Privacy Policy

SAM — Smart Allocations Mechanism

Last updated: June 2026

1. Introduction

Smart Allocations Ltd. ("we", "our", "us") operates the SAM application. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

2. Information We Collect

a) Information You Provide

• Name, email address, and phone number during registration
• Referral codes
• Exchange API keys for connected accounts — Binance, Bybit, Kraken (stored encrypted, never shared)
• Configuration preferences and investment rules

b) Information Collected Automatically

• Device information (model, OS version, unique device identifiers)
• Usage data and interaction logs
• IP address and approximate location
• Push notification tokens

c) Third-Party Services

We may receive information from third-party authentication providers (Apple, Google) if you choose to sign in through those services.

3. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Execute your configured automation rules via your connected exchange's API
• Send verification codes and important service notifications
• Provide customer support
• Improve and personalise the service
• Comply with legal obligations
• Detect and prevent fraud or abuse

4. Data Sharing

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

• Service providers who assist in operating the platform (cloud hosting, analytics, notifications)
• Your connected exchange (Binance, Bybit, or Kraken), solely to execute your configured rules via their API
• Law enforcement or regulatory authorities when required by law
• A successor entity in the event of a merger or acquisition

5. Data Security

We implement industry-standard encryption and security measures to protect your data. API keys are stored using AES-256 encryption. However, no method of transmission over the internet is 100% secure.

6. Data Retention & Deletion

We retain your personal information for as long as your account is active or as needed to provide services. You can permanently delete your account and associated data at any time directly in the app, from Settings → Delete Account; this removes your portfolios, configuration, and personal data, subject to any limited records we are legally required to retain. You may also contact us to request deletion.

7. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate personal data
• Request deletion of your personal data
• Object to or restrict processing of your data
• Data portability
• Withdraw consent at any time

8. Cookies and Tracking

The mobile application may use local storage and analytics SDKs to improve user experience. We do not use third-party advertising cookies.

9. Children's Privacy

SAM is not directed at anyone under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us immediately.

10. International Transfers

Your data may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place in compliance with applicable data protection laws.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or an in-app notification.

12. Contact Us

For privacy-related inquiries or to exercise your rights, contact us at:

noam@smartallocations.com

Smart Allocations Ltd.