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Privacy Policy — Sala del Trading

Last updated: May 14, 2026

This Policy describes how Henry Lucena ("the Controller", "we") handles personal information of users ("you", "the User") of Sala del Trading services, which include:

  • Everywhare app (iOS / Android) with trading signals and MT5 execution.

  • Élite community on Circle (monthly subscription).

  • 1:1 Mentoring ("Trading Rentable en 4 Semanas").

  • Website saladeltrading.com.

By using any of these services you accept this Policy. If you do not agree, do not use the service.

1. Data controller

  • Controller: Henry Lucena (natural person)

  • Legal domicile: Republic of Argentina

  • Privacy contact: saladeltrading@gmail.com

If your jurisdiction grants you the right to contact a supervisory authority, in Argentina the competent body is the Agencia de Acceso a la Información Pública (AAIP) — argentina.gob.ar/aaip.

2. Data we collect

We only collect data necessary for each service to function:

Everywhare app

Account

  • Data: Email, display name you choose during onboarding

  • Source: You at sign-up

Settings

  • Data: Risk-per-trade percentage, auto-execute preference

  • Source: You while using the app

Broker data

  • Data: MT5 balance, currency, order ticket, fill price

  • Source: Synced from your MT5 account via our engine

Trading activity

  • Data: Signal ID, symbol, direction, levels, lot size, P&L

  • Source: Generated when you execute orders

Notifications

  • Data: Push notification token (Expo)

  • Source: Generated by your device

Legal acceptance

  • Data: Date of Terms and Privacy acceptance

  • Source: You at onboarding

Circle Élite community

Account

  • Data: Email, name, optional profile photo

  • Source: You when joining

Subscription

  • Data: Status, plan, start/renewal dates

  • Source: Payment processor

Participation

  • Data: Messages, comments, reactions you post

  • Source: You when participating

1:1 Mentoring

Contact

  • Data: Full name, email, WhatsApp / phone

  • Source: You at sign-up

Payment

  • Data: Billing data you provide to the processor

  • Source: You when paying

Sessions

  • Data: Notes the mentor takes on your progress (no sensitive data)

  • Source: Generated during the mentoring

We do not collect biometric data, health data, precise location, contacts, personal photos, browsing history outside our services, or data from minors.

3. How we use your data

Your data is used solely for:

  1. Service delivery: create and maintain your account, show you signals, execute trades you request, manage your subscription, coordinate mentoring.

  2. Operational communications: push notifications about order status, position closures, and new signals; emails about your subscription.

  3. Support: respond to inquiries you send us.

  4. Legal compliance: retain data required by tax and commercial law.

  5. Product improvement: detect errors and understand aggregate service usage (without identifying individuals).

We do not sell your data. Ever. Under any circumstances.

4. Who we share your data with

We work with vendors who process data on our behalf under confidentiality agreements and security standards:

Supabase (USA)

  • Purpose: App DB storage, authentication, realtime

  • Data shared: Everywhare account and trading data

Anthropic (USA)

  • Purpose: Automated technical analysis of signals

  • Data shared: Setup data (symbol, levels). NO personal data

Expo (USA)

  • Purpose: Push notification delivery

  • Data shared: Notification token

Vantage (MT5 broker)

  • Purpose: Actual order execution

  • Data shared: Trading activity you request to execute

Circle (Circle.so, USA)

  • Purpose: Élite community platform

  • Data shared: Your community profile data

Payment processors (Stripe, Whop, others)

  • Purpose: Subscription / mentoring billing

  • Data shared: Email, billing data you provide

Apple / Google

  • Purpose: App distribution

  • Data shared: Data required by the stores (no additional sharing)

Some vendors process data in the United States. By using our services you consent to this international transfer.

We may disclose data if required by a competent authority via court order or applicable regulation.

5. Retention period

  • Account data: as long as your account is active + 2 years from last activity.

  • Trading and billing data: 5 years (tax compliance and dispute resolution).

  • Circle messages: while your account is active. Upon termination you may request deletion of your messages (subject to context: replies to others may remain anonymized to preserve the thread).

  • Notification tokens: while valid. Removed if you revoke permissions on your device.

Upon account deletion, we remove identifiable personal data except what we are legally required to retain.

6. Your rights

You have the right to:

  • Access: know what data we hold about you.

  • Rectification: correct inaccurate data.

  • Erasure: request deletion of your data ("right to be forgotten").

  • Objection: object to specific processing.

  • Portability: receive your data in a structured format.

  • Withdraw consent: when processing is based on it.

To exercise any of these rights, write to saladeltrading@gmail.com. We respond within 10 business days.

If you believe we have not addressed your complaint, you may file a claim with the AAIP.

7. Security

We apply reasonable technical and organizational measures:

  • Encryption in transit (HTTPS/TLS) for all communication.

  • Encryption at rest in certified cloud providers.

  • Row-level security in the app database: you only access your own data.

  • Authentication with secure tokens and automatic refresh.

  • Periodic access auditing.

No system is 100% secure. We will notify you within a reasonable timeframe if an incident affects your data.

8. Minors

Our services are not directed at individuals under 18. We do not knowingly collect data from minors. If you discover a minor is using our services, contact us and the account will be deleted.

9. Cookies and similar technologies

Everywhare app: does not use browser cookies. It uses local device storage (Expo SecureStore) to keep your session signed in.

Website saladeltrading.com: may use technical cookies for session and analytics cookies to understand site usage (aggregated). You can reject them from your browser.

10. Changes to this policy

We may update this Policy. If changes are material, we will notify you in-app, in Circle, or by email before they take effect. The current version is always available at saladeltrading.com/privacy and within the app.

11. Governing law

This Policy is governed by the laws of the Republic of Argentina, in particular Law 25.326 on Personal Data Protection and its regulations.

12. Contact

For any privacy inquiry or to exercise your rights:

Email: saladeltrading@gmail.com