and managing licenses
Displaying performance analytics and trading statistics
3.2 Communication
Sending account-related notifications
Providing customer support
Delivering updates and important announcements
3.3 Service Improvement
Analyzing app performance and usage patterns
Improving user experience and features
Detecting and preventing fraud or abuse
Conducting research and development
3.4 Legal Compliance
Complying with legal obligations
Protecting our rights and the rights of others
Investigating potential violations of our terms of service
3.5 AI inference and training
Content you write in our apps is not sent to an AI provider.
If you use trade-hub's AI Strategy Builder, the prose you write there, together with the conversation it belongs to, is sent to Groq, Inc. (United States) or, for the AI options that use Claude models, to Anthropic, PBC (United States), to generate the builder's answer. An AI option can name a second model, so when the first cannot answer, the same prose can go to the next provider in that option's list. Neither provider is permitted to use it to train its models. trade-hub also learns from the builder's own failures (as codes, never your prose), may report a fault in its own software to GitHub (codes and counts only), and, while an administrator diagnoses a fault, may keep a copy of an AI call for up to 30 days. The trade-hub notice explains this in full.
Our engineers use an AI coding assistant, Anthropic's Claude, to investigate incidents. It reads our logs through a tier that carries no name, e-mail address or IP address, only pseudonymous references and request identifiers. That content is not used to train Anthropic's models.
4. Information Sharing and Disclosure
4.1 When We Share Information
We may share your information in the following circumstances:
With Your Consent: When you explicitly authorize us to share information
Service Providers: With trusted third-party service providers who assist in app operations
Legal Requirements: When required by law or to protect our legal rights
Business Transfers: In connection with a merger, acquisition, or sale of assets
4.2 Who processes your data for us
These companies process personal data on our behalf, under contracts that bind them to our instructions:
Amazon Web Services (AWS) (Ireland): holds your sign-in account and a second copy of our log archive, and sends our e-mail.
Hetzner (Germany): hosts our servers and databases, where your account data and every log line are first written.
Cloudflare (USA; storage in the EU): handles every connection to our servers, and keeps the primary copy of our log archive in its EU storage region.
Grafana Labs (USA; our data is stored in Frankfurt, Germany): keeps our searchable logs and metrics and runs our alerting.
Sentry (USA; our data is stored in Frankfurt, Germany): receives scrubbed error reports from our administration console and from trade-hub.
Vercel (USA): hosts our websites and web apps, keeps their short-lived runtime logs, and provides the website analytics in §2.3.
GitHub (USA): hosts our source code and our build and release records, and receives trade-hub's reports of faults in its AI Strategy Builder, which hold codes and counts only. By rule, your personal data does not go there.
Groq (USA): answers trade-hub AI Strategy Builder requests for the options that use its models, including as the next model in an option's list (§3.5).
Anthropic (USA): answers trade-hub AI Strategy Builder requests for the options that use its Claude models, including as the next model in an option's list, and provides the AI assistant our engineers use (§3.5).
healthchecks.io: alerts us when a scheduled job stops. It receives no personal data.
Telegram: carries our alert messages to the on-call engineer. It receives no personal data.
Payment providers are named at checkout.
Payment Data Processing
Payment Information: When you make a purchase on our website, payment information (including card details, billing address, and transaction data) is collected and processed by the payment provider used at checkout, not by the App. We do not store or have access to your full payment card details in the App. For how the payment provider handles your data, see the terms and privacy information provided at checkout.
5. Data Security
Security Measures
We implement industry-standard security measures to protect your information:
5.1 Security Measures
Encryption: data is encrypted in transit. Our log archive is encrypted at rest by its storage providers. The disks of our own servers are not yet encrypted at rest. Access to them is limited to named operators using individual keys, and no server accepts a direct inbound web connection.
Secure Servers: Information is stored on secure, monitored servers
Access Controls: Limited access to personal information on a need-to-know basis
Regular Audits: Periodic security assessments and updates
5.2 Data Retention
While your account is active, we retain the personal data needed to provide the App and linked services. After you delete your account or we terminate it, we will securely erase or irreversibly anonymize your personal data within 30 days, unless a longer period is required by law or for limited legitimate purposes described below.
