🛡️ MARKET LLAMA — PRIVACY POLICY

Last Updated: [Insert Date]

1. Introduction

This Privacy Policy explains how Market Llama, operated under Lee Henry Inc. (“we”, “us”, “our”), collects, uses, stores, and protects your personal data when you access or use our Platform and Services.

We are committed to safeguarding your privacy and complying with applicable data protection laws, including the:

General Data Protection Regulation (GDPR)
Nigeria Data Protection Regulation (NDPR)
Other relevant regional privacy standards

By using Market Llama, you consent to the practices described in this Privacy Policy.

2. Definitions

“Personal Data” — Any information relating to an identified or identifiable individual.
“User” / “You” — Any individual or entity accessing the Platform.
“Platform” — The Market Llama website, dashboard, systems, automation tools, and all related services.
“Broker Account” — Third-party trading account (e.g., Deriv) connected to Market Llama via API Token.
“Processing” — Any operation performed on data (collection, storage, transfer, deletion, etc.).

3. Data We Collect

We collect the following categories of data:

3.1. Account Information

Full name
Email address
Password (encrypted)
Phone number (optional)
Country & region
IP address and device metadata
Timezone and language preferences

3.2. Broker Connection Data

When you connect a trading account:

Broker account Login ID
API Token (encrypted and never displayed again)
Account type (demo/live)
Balance, equity, margin
Trade history, open positions, past orders
Market data associated with your trading activity

We do NOT collect:

Broker account password
Withdrawal PIN or secure IDs
Personal data unrelated to trading activities

3.3. Transaction & Payment Data

When subscribing to a plan:

Payment method (card, bank, etc.)
Payment provider (Flutterwave, Paystack, Stripe)
Transaction ID
Subscription plan details
Billing status & history

We do not store full card numbers or sensitive payment credentials. All payments are processed securely via third-party partners.

3.4. Usage & Technical Data

Login logs
Page visits
Click interactions
Device type and OS
Browser data
Cookies and tracking identifiers (non-invasive)

3.5. Communication Data

Support messages
Emails sent to Market Llama
Notifications and feedback

4. How We Use Your Data

We use your data strictly for legitimate business purposes, including:

4.1. Service Delivery

Automating trades on your connected broker account
Providing analytics, insights, and performance dashboards
Managing your subscription and billing
Operating your Market Llama account
Improving strategy execution and accuracy

4.2. Security & Compliance

Detecting fraud or unauthorized access
Verifying user identity where necessary
Enforcing Terms & Conditions
Complying with legal obligations

4.3. Performance Optimization

Enhancing system efficiency
Monitoring platform performance
Training AI models on anonymized data

4.4. Communication

Sending service updates
Providing support
Delivering account notifications
Informing users of feature changes, strategies, or billing updates

5. Legal Basis for Processing (GDPR/NDPR)

We process data based on the following legal grounds:

Contractual Necessity — To deliver automated trading and analytics services.
Legitimate Interest — To improve system performance and detect fraud.
User Consent — For email communications, tracking cookies, or optional features.
Legal Obligation — To meet regulatory, tax, or compliance requirements.

6. API Tokens & Sensitive Access

Your API Token enables automated trading.

We guarantee that:

API Tokens are stored in encrypted form
Tokens are never shared with third parties
Tokens are never logged in plaintext
Tokens are only used to execute trades you authorize
You can revoke access at any time from your broker dashboard

We do not initiate withdrawals or deposits via your API Token.

7. Data Sharing & Third Parties

We do not sell or rent personal data.

We only share data with:

7.1. Payment Partners

Paystack
Flutterwave
Stripe

For billing and subscription processing.

7.2. Cloud & Infrastructure Providers

Secure hosting servers
Encrypted databases
Backup storage services

All providers meet industry security standards.

7.3. Compliance Authorities

Where legally required:

Government regulators
Law enforcement
Compliance auditors

8. Data Retention

We retain data only as long as necessary:

Account data — while your account remains active
Trading data — up to 5 years for compliance
Payment data — up to 7 years for tax purposes
API Tokens — deleted immediately when you disconnect an account
Communication logs — up to 24 months

Users may request data deletion at any time (see Section 11).

9. Cookies & Tracking

Market Llama uses:

Essential cookies (for login + dashboard functionality)
Analytical cookies (optional)
No invasive advertising cookies

You may disable cookies in your browser, but some features may stop working.

10. Data Protection & Security Measures

We use industry-grade security:

End-to-end data encryption
Encrypted API Token storage
Firewalls and intrusion detection
Access control and audit logs
Secure HTTPS communication
Regular security reviews and penetration testing

Despite this, no system is 100% risk-free.

11. User Rights (GDPR & NDPR)

You have full control over your personal data. You may:

Request access
Request correction
Request deletion
Request data portability
Withdraw consent
Object to certain processing
Request restriction of processing

To exercise these rights, contact: privacy@marketllama.com

We will respond within:

30 days (GDPR)
7–21 days (NDPR)

12. International Data Transfers

Your data may be processed outside your country, including the EU, US, or Africa, depending on server infrastructure.

We ensure:

Standard contractual clauses
GDPR-compliant safeguards
NDPR-compliant data transfer policies

Your data remains protected regardless of location.

13. Children’s Privacy

Market Llama does not knowingly collect data from individuals under 18 years of age. If we discover underage usage, we will immediately delete the account.

14. Changes to This Policy

We may update this Privacy Policy periodically. Updated versions will be posted on the Platform with a revised “Last Updated” date. Continued use of Market Llama constitutes acceptance of the updated Policy.

15. Contact Information

For privacy questions, data requests, or legal issues:

Market Llama Privacy Office
Email: privacy@marketllama.com
Website: www.marketllama.com