The Market Robo™

Privacy Policy

Version v4-2026-10-10 · Effective 11/10/2026

Privacy Policy

Legal Document

Your privacy is important to us. This policy explains how we collect, use, and protect your information when you use TheMarket Robo.

Table of Contents

1.

Introduction

2.

Information We Collect

3.

How We Use Your Information

4.

Information Sharing and Disclosure

5.

Data Security

6.

Your Rights and Choices

7.

Cookies and Tracking Technologies

8.

Contact Information

9.

Children's Privacy

10.

International Data Transfers

11.

Changes to This Privacy Policy

12.

Compliance with Laws

13.

Data Protection Officer

1. Introduction

Welcome to TheMarket Robo, operated by TMKR Global, LLC ("we," "us," "our," or "Company"), a professional trading robot management and monitoring platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (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 TheMarket Robo, 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.

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 Financial Information

For trading robot management, we collect:

•

Trading performance data (profits, losses, win rates)

•

License information and usage statistics

•

Order history and transaction references (payment details are processed by the payment provider used at checkout)

•

Session data and trading activity

Note: Payment card information, billing addresses, and detailed payment transaction data are collected and processed by the payment provider used at checkout (merchant of record), not by us. We only receive transaction references and order confirmations from the payment provider.

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 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

•

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: Payment methods are not currently assigned. When you make a purchase, payment information (including card details, billing address, and transaction data) is collected and processed by the payment provider used at checkout, not by us. We do not store or have access to your full payment card details. 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

We retain your information for:

•

As long as your account is active

•

As needed to provide our services

•

As required by law or for legitimate business purposes

•

Until you request deletion (subject to legal requirements)

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.

ClassWhat it holdsSearchableArchiveWhy we keep it
Class

access

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

app

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

security

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

audit

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

evidence

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

ai-ops

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

ai-content

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

debug

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

metrics

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

deploy

What it holds

Records of our software releases

Searchable

—

Archive

2557 days (seven years)

Why we keep it

Accountability (GDPR Art 5(2))

Class

browser-storage

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

•

Delete your account through the app or by contacting us

•

Opt-out of non-essential communications

•

Control notification preferences

6.3 Data Deletion Requests

To request data deletion:

1.

Contact us using the information in Section 8

2.

Provide your account email and sufficient identification

3.

Specify what data you want deleted

4.

We will respond within 30 days

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

General / legal: info@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

TheMarket Robo is intended for users 18 years and older. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

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 TheMarket Robo, you acknowledge that you have read and understood this Privacy Policy.

This privacy policy is effective as of the date listed above and applies to all users of TheMarket Robo mobile application.