Privacy Policy

Effective Date: October 2, 2026

1. Introduction

jazzrabbit OÜ (Registry code: 16489902, Estonia), operating TTMT ("Telegram to MetaTrader"), is committed to protecting your privacy. This policy explains how we collect, use, and protect your personal data.

2. Data Controller

jazzrabbit OÜ
Registry code: 16489902
Estonia
Email: [email protected]

3. Data We Collect

3.1 Account Information

• Email address
• Name (optional)
• Password (hashed)

3.2 MetaTrader Credentials

• MetaApi account tokens
• Broker account information (encrypted)

3.3 Telegram Data

• Telegram session data (for channel monitoring)
• Channel IDs you choose to monitor
• Signal messages from your selected channels

3.4 Trading Data

• Trade history and positions
• Signal parsing results
• Performance metrics

3.5 Affiliate Payout Details

If you are an affiliate and ask for a payout, we store the payout details you give us (your name, country, and a bank or Wise/Revolut identifier), encrypted, so that we can pay you.

3.6 Technical Data

• IP address
• Browser type and version
• Device information
• Usage analytics (via Posthog)

3.7 Bot Protection Data (Cloudflare Turnstile)

To protect sign-up and other forms from abuse, we use Cloudflare Turnstile in invisible mode. Cloudflare processes a limited set of technical data (e.g. IP address, request headers, browser characteristics, and challenge interaction signals) to determine whether a visitor is human. No visible challenge is shown.

Cloudflare's processing of this data is governed by the Cloudflare Turnstile Privacy Addendum, which forms part of this Privacy Policy in respect of Turnstile.

4. How We Use Your Data

We use your data to:

• Provide and operate the TTMT service
• Execute trades on your behalf
• Monitor Telegram channels you specify
• Improve our signal parsing AI
• Send service-related communications
• Comply with legal obligations

5. Legal Basis for Processing

Under GDPR, we process your data based on:

• Contract - to provide our service to you
• Legitimate Interest - to improve our service and prevent fraud
• Legal Obligation - to comply with applicable laws
• Consent - for marketing communications (where applicable)

6. Data Storage and Security

6.1 Infrastructure

• All data is hosted on Hetzner servers in Germany (EU)
• Database services provided by Supabase (SOC2 certified)

6.2 Security Measures

• All data encrypted in transit (TLS 1.3)
• Sensitive data encrypted at rest
• Regular security audits
• Access controls and authentication

6.3 Retention

• Account data: retained while your account is active
• Trading data: retained for 2 years after account closure
• Analytics data: anonymized after 26 months
• Trial-eligibility record: to prevent repeated free trials we keep a pseudonymised record (a keyed hash, not the value itself) of the Telegram phone number, username and account ID connected to your account and of the fingerprint of the payment card on your subscription. It is recorded when a subscription starts, and again when you connect or change your Telegram account or change your card. This record is kept after an account is deleted. We use it to decide whether a free trial is available and, until a first payment has been made, whether a trading account can be connected or reconnected and whether an extra account slot can be bought. Our support staff can see which kind of identifier matched (phone number, username, account ID or card).

7. Third-Party Services

We share data with trusted third parties:

8. International Transfers

When data is transferred outside the EU/EEA, we ensure appropriate safeguards:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Certified providers (Privacy Shield successors)

9. Your Rights (GDPR)

Under GDPR, you have the right to:

• Access - request a copy of your data
• Rectification - correct inaccurate data
• Erasure - request deletion of your data
• Portability - receive your data in a portable format
• Restriction - limit how we use your data
• Objection - object to certain processing
• Withdraw Consent - where processing is based on consent

Erasure does not remove the trial-eligibility record described in section 6.3. That record is pseudonymised, and we keep it on the basis of our legitimate interest in preventing repeated free trials.

To exercise these rights, contact: [email protected]

10. Cookies

We use essential cookies for:

• Authentication and session management
• Security (CSRF protection)

Analytics cookies (Posthog) are used with your consent.

11. Children's Privacy

Our service is not intended for anyone under 18. We do not knowingly collect data from minors.

12. Changes to This Policy

We may update this policy with reasonable notice. Material changes will be communicated via email.

13. Contact & Complaints

For privacy inquiries:
Email: [email protected]

You may also lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon): www.aki.ee