Privacy Policy

1. Data Controller

Calamari Trading LLC, a Florida limited liability company, is the data controller for the personal information you provide when using our Services. For questions about this policy or to exercise your data rights, contact us at privacy@calamaritrading.ai.

2. What Data We Collect

We collect the minimum data necessary to deliver, operate, and support the Services. The following table describes each category of data we collect and why.

3. What We Do NOT Collect

This section is as important as the previous one. Calamari is designed so that your most sensitive trading data never touches our servers.

4. How We Use Your Data

We use the data we collect for the following purposes, each of which is necessary to deliver the Services or fulfill our legal obligations:

• —Service delivery: provisioning and managing your Tentacle, configuring MT4/MT5 terminals, and operating the Watchdog monitoring system.
• —Billing and payments: processing subscription charges, handling payment failures, and issuing refunds.
• —Customer support: responding to support requests, diagnosing technical issues, and providing onboarding assistance.
• —Service communications: sending transactional emails (account activation, billing receipts, maintenance notices, and security alerts).
• —Product improvement: analyzing aggregated, anonymized usage patterns to improve the Dashboard and platform features.
• —Legal compliance: fulfilling our obligations under applicable law, responding to lawful requests from government authorities, and enforcing our Terms of Service.

We do not sell your personal data. We do not use your data for advertising, behavioral profiling, or any purpose unrelated to delivering the Services.

5. Third-Party Service Providers

We share data with the following third-party service providers solely to the extent necessary to operate the Services. All providers are subject to contractual data processing agreements that prohibit them from using your data for any purpose other than providing their services to Calamari.

We do not share your data with any other third parties except as required by law or with your explicit consent.

6. Data Retention

We retain your personal data only for as long as necessary to deliver the Services and fulfill our legal obligations:

• —Account information and Tentacle configuration: retained for the duration of your active subscription, plus 30 days post-cancellation to allow for account recovery.
• —Billing records: retained for seven (7) years as required by applicable tax and financial regulations.
• —Support communications: retained for two (2) years from the date of the last interaction.
• —Tentacle telemetry data: retained for 90 days on a rolling basis.
• —Audit logs: retained for one (1) year.

Upon cancellation, your Tentacle is decommissioned and all associated data is permanently deleted after the 30-day recovery window, or immediately upon your explicit written request to privacy@calamaritrading.ai.

7. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data. We honor these rights regardless of where you are located.

To exercise any of these rights, email privacy@calamaritrading.ai. We will respond within 30 days. We may need to verify your identity before processing your request.

8. GDPR Compliance (EEA Residents)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) or equivalent legislation applies to our processing of your personal data. Our legal bases for processing are:

• —Contract performance: processing necessary to deliver the Services you have subscribed to.
• —Legal obligation: processing required to comply with applicable law.
• —Legitimate interests: processing for fraud prevention, security, and product improvement, where these interests are not overridden by your rights.
• —Consent: where we have obtained your explicit consent for a specific processing activity.

Your data may be transferred to and processed in the United States, where Calamari is headquartered. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses where required. You have the right to lodge a complaint with your local data protection authority.

9. CCPA Compliance (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you the following additional rights:

• —The right to know what personal information we collect, use, disclose, and sell.
• —The right to delete personal information we have collected from you.
• —The right to opt out of the sale of your personal information. Note: Calamari does not sell personal information.
• —The right to non-discrimination for exercising your CCPA rights.

To exercise your CCPA rights, contact us at privacy@calamaritrading.ai.

10. Security

We implement industry-standard technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include TLS encryption for all data in transit, access controls with multi-factor authentication for administrative systems, and audit logging of all data access events.

In the event of a data breach that compromises your personal information, we will notify you via email within 72 hours of discovering the breach, in accordance with applicable data protection law. See our Security Architecture page for a detailed description of our technical security controls.

11. Cookies and Tracking

The Calamari marketing website uses minimal cookies necessary for site functionality and session management. We do not use third-party advertising cookies or behavioral tracking pixels. The Dashboard uses session cookies to maintain your authenticated session. We do not use Google Analytics or similar third-party analytics services that track individual users across sites.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. We will provide at least 30 days' notice of material changes by posting the updated policy on our website and notifying you via the email address on file. The “Last Updated” date at the top of this page indicates when the policy was most recently revised.

13. Contact Information

For privacy-related inquiries, data subject requests, or to report a privacy concern: