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Privacy Policy

Last updated: October 4, 2026

1. Introduction

At TRINY ("we", "our") we respect the privacy of our users. This Privacy Policy explains what data we collect, how we use it, who we disclose it to and what rights you have regarding your personal information when you access triny.trade or use the TRINY app (app.triny.trade).

2. Data we collect

We collect the following categories of data:

  • Data you provide directly: email address, name, payment information — when you subscribe through Stripe. Card details are entered directly with Stripe and never reach our servers.
  • Technical data: IP address, browser type, operating system, pages visited, time spent on the site — collected automatically.
  • Usage data: content interaction, button clicks, display of promotional popups.
  • Cookies: strictly necessary ones (session, checkout hand-off, remembering your cookie choice) and, only with your consent, measurement and advertising cookies. You can refuse on your first visit or change your choice at any time from the „Cookies" button in the corner of the page.
  • Affiliate program: if you arrived through a member's personal link (triny.trade/i/…), we keep their code and first name in a cookie for 60 days so we can credit your subscription to them. If you pay, the member sees only your masked email (for example „a•••@g•••.com”), the plan, the amount and the payment date, for their commission.
  • Your app account: email address, name, password (stored only as a hash that we cannot read), your Discord identifier if you link it, your preferences, your Academy progress and the devices on which you enabled notifications.
  • The in-app assistant (the “Mentor”): the questions you write and the answers you receive, kept in your account.
  • Agreement log: the date and time you accepted the Terms and the risk warnings in the app, the version accepted, the account email address, the IP address and the browser type.

3. How we use data

We use the collected data to:

  • Provide and manage access to the Platform and TRINY community;
  • Process payments and manage subscriptions;
  • Improve site performance, design and features;
  • Respond to your requests and questions, including through the in-app assistant;
  • Keep evidence that you accepted the Terms and the risk warnings;
  • Send communications related to your account or offers, within the limits of your consent;
  • Comply with applicable legal and regulatory obligations.

4. Legal basis (GDPR)

We process your personal data based on the following legal bases provided by Regulation (EU) 2016/679 (GDPR):

  • Contract performance — to provide the services you subscribed to;
  • Your consent — for non-essential cookies and marketing communications;
  • Legitimate interest — to improve the Platform, prevent abuse and keep evidence of your agreements, for the establishment, exercise or defence of legal claims;
  • Legal obligation — to comply with tax and commercial legislation.

5. Data sharing

We do not sell your personal data. We may share information with:

  • Stripe Payments Europe, Ltd. (Ireland) — payment processing and subscription management;
  • Discord Netherlands B.V. — granting and revoking community access, based on your Discord identifier;
  • Vercel Inc. — hosting of the site and the app;
  • Infrastructure providers for the app — the database (in the European Union), sending of emails and notifications;
  • An artificial intelligence service provider — receives your profile name and the questions you write to the in-app assistant, in order to generate the answer. It may process this data outside the EEA, including in the USA, under the safeguards provided by GDPR (Standard Contractual Clauses). Please do not include sensitive data about yourself in your questions;
  • Meta Platforms Ireland Ltd. — only if you accepted advertising cookies: conversion measurement via the Meta Pixel and Conversions API. We send a browser identifier, your email address and an internal customer identifier — the last two irreversibly hashed — at the time of payment and on each renewal, plus the campaign source that brought you. Meta may transfer this data outside the EEA, including to the USA, under Standard Contractual Clauses and the EU-US Data Privacy Framework;
  • Public authorities — when required by law.

These third parties process data according to their own privacy policies and are required to comply with applicable data protection legislation.

6. Cookies and similar technologies

The TRINY website uses cookies and equivalent technologies (localStorage, sessionStorage) to provide an optimal experience, remember your preferences and measure performance. You can disable cookies from your browser settings, but certain features may become unavailable.

7. Data retention

We retain personal data only for as long as necessary for the purpose for which it was collected, including to fulfill legal, accounting or reporting obligations. After this period expires, the data is securely deleted or anonymized. The agreement log (evidence that you accepted the Terms and the risk warnings) is kept after your account is closed, for the applicable limitation period, as a rule 3 years.

8. Your rights

In accordance with GDPR, you have the following rights:

  • Right to access your personal data;
  • Right to rectification of inaccurate data;
  • Right to erasure of data ("right to be forgotten");
  • Right to restriction of processing;
  • Right to data portability;
  • Right to object to processing;
  • Right to withdraw consent at any time;
  • Right to file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP).

To exercise these rights, you can contact us at the email address listed at the end of the document.

9. Data security

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure or destruction. However, no data transmission over the internet is completely secure; we cannot guarantee absolute security.

10. Minors

TRINY is not directed to persons under 18 years of age. We do not knowingly collect personal data from minors. If you discover that a minor has provided us with personal data, please contact us to delete it.

11. Policy changes

We may update this Privacy Policy from time to time. The updated version will be posted on this page, with the last modification date listed above. We encourage you to check back periodically to see any changes.

12. Contact

For any questions regarding this Privacy Policy or the processing of your personal data, you can contact us at: hello@triny.trade