Privacy Policy

Last updated: September 6, 2026

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1. Introduction

This Privacy Policy explains how SULAMX LTD ("SulamX", "we", "us", or "our") collects, uses, and protects personal data when you visit sulamx.com (the "Site") or use our services, including the SulamX Pro chart-analysis tool for the TradingView platform (together, the "Services").

We keep data collection deliberately minimal. We collect only what we need to operate the Site, provide access to SulamX Pro, and support our customers. This policy describes exactly what that is — nothing more.

If you have any questions about this policy or your personal data, contact us at info@sulamx.com.

2. Data We Collect

We collect the following categories of data, and only these:

Contact form data. When you use the contact form on the Site, we receive the name, email address, and message you submit.

TradingView username. To grant you access to SulamX Pro after purchase, we need your TradingView username. We use it solely to provision invite-only access to the tool on the TradingView platform.

Email correspondence. If you email us (for example, at info@sulamx.com), we receive your email address and the contents of your message, and we keep the correspondence so we can respond and provide support.

Basic site analytics. The Site is hosted on Framer, which provides built-in, aggregate analytics (such as page views and general visitor counts). These hosting statistics are aggregate. Separately, Google Analytics is used after analytics consent, and Meta Pixel is used after marketing consent to measure page visits and the performance of our content and advertising. Meta may receive page URLs, referring pages, IP addresses, browser/device information and cookie identifiers, and may associate this information with a Meta account under its own privacy policy. Our Pixel does not send customer form values, payment details or TradingView usernames, and advanced matching is disabled.

Payment and billing data — handled entirely by the payment provider. Accounts and subscriptions are managed through our customer portal at account.sulamx.com. Payments are processed by our payment provider. We never see or store your full payment card details. Our payment provider's handling of payment data is described in its own privacy policy. From our payment provider we may receive limited transaction information (such as your email address, subscription status, and order reference) so that we can grant and manage your access.

We do not intentionally collect special categories of personal data or send such data to Meta. Meta processes consented event data under its own policies.

3. How We Use Data

We use the data described above only for the following purposes:

1. Providing access to SulamX Pro — using your TradingView username to grant, manage, and, where applicable, revoke invite-only access after purchase or cancellation.

2. Customer support — responding to contact form submissions and email inquiries.

3. Billing and subscription management — coordinating with our payment provider and our portal platform provider, regarding purchases, renewals, cancellations, and refunds.

4. Operating and improving the Site — using aggregate hosting statistics and consented analytics to understand Site usage, and consented Meta page-visit events to measure content and advertising performance.

5. Legal obligations — complying with applicable laws, including accounting, tax, and record-keeping requirements, and responding to lawful requests from authorities.

We do not use your data for automated decision-making that produces legal or similarly significant effects, and we do not send marketing emails unless you have asked us to.

4. Legal Bases for Processing

Where the EU/UK General Data Protection Regulation (GDPR) or similar laws apply, we rely on the following legal bases:

• Performance of a contract — processing your TradingView username, email address, and transaction information to deliver the subscription you purchased and to provide support.

• Legitimate interests — operating and securing the Site, maintaining aggregate analytics, keeping records of correspondence, and preventing misuse of the Services. We balance these interests against your rights and freedoms.

• Consent — where you voluntarily submit information through the contact form or otherwise reach out to us. Optional analytics and Meta marketing measurement also rely on your cookie choices. You may withdraw these choices at any time through Cookie Settings; you can contact us about other consent-based processing.

• Legal obligation — retaining records where required by tax, accounting, or other applicable laws.

5. Sharing of Data

We share personal data only with the following recipients, and only to the extent necessary:

• Our payment provider — provides payment processing for subscription purchases. Our portal platform provider — hosts the customer portal used to manage accounts and subscriptions, and processes related account data.

• TradingView — we use your TradingView username within TradingView's invite-only scripts mechanism to grant you access to SulamX Pro. We share no other personal data with TradingView.

• Hosting and infrastructure providers — including Framer (Site hosting and built-in analytics) and our email service providers, which process data on our behalf to keep the Site and our communications running.