We may retain certain records where necessary for legal, tax, accounting, fraud prevention, or dispute resolution—for example, transaction references and billing records related to purchases on our website—for up to seven (7) years, or as long as applicable law requires. Aggregated or de-identified data that cannot reasonably be linked to you may be kept longer for analytics and service improvement.
If your account becomes inactive, we may contact you at the email on file before further action. Unless we are required to retain data, dormant accounts may be scheduled for deletion after reasonable notice, consistent with the timelines above.
We keep your account data for as long as your account exists. Our logs and records are kept for the periods below. "Searchable" means our engineers can search the record in our hot log store. "Archive" is the sealed, locked copy we keep for accountability and investigations, stored in two separate places. After the stated period a record is deleted.
| Class | What it holds | Searchable | Archive | Why we keep it |
|---|---|---|---|---|
| Class
| What it holds Request log: time, route, result, duration, request id, IP address, user agent, pseudonymous account reference | Searchable 14 days | Archive 348 days; the IP address is replaced by a salted hash after 14 days | Why we keep it Security and service delivery: legitimate interest (GDPR Art 6(1)(f), Recital 49) |
| Class
| What it holds Application and error log, never request bodies | Searchable 14 days | Archive 348 days | Why we keep it Running and fixing the service: legitimate interest |
| Class
| What it holds Sign-in, authorisation and signature outcomes | Searchable 30 days | Archive 713 days; the person is pseudonymised after 30 days | Why we keep it Security, and establishing or defending legal claims |
| Class
| What it holds Ledgers and administrative decisions: orders, credits, payments, account and administrative actions | Searchable 90 days | Archive 2540 days (about seven years), de-identified before it is locked; kept after erasure | Why we keep it Accountability and the financial-records period (GDPR Art 5(2), 24, 32, 17(3)(b)) |
| Class
| What it holds Evidence of a security incident | Searchable for the incident | Archive Kept indefinitely under legal hold, reduced to counts and categories of the people affected | Why we keep it Documenting a personal-data breach (GDPR Art 33(5)) |
| Class
| What it holds trade-hub AI request log: timing, model, outcome, token counts, cost — never your prose | Searchable 30 days | Archive 183 days | Why we keep it Operating, securing and fixing the AI builder: legitimate interest (GDPR Art 6(1)(f)) |
| Class
| What it holds trade-hub AI Strategy Builder conversations and, only while call capture is on, the copy of what an AI call sent and answered | Searchable 30 days | Archive not archived; conversations de-identified 30 days after last use, captured calls deleted 30 days after capture, both erased with your account | Why we keep it Keeping it no longer than needed (GDPR Art 5(1)(e)) |
| Class
| What it holds Diagnostic output that could contain personal data | Searchable 7 days | Archive not archived | Why we keep it We try not to capture it at all |
| Class
| What it holds Counts and timings with no identifiers | Searchable counts only | Archive not archived; kept indefinitely, as counts are not personal data | Why we keep it Operating the service |
| Class
| What it holds Records of our software releases | Searchable — | Archive 2557 days (seven years) | Why we keep it Accountability (GDPR Art 5(2)) |
| Class
| What it holds What trade-hub keeps in your browser | Searchable until you sign out | Archive not archived; cleared when you sign out | Why we keep it Scoped to your account |
6. Your Rights and Choices
6.1 Access and Control
You have the right to:
Access: Request information about the personal data we hold about you
Correction: Request correction of inaccurate or incomplete information
Deletion: Request deletion of your personal information
Portability: Request a copy of your data in a structured format
Restriction: Request limitation of processing in certain circumstances
6.2 Account Management
You can:
Update your account information through the app settings
Request account deletion from the App (see Section 6.3) or by contacting us
Opt-out of non-essential communications
Control notification preferences
6.3 Data Deletion and Account Deletion
To request deletion of your account and associated personal data, start from the App:
Open the Profile screen in the App (it may appear as Profile & Settings in the navigation).
