Privacy Policy

1. What data we process

• Account data: name, email address, password (stored only as an irreversible hash), language, profile photo if you upload one, email verification status, account type (member, analyst) and the date you accepted the Terms of Service at sign-up. If you sign in with Google, we receive only your name and email address from Google.
• Security data: if you turn on two-step verification, the method you chose, the authenticator app secret or the phone number for SMS; hashes of one-time codes; hashes of app session refresh tokens and the device's browser/app description (user agent); IP addresses, to limit abuse.
• Membership and payment data: which Club and plan you joined, start and renewal dates, your cancellation reason if you give one, payment amounts, transaction and subscription references, refund requests and their reasons, your Makkler balance history and your MakklerPRO subscription. Your card number and security code never reach Makkler; the payment provider processes them directly. For app store purchases we keep the purchase records Google Play or Apple sends us.
• Content and communications: direct messages you send to analysts, your news comments, comments you report and users you block, your support requests, and messages you send through the contact form.
• Usage within the Platform: your watchlists and price alerts, holdings you enter in MakklerPRO, your notifications and whether you read them, and the Club you opened last. Questions you ask MakklerAI are processed only to generate the answer and are not stored on our servers.
• Device and notification data: your device's push token, its platform (Android, iOS or browser) and language, so we can send push notifications.
• Wallet data: your wallet address, if you link a Solana wallet for MKL. Blockchain transactions are public and cannot be deleted by us.
• Analyst data: in your application, your name, email, phone number, SPK licence number if any, channel link, follower estimate, interests and application text; once your Club opens, the bank account (holder, bank, IBAN, SWIFT) or crypto wallet address we pay you to, payout records and receipts; and the posts, videos, portfolio and futures records you publish.
• Technical logs: our server and content delivery infrastructure keeps access logs containing IP address, time of request, requested address and browser details, for security and troubleshooting.

2. Why we process it, and on what legal basis

• To create your account, sign you in and provide the Platform - performance of a contract.
• To run Club memberships, payments, renewals, cancellations and refunds, and to pay analysts - performance of a contract; legal obligation for payment and accounting records.
• To send email verification, password reset, two-step verification and transactional emails - performance of a contract.
• To deliver notifications such as new posts, portfolio updates and message replies - performance of a contract; for push notifications, also the permission you give on your device.
• Account and Platform security, preventing fraud and abuse, rate limiting, comment moderation, reports and blocking - legitimate interests and legal obligation.
• To answer support requests and contact form messages - legitimate interests and performance of a contract.
• To review analyst applications - steps prior to a contract and legitimate interests.
• To handle legal claims, chargebacks and disputes - establishment, exercise or defence of legal claims.

We do not send marketing emails, do not build advertising profiles, do not make automated decisions with legal effects on you, and do not sell your data.

3. Who we share it with

• The analyst of a Club you are a member of: your name, email address, plan and start date, the messages you send them and refund requests concerning their Club. Cancellation reasons are only shown to analysts in aggregate, without names.
• Other users: your news comments are public, together with your name.
• Payment providers: Helcim (Canada) for card payments on the website; Google (Google Play) and Apple (App Store) for in-app purchases.
• Infrastructure and service providers: server hosting (USA), Cloudflare (content delivery and attack protection), email delivery (Spacemail), push notifications (Google Firebase Cloud Messaging and Apple Push Notification service), the Solana network (MKL transactions) and OpenAI (answering MakklerAI questions and translating Club content).
• Competent authorities and courts: only where the law requires it.

Our service providers access data only as far as needed to provide their service to us.

4. International transfers

Makkler is a US company and our servers are in the United States. When you use the Platform from Turkey, the European Union or elsewhere, your data is transferred to the United States and to the countries where the providers above operate (for example Canada). These transfers are necessary for us to provide the service. See the Data Protection Notice for details.

5. How long we keep it

• Account data: for as long as your account is open. When you delete your account, your name, email, password, profile photo, messages, comments, watchlists, notifications, support conversations, wallet link and device tokens are deleted.
• Payment, refund and accounting records: for the period required by tax and accounting law. After account deletion these records no longer carry your name or email and are linked to an anonymous "Deleted user" record.
• Rate-limit records (which contain IP and email addresses) are kept for at most 2 days, expired app session tokens for at most an hour after they expire, and server access logs for about 14 days.
• Analyst applications, payout details and payout receipts: for the duration of the analyst relationship and the statutory retention periods after it.
• Contact form messages: in our mailbox for as long as reasonably needed to resolve your request and any dispute.

6. Cookies and data stored on your device

• Session cookies: keep you signed in and protect forms; strictly necessary.
• Language cookie (lang): remembers the language you chose for 1 year.
• Campaign cookie (makkler_pro_campaign): if you arrived through an analyst's MakklerPRO campaign link, remembers for 30 days which analyst a subscription is credited to. It contains only the campaign code.
• Cloudflare security cookies: may be needed to tell automated attack traffic apart.
• Browser storage: preferences such as theme, chart settings and the wallet app you used last are kept on your device only.

We use no advertising, analytics or tracking cookies or third-party scripts. YouTube videos on Club pages are shown in privacy-enhanced mode (youtube-nocookie.com): YouTube sets no cookies until you play a video, and once you do, YouTube's own privacy policy applies.

7. Mobile apps

Our Android and iOS apps use the same account and data as the website. Apart from internet access and (if you allow it) notifications, the apps ask for no permissions; they collect no location, contacts, camera, microphone or advertising ID data and contain no third-party analytics or advertising libraries. In-app purchases are processed by Google Play or the App Store. You can delete your account from the app's Account tab.

8. Age limit

The Platform is not for anyone under 18, and people under 18 may not open an account. If we learn that we are processing data of someone under 18, we close the account and delete the data.

9. Your rights

Your rights - such as access, correction, deletion, portability and objection - and how to exercise them are explained in the Data Protection Notice. You can delete your account yourself at any time. For any privacy request: [email protected].

10. Changes

We may update this policy. The date at the top shows the latest change; we will tell you about material changes by email.