TM9 ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use our platform, mobile apps (TM9, TM9 2.0, Master AI, MMM), and website. By using our services, you consent to the practices described below.
1. Who we are
TM9 is a software development and technology platform operated by [TM9 Legal Entity Name], registered at:
2006 Churchill Tower, Business Bay, Dubai, UAE
For privacy-related queries, contact [email protected].
2. Information we collect
A. Information you provide
- Account information: name, email address, phone number, password, country, profile picture.
- Identity verification (where applicable): government ID, KYC documents (only when required for premium services).
- Broker connection data: your broker account number, broker server, broker name, login credentials (stored encrypted, used solely to connect your account on the platform).
- Master AI / MMM credentials: when you link Master AI to MMM for auto-trading, we store the integration tokens needed to operate the connection.
- Payment information: billing details processed via Stripe, Razorpay, Apple, or Google. TM9 does not store full credit card numbers.
- Communications: support tickets, emails, chat messages, feedback.
B. Information collected automatically
- Device & technical data: IP address, device type, OS, browser, app version, language, time zone.
- Usage data: pages visited, features used, session duration, click patterns.
- Cookies & tracking: cookies, web beacons, and analytics pixels (see Section 9).
- Crash & performance logs: app stability, error reports.
C. Information from third parties
- Brokers: trade execution data, account balances, open positions (displayed for your reference).
- Payment processors: subscription and payment status.
- Authentication providers: if you sign in with Google, Apple, etc.
- Analytics providers: aggregated user behavior data.
3. How we use your information
- Provide the platform: create your account, connect your broker, display trading data.
- Operate Master AI & MMM: generate signals, execute auto-trades on your linked broker.
- Process payments: manage subscriptions, billing, and refunds.
- Communicate: service notifications, support replies, important updates.
- Improve the platform: analyse usage, fix bugs, build new features.
- Marketing (with your consent): promotional emails, in-app offers — opt out anytime.
- Security & fraud prevention: detect suspicious activity, prevent unauthorised access.
- Legal compliance: AML, KYC, tax, and regulatory obligations.
- Personalisation: recommend features, set defaults, deliver localised content.
4. Legal basis for processing (GDPR / DPDP / similar)
- Contract: to provide the services you requested.
- Consent: for marketing and optional features (you may withdraw consent anytime).
- Legal obligation: for tax, AML, KYC, regulatory compliance.
- Legitimate interest: for security, fraud prevention, product improvement.
5. How we share your information
We do not sell your personal data. We share data only as described below.
A. With your broker
When you connect a broker, we transmit the credentials and required data to enable trading. Your broker is an independent data controller with its own privacy policy.
B. With service providers
- Cloud hosting (AWS, Azure, your VPS providers)
- Payment processors (Stripe, Razorpay, Apple, Google)
- Analytics (Google Analytics, Firebase, AppsFlyer-style tools)
- AI providers (OpenAI, Azure OpenAI — used for chart analysis and signals)
- Push notifications (Firebase Cloud Messaging)
- Email services (transactional emails)
- Customer support tools
These providers are contractually required to protect your data.
C. For legal reasons
We may disclose data to comply with subpoenas, court orders, government requests, or to enforce our Terms and protect our rights.
D. Business transfers
In case of a merger, acquisition, or sale of TM9 assets, your data may be transferred to the new owner under the same privacy commitments.
6. International data transfers
Your data may be processed in countries different from your own, including:
- United Arab Emirates (TM9 corporate operations)
- United States (cloud and AI providers)
- India (development and operations team)
- Singapore / Europe (cloud regions)
Where required, we use Standard Contractual Clauses (SCCs) or equivalent safeguards to protect cross-border transfers.
7. Data retention
- Account data: while your account is active + 7 years after closure (for tax/AML compliance).
- Trading records: as required by financial regulations.
- Marketing data: until you opt out.
- Logs & analytics: up to 24 months.
After retention periods, we delete or anonymise data securely.
8. Data security
- Encryption in transit (HTTPS / TLS 1.2+)
- Encryption at rest for sensitive data (broker credentials, payment data)
- Access controls: role-based access, audit logs
- Secure infrastructure: cloud-hosted with firewalls, DDoS protection
- Regular security reviews and patching
However, no system is 100% secure. You are responsible for keeping your account credentials private and using strong passwords.
9. Cookies & tracking
- Essential: login sessions, security.
- Analytics: understanding usage patterns.
- Preferences: language, theme, defaults.
- Marketing (with consent): promotion targeting.
You can control cookies via browser settings or via the in-app cookie banner where applicable.
10. Your rights
Depending on your jurisdiction (GDPR, India DPDP Act, CCPA, etc.), you have the right to:
- Access your data
- Correct inaccurate or incomplete data
- Delete your data ("right to be forgotten")
- Object to certain processing
- Restrict processing
- Data portability — receive your data in a machine-readable format
- Withdraw consent at any time
- Lodge complaints with a data protection authority
To exercise rights, email [email protected]. We respond within 30 days.
11. Children's privacy
TM9 is not intended for users under 18 years old. We do not knowingly collect data from children. If we discover such collection, we will delete it immediately. Parents who believe their child has provided data should contact us.
12. Automated decision-making & AI
TM9 uses AI (Master AI) for:
- Generating market analysis and trade signals
- Automated execution (in MMM)
- Fraud detection and risk scoring
AI signals are
not financial advice. Decisions to act on signals are yours. You may request human review of any significant automated decision impacting your account by contacting
[email protected].
13. Third-party links & apps
TM9 may link to or integrate with third-party services (brokers, payment processors, data providers). These services have their own privacy policies. TM9 is not responsible for third-party privacy practices.
14. Marketing communications
With your consent, we may send:
- Product updates and new features
- Promotional offers
- Educational trading content
- Newsletters
You can opt out anytime via the unsubscribe link in emails, app notification settings, or by emailing [email protected].
15. Financial transactions
TM9 does not process or hold trading funds. All deposits, withdrawals, and trading capital are handled exclusively by your broker. Privacy practices for trading funds are governed by your broker's policy. Contact your broker directly for any fund-related concerns.
16. Changes to this policy
We may update this Privacy Policy. Material changes will be notified via email to your registered address, in-app notification, or banner on trademaster9.com. Continued use after changes means acceptance of the updated policy.
For privacy questions, data requests, or complaints:
Thank you for trusting TM9.