Privacy Policy

1. Introduction

Brownsolve LTD ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use The Keep HQ platform.

2. Data Controller

3. Information We Collect

3.1 Account Information

• Email address
• Display name / username
• Country and timezone
• Subscription tier and billing information

3.2 Trading Telemetry (Read-Only)

When you connect a trading bot, we receive:

• Account balance and equity
• Open positions (symbol, volume, profit/loss)
• Trade history (entry/exit prices, commissions, swaps)
• Safety flag status (daily loss limit, margin guard, etc.)
• Bot configuration parameters

We do NOT collect:

• Broker login passwords
• Exchange withdrawal keys
• Bank account details
• Credit card numbers (processed by LemonSqueezy/Stripe)

3.3 Usage Data

• Login times and IP addresses
• Feature usage patterns
• Dashboard interactions
• API request logs

3.4 Device Information

• Browser type and version
• Operating system
• Screen resolution
• Referral source

4. How We Use Your Data

4.1 Primary Purposes

• Platform Operation: Running the gamification engine, leaderboards, and dashboard
• Safety Monitoring: Detecting at-risk accounts and triggering alerts
• Billing: Processing subscriptions and payments
• Customer Support: Responding to inquiries and troubleshooting

4.2 Gamification

Your performance data is used to:

• Calculate XP, ranks, and badges
• Populate leaderboards (with your display name)
• Track trial progress
• Generate performance reports

4.3 Analytics

Aggregate, anonymized data is used for platform improvement, feature development, usage statistics, and marketing insights.

5. Data Sharing

5.1 Third-Party Processors

• LemonSqueezy / Stripe: Payment processing
• Hetzner: Cloud hosting and infrastructure
• Telegram: Optional alert notifications
• Cloudflare: CDN and DDoS protection

5.2 Legal Requirements

We may disclose data if required by court order or subpoena, regulatory investigation, or law enforcement request (with valid legal basis).

5.3 Business Transfers

In the event of a merger, acquisition, or asset sale, user data may be transferred with appropriate safeguards.

6. Data Security

6.1 Technical Measures

• AES-256-GCM encryption for API keys at rest
• TLS 1.3 for all data in transit
• Daily encrypted database backups
• Role-based access controls
• Regular security audits

6.2 Organizational Measures

• Staff bound by confidentiality agreements
• Security incident response plan
• Regular security training
• Third-party penetration testing

7. Data Retention

7.1 Active Accounts

Data retained for the duration of your subscription plus 90 days.

7.2 Deleted Accounts

• Personal identifiers anonymized within 90 days
• Trading telemetry retained in aggregate form for analytics
• Billing records retained for 7 years (legal requirement)

7.3 Backups

Backups are retained for 30 days with automated deletion.

8. Your Rights (GDPR)

If you are in the European Economic Area, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we use your data
• Portability: Receive your data in a machine-readable format
• Objection: Object to certain processing activities
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, email: privacy@thekeephq.com. We will respond within 30 days of receiving your request.

9. Cookies and Tracking

9.1 Essential Cookies

Required for platform functionality (authentication, security, preferences).

9.2 Analytics Cookies

Optional cookies for usage analytics. Can be disabled in browser settings.

9.3 Third-Party Cookies

Payment processors may use cookies for fraud prevention.

See our Cookie Policy for full details.

10. International Transfers

Data is primarily stored in the European Union (Germany via Hetzner). If data is transferred outside the EU, we ensure appropriate safeguards (Standard Contractual Clauses) are in place.

11. Children's Privacy

The Platform is not intended for users under 18 years of age. We do not knowingly collect data from children.

12. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified via email and dashboard alert. The "Last Updated" date at the top indicates the most recent revision.

13. Contact Us

• Email: privacy@thekeephq.com
• Postal: Brownsolve LTD, [Registered Address], Ireland
• Data Protection Officer: dpo@thekeephq.com

BY USING THE KEEP HQ PLATFORM, YOU CONSENT TO THE COLLECTION AND USE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.