Privacy Policy

1. Scope

This Privacy Policy explains what data the TMC Interface processes, why, and your choices. TMC is a non-custodial interface and collects the minimum data needed to run a secure trading tool.

2. Data We Collect

• Email address — collected only if you use the Embedded ("1-Click") Wallet, to provision and recover your Embedded Wallet through our infrastructure provider Turnkey, and to secure your account. If you only ever use a Connected Wallet (e.g., Phantom), we do not collect your email.
• Wallet public addresses — the public Solana addresses you connect or that are provisioned for you (already public on-chain).
• Technical and usage data — IP address, device/browser information, and server logs, for security, abuse and fraud prevention, rate-limiting, and diagnostics.
• Local device storage — session data, wallet references, and preferences stored in your browser to run the Interface.

We do NOT collect fiat, bank, or payment details (there is no fiat on-ramp), government-ID or KYC documents, or any token-creation data.

3. What We Cannot Access

TMC cannot access your private keys or seed phrases. For an Embedded Wallet, keys are generated and held within Turnkey's hardware-backed secure enclave (TEE) and unlocked by your passkey; no seed phrase is generated, and TMC cannot view, export, move, or reconstruct them. For a Connected Wallet, keys never leave your own wallet software. We cannot recover your Wallet for you.

4. How We Use Data

To: (a) provide and operate the Interface and your Wallet; (b) authenticate you and enable Embedded-Wallet login and recovery; (c) secure the service, prevent abuse/fraud, and enforce rate limits; (d) maintain, debug, and improve the Interface; and (e) comply with applicable legal obligations. We do not sell your personal data and do not use it for third-party advertising.

5. Legal Bases

Where data-protection law applies (including the GDPR, given the operator's location), we rely on: performance of our agreement with you; our legitimate interests (security, abuse prevention, service integrity); your consent where required; and compliance with legal obligations.

6. Service Providers (Sub-processors)

We rely on the following providers, which process data on our behalf under their own terms and safeguards: Turnkey (Embedded-Wallet infrastructure — secure-enclave key management, passkey and email-based recovery); Cloudflare (frontend hosting, CDN, and DNS); Railway (backend application and database hosting); Helius (Solana RPC / blockchain access); PumpPortal (market-data ingestion); Solana Tracker (historical chart data); Pinata / IPFS (token image hosting); Jupiter (swap routing, on-chain); TradingView (chart-rendering library that runs in your browser — see the TradingView Attribution page).

7. On-Chain Data Is Public

Any transaction you sign and broadcast — including your Wallet address, amounts, and counterparties — is recorded on the public Solana blockchain, is permanent, and is outside our control. This is inherent to public blockchains.

8. Cookies and Local Storage

The Interface uses browser local storage (and strictly necessary cookies) to run — e.g., to keep you signed in and store preferences. We do not use third-party advertising or cross-site tracking cookies. Clearing this storage may sign you out or affect functionality.

9. Data Retention

We keep personal data only as long as needed for the purposes above or as required by law, then delete or anonymize it. Technical logs are kept for a limited period. On-chain data cannot be deleted (Section 7).

10. Security

We use technical and organizational measures appropriate to the risk, and rely on providers such as Turnkey for hardware-backed key security. No system is perfectly secure, and you are responsible for protecting your device, passkey, and recovery email.

11. Your Rights

Depending on your location, you may have rights to access, correct, delete, restrict, object to, or port your personal data. To exercise them, contact pro.tmc.com@gmail.com. We cannot alter or delete on-chain data, and some data must be retained for security or legal reasons.

12. International Transfers

Our providers may process data in countries other than yours; where required, transfers rely on appropriate safeguards (such as standard contractual clauses).

13. Children

The Interface is for adults (18+) only. We do not knowingly collect data from anyone under 18.

14. Changes

We may update this Policy; the "Version" date reflects the latest revision.

15. Contact

Privacy questions or requests: pro.tmc.com@gmail.com.