We do not sell customer lists. When you opt in, we share analytics data with Google and marketing event data with Meta as described above. You can refuse or withdraw optional measurement through Cookie Settings. We may disclose data where required by law, court order, or to protect our legal rights, and in the event of a corporate transaction (such as a merger or acquisition), in which case this policy will continue to apply to your data.

6. International Transfers

We and our service providers (including our payment provider, Framer, TradingView, Google and Meta) may process data in countries other than your own, including the United States and the European Economic Area (EEA). Where personal data is transferred from the EEA or UK to a country without an adequacy decision, we and our providers rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or equivalent mechanisms.

7. Data Retention

We keep personal data only as long as needed for the purposes described in this policy:

• Contact form submissions and email correspondence — retained for as long as needed to handle your inquiry and for a reasonable period afterward for reference and support continuity.

• TradingView username and subscription records — retained for the duration of your subscription and for a reasonable period afterward to handle access management, disputes, and re-subscriptions.

• Transaction records — retained as required by applicable tax and accounting laws.

• Aggregate analytics — anonymous by nature and not linked to identifiable individuals.

When data is no longer needed, we delete it or anonymize it.

8. Your Rights

Depending on where you live, you may have the following rights regarding your personal data:

• Access — request a copy of the personal data we hold about you.

• Rectification — request correction of inaccurate or incomplete data.

• Erasure — request deletion of your data, subject to legal retention requirements.

• Portability — request your data in a structured, commonly used, machine-readable format.

• Objection — object to processing based on our legitimate interests.

• Restriction — request that we limit processing in certain circumstances.

• Withdrawal of consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, email us at info@sulamx.com. We will respond within the timeframes required by applicable law. We may need to verify your identity before acting on a request.

You also have the right to lodge a complaint with a data protection supervisory authority — in the EU, the authority in your country of residence or workplace; in the UK, the Information Commissioner's Office (ICO).

For your payment data, the payment provider is the controller — you can also exercise your rights directly with our payment provider as described in the payment provider's privacy policy.

9. Cookies and Analytics

We keep this simple, because our setup is simple:

• The Site is hosted on Framer and uses Framer's built-in analytics, which are aggregate and anonymous. To our knowledge this does not involve advertising or cross-site tracking cookies.

• Meta Pixel loads only after marketing consent. It measures page visits using browser information and cookie identifiers such as _fbp and, when applicable, _fbc. We currently send PageView events; this installation does not measure completed purchases in the customer portal. Automatic event detection, advanced matching and Conversions API are not enabled. We do not add fingerprinting scripts.

• If you purchase a subscription, the payment provider's checkout may use cookies necessary to process your transaction securely. These are governed by the payment provider's own privacy policy and cookie disclosures.

Essential technical cookies or similar technologies may be used by our hosting provider to make the Site function. Use Cookie Settings to accept, reject or change analytics and marketing choices independently. Rejecting optional cookies does not prevent normal site use. Withdrawing marketing consent stops future Pixel events and attempts to remove our Meta cookies; it does not undo data already sent. Consent choices are remembered for up to 12 months, unless you clear them. You can also control cookies in your browser. For Meta processing and retention, see Meta Privacy Policy and Meta Cookies Policy.

10. Children

The Site and Services are not directed at anyone under 18 years of age, and we do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with personal data, contact us at info@sulamx.com and we will delete it.

11. Security

We take reasonable technical and organizational measures to protect personal data, including limiting the data we collect in the first place, restricting access to it, and relying on established providers (Framer, our payment provider, TradingView, and our email providers) that maintain their own security programs. No method of transmission or storage is completely secure, but minimizing what we collect is our first line of defense.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will post the revised version on this page and update the "Last updated" date at the top. If a change is material, we will take reasonable steps to bring it to your attention, such as a notice on the Site. Your continued use of the Site or Services after an update means the revised policy applies.

13. Contact

SULAMX LTD
Email: info@sulamx.com

For payment, billing, invoice, and refund matters, contact us via info@sulamx.com.