Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide

When you register or use our Service, you may voluntarily provide:

• Telegram Data: User ID, username, first/last name
• Payment Information: Transaction history, order IDs, payment status (we do NOT store credit card numbers — all payments are processed by Midtrans, a PCI DSS-certified payment gateway)
• TradingView Username: For granting indicator access
• IB Verification Data: Deposit proof you upload for Exness IB verification
• Mentorship Data: Registration information for mentorship programs

1.2 Information Collected Automatically

When you visit our website, certain information may be collected automatically:

• Log Data: IP address, browser type and version, pages visited, time and date of visit, time spent on pages, and other diagnostic data
• Device Data: Device type, operating system, unique device identifiers
• Cookies & Similar Technologies: See Section 5 below for details

1.3 Information from Third Parties

We may receive information about you from third-party services you use in connection with our Service, including Telegram, Midtrans, and TradingView, limited to what is necessary to provide our Service.

2. Legal Basis for Processing

We process your personal data based on:

• Consent: You have given explicit consent for processing your data for one or more specific purposes
• Contract Performance: Processing is necessary for the performance of a contract (e.g., providing membership access, processing payments)
• Legitimate Interest: Processing is necessary for our legitimate interests (e.g., improving our Service, preventing fraud) provided it does not override your fundamental rights
• Legal Obligation: Processing is necessary to comply with applicable laws

3. How We Use Your Information

We use the information we collect to:

• Process payments and provide access to subscriptions and services
• Manage memberships, renewals, and account administration
• Verify IB registrations and grant complimentary access
• Grant TradingView indicator access
• Send service-related notifications via Telegram
• Manage mentorship program enrollment
• Improve, personalize, and optimize our website and Service
• Respond to inquiries, support requests, and customer service
• Detect, prevent, and address technical issues, fraud, or abuse
• Comply with legal obligations and enforce our terms

4. Data Sharing & Disclosure

We do NOT sell, rent, or trade your personal data to third parties. We may share information only in the following circumstances:

• Payment Processor (Midtrans): Transaction data necessary to process payments securely
• Telegram API: To deliver messages, manage groups, and provide bot functionality
• TradingView: Your TradingView username only, to grant indicator access
• Legal Requirements: When required by law, regulation, legal process, or governmental request
• Protection of Rights: To enforce our policies, protect our rights, privacy, safety, or property, or that of others
• Business Transfers: In connection with any merger, acquisition, or sale of assets, your data may be transferred as part of that transaction

5. Cookies & Tracking Technologies

Cookies are small text files stored on your device when you visit a website. We use cookies and similar technologies as follows:

5.1 Essential Cookies

Required for basic website functionality, including admin panel authentication. These cannot be disabled as they are necessary for the Service to function.

5.2 Analytics Cookies

We may use third-party analytics services (such as Google Analytics) to help us understand how visitors use our website. These services may collect information such as your IP address, browser type, referring/exit pages, and timestamps. Google Analytics uses cookies to collect this information. You can learn more about how Google uses data at Google's Partner Sites page.

5.3 How to Manage Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or to alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of certain parts of the Service. You can also opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

6. Data Security

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

• HTTPS/TLS encryption for all data in transit
• Encrypted database storage (Supabase PostgreSQL)
• HMAC-based authentication for the admin panel
• PCI DSS-certified payment processing via Midtrans
• Regular security reviews and updates

While we strive to protect your personal data, no method of transmission or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to continuous improvement.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• Account Data: Retained for the duration of your active membership and for up to 12 months after expiration
• Transaction Records: Retained for 5 years to comply with tax and financial record-keeping obligations
• IB Verification Data: Retained for 6 months after verification, then deleted
• Communication Logs: Retained for up to 12 months

When data is no longer needed, it is securely deleted or anonymized.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including countries where our hosting providers (Supabase, Vercel, Fly.io) maintain servers. These countries may have data protection laws that are different from those in your jurisdiction. By using our Service, you consent to such transfers. We take appropriate safeguards to ensure that your personal data remains protected in accordance with this Privacy Policy.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Request that we limit how we use your data
• Right to Data Portability: Request a machine-readable copy of your data
• Right to Object: Object to our processing of your data based on legitimate interests
• Right to Withdraw Consent: Withdraw previously given consent at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us through the channels listed in Section 13. We will respond to your request within 30 days.

10. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal data from a child under 18 without parental consent, we will take steps to delete that information as soon as possible. If you believe we have collected data from a child, please contact us immediately.

11. Third-Party Links & Services

Our Service may contain links to third-party websites, services, or applications (including but not limited to Telegram, TradingView, Midtrans, and Exness) that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policy of every site you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. We encourage you to review this Privacy Policy periodically. Material changes will be communicated via our website and/or Telegram. Your continued use of the Service after any changes indicates acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Telegram Bot: @AudenFXbot
• Website: audenfx.com

14. Consent

By using our website and Service, you hereby consent to our Privacy Policy and agree to its terms.