How we collect, use, and protect your personal information

1. Introduction and Data Controller

This Privacy Policy describes how Talamo Solutions LTD (hereinafter, "Tálamo", "We", or "the Controller") collects, uses, stores, and protects the personal information of users of the Tálamo platform.

• Data controller: Talamo Solutions LTD
• Address: Bugo LLC, 2831 St. Rose Pkwy, Suite 244, Henderson, NV 89052
• Contact email: support@talamo.app

2. Personal Data Collected

We collect the following categories of personal data:

For copy trading we store an encrypted trading password for the account you connect, solely to read and replicate trades; it never allows withdrawals. Other connection identifiers are used solely to import performance data.

3. Purposes of Processing

We use your personal data for the following purposes:

• Account management: Create and maintain your user account, authenticate your identity, and provide access to services.
• Service provision: Provide educational tools, calculators, analysis, and Platform functionalities.
• Personalization: Adapt the user experience according to your preferences and declared experience level.
• Communications: Send service-related notifications, security updates, and, with your consent, commercial communications.
• Analysis and improvement: Analyze Platform usage to improve our services and develop new features.
• Legal compliance: Comply with applicable legal obligations and respond to requests from competent authorities.
• Security: Detect and prevent fraud, unauthorized access, and other illegal activities.

4. Legal Basis for Processing

The processing of your personal data is based on the following legal grounds:

• Contract performance: Processing is necessary to provide the services requested by the User.
• Consent: For sending commercial communications and using non-essential cookies, we request your prior consent.
• Legitimate interest: For usage analysis, service improvement, and fraud prevention, based on our legitimate interest in maintaining and improving the Platform.
• Legal obligation: To comply with applicable legal and regulatory requirements.

Access from artificial intelligence clients

When a user voluntarily connects an MCP-compatible client, Tálamo shares only the data requested by authorized tools.

• Access uses OAuth and is isolated by user and client application.
• It may include journal data, learning progress, published signals, and safe audited-account summaries.
• It never includes passwords, broker credentials, servers, secrets, or trading capability.
• For security, we log user, client, tool, outcome, and latency without storing sensitive response content.
• Revoking access in Settings invalidates the client; data deletion can be requested at soporte@talamo.app.

5. Data Retention

We retain your personal data for the time necessary to fulfill the described purposes:

• Account data: During the contractual relationship and up to 5 years after cancellation to comply with legal obligations.
• Browsing data: Maximum 24 months from collection.
• Imported trading data: Until the User requests deletion or cancels their account.
• Commercial communications: Until you withdraw your consent.

6. Data Sharing with Third Parties

We may share your personal data with the following categories of third parties:

• Infrastructure providers: Supabase (database and authentication), for secure data storage.
• Analytics tools: Google Analytics, to analyze Platform usage in aggregate form.
• Integration providers: MetaAPI, to import performance data when the User voluntarily connects their trading account.
• Competent authorities: When required by law or to protect our legal rights.
• Tálamo partners who referred you: they see your name, your masked email and phone, and your access status, to manage their relationship with you; your full contact only when they expressly request it, and every request is logged.
• Stripe (payment processor): processes your card charges; Tálamo never sees the full card number.

We do not sell or rent your personal data to third parties for commercial purposes.

7. User Rights

In accordance with applicable legislation, you have the following rights:

• Access: Request confirmation of whether we process your data and access it.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your data when it is no longer necessary for the purposes for which it was collected.
• Objection: Object to the processing of your data for reasons related to your particular situation.
• Restriction: Request restriction of processing in certain circumstances.
• Portability: Receive your data in a structured, commonly used, and machine-readable format.
• Withdrawal of consent: Withdraw your consent at any time, without affecting the lawfulness of prior processing.

To exercise these rights, contact us at: support@talamo.app

8. Information Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption of data in transit using HTTPS/TLS.
• Password encryption using secure algorithms.
• Role-based access control and two-factor authentication for administrators.
• Monitoring and logging of access to sensitive data.
• Regular backups and recovery procedures.
• Periodic security assessments.

9. Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience:

• Essential cookies: Necessary for the basic operation of the Platform (authentication, session preferences).
• Analytics cookies: To analyze Platform usage and improve our services.
• Preference cookies: To remember your settings (language, theme).

You can manage your cookie preferences in your browser settings.

10. International Transfers

Your data may be transferred and processed in countries other than yours:

• We use service providers located in different jurisdictions (mainly the United States and European Union).
• We ensure adequate safeguards exist for the protection of your data, such as approved standard contractual clauses.
• For more information about specific transfers, please contact us.

11. Policy Updates

We may update this Privacy Policy periodically:

• Modifications will be published on the Platform with an indication of the last update date.
• For significant changes, we will notify you by email.
• We recommend reviewing this policy regularly.

12. Contact

For any questions about this Privacy Policy or the processing of your personal data:

• Email: support@talamo.app
• Postal address: Bugo LLC, 2831 St. Rose Pkwy, Suite 244, Henderson, NV 89052