Scroll to the Danger Zone and the Delete Account section. Follow the instructions there to contact our team and complete verification.
Alternatively, email support@themarketrobo.com (mailto$1@themarketrobo.com) from your account email (or include your account email in the message) and state that you want your account and personal data deleted.
We will confirm receipt and respond within 30 days, subject to any legal retention exceptions described in Section 5.2. On the web app, account deletion may also be initiated from the same profile area; the flow is equivalent.
6.4 California Residents (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may apply to certain processing of your personal information.
We do not sell your personal information as that term is defined under the CCPA/CPRA.
We do not share your personal information with third parties for cross-context behavioral advertising (as described under CPRA) without appropriate consent where required by law.
We do not share your personal information with third parties for their own direct marketing purposes without your explicit consent.
You may exercise the access, deletion, and correction rights described in Section 6.1 by following the steps in Section 6.3 or contacting us as set out in Section 8. We will not discriminate against you for exercising these rights.
7. Cookies and Tracking Technologies
Website: Vercel Web Analytics and Vercel Speed Insights (§2.3).
Customer app, and the vendor and commissioner app: no analytics, crash-reporting or performance-monitoring software. We find and fix problems from our own server logs (§2.3).
All of our services: the server logs in §2.3, kept as §5.2 describes.
8. Contact Information
For privacy-related inquiries, data requests, or concerns:
Support Email: support@themarketrobo.com (mailto$2@themarketrobo.com)
General / legal: info@themarketrobo.com (mailto$3@themarketrobo.com)
Legal Address: Georgia, Tbilisi, Nadzaladevi district, Kursebi street, N 15
Company: TMKR Global, LLC
Response Time: We will respond to all privacy inquiries within 30 days.
9. Children's Privacy
The Market Robo Customer App is strictly intended for individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal data from someone under 18, we will take steps to delete that information promptly. If you believe a minor has provided us with personal data, please contact us immediately using Section 8.
10. International Data Transfers
Your data is stored in the European Union: in Germany (Hetzner, Grafana Labs, Sentry) and in Ireland (AWS), and our log archive is held in Cloudflare's EU storage region. Some providers are companies based in the United States, so they may access or process data from there: Cloudflare, Vercel, GitHub, Grafana Labs, Sentry, Groq and Anthropic. Where that happens, we rely on the European Commission's Standard Contractual Clauses, or on the EU–US Data Privacy Framework where the provider is certified. Our company is registered in Georgia.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will:
Each new version of this notice shows its own version number and effective date, both taken from our document records.
Before a material change takes effect, we will tell you by e-mail or in the app.
Your continued use of the App after changes become effective constitutes acceptance of the updated policy.
12. Compliance with Laws
European Union and United Kingdom (GDPR and UK GDPR). You can ask us for a copy of your data, and to correct, erase, restrict or move it. Where we rely on legitimate interest, you can object. You may complain to your local data-protection authority.
California (CCPA / CPRA). You have the right to know what personal information we collect, use and disclose; to delete it; to correct it; and not to be discriminated against for exercising these rights. We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
Australia (Australian Privacy Act 1988 and the Australian Privacy Principles). You may access and correct your personal information. We disclose it to the overseas recipients in §4.2, in the United States, the European Union and Georgia (APP 8). You may complain to us first; if you are not satisfied, you may complain to the Office of the Australian Information Commissioner.
Google Play Store requirements and policies.
13. Data Protection Officer
Privacy contact: privacy@themarketrobo.com. This mailbox handles privacy requests only, and it is separate from customer support. We log each request on the day it arrives. For requests about your own data, we answer within one month of receipt.
By using the The Market Robo App (Customer App), you acknowledge that you have read and understood this Privacy Policy.
This privacy policy is effective as of the date listed above and applies only to the The Market Robo customer mobile application. For the website and other services, see our general Privacy Policy.