# Privacy Policy

_Last updated: July 2026_

This policy explains what personal data BTCMatic (operated by SMARTCHIP Ltd, the data controller) processes, why, and what rights you have. We collect the minimum the service needs — there are no ads, no tracking pixels, and we never sell data.

## 1. What we store

| Data | Purpose | Legal basis |
|---|---|---|
| Email address (optional with Nostr sign-in) | Account identity, magic-link sign-in, service notifications | Contract |
| Nostr public key (only if you sign in with Nostr) | Account identity — we never see or store your private key | Contract |
| Your rules, watched addresses, fire/order history and evaluation traces | Providing the automation service; showing you why rules did or did not fire | Contract |
| Exchange API keys (trade-only) | Placing orders on your exchange account. Stored with per-account envelope encryption (AES-256-GCM, keys wrapped by a hardware KMS); decrypted only in the isolated order executor, never logged | Contract |
| Notification channels (Telegram chat id, email, webhook URLs and signing secrets) | Delivering the notifications you configure; webhook secrets encrypted at rest | Contract |
| Subscription and payment status | Billing. Card details go directly to Stripe — we never see or store them | Contract |
| Audit log (fires, orders, key validations, account actions) and server logs | Security, abuse prevention, support and dispute resolution | Legitimate interest |

Bitcoin addresses you watch are public blockchain data; we treat your _association_ with them as personal data and protect it accordingly.

## 2. Processors and recipients

We share data only with the processors needed to run the service:

| Processor | Role | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting (all application data) | Germany (EU) |
| Cloudflare, Inc. | DNS, TLS proxy, DDoS protection (traffic metadata) | EU/US (SCCs) |
| Stripe, Inc. | Payment processing (email, payment details) | EU/US (SCCs) |
| Telegram | Message delivery, only if you connect a Telegram channel | Per Telegram's policy |
| Transactional email (SMTP) provider | Magic-link and notification email delivery | EU region selected |

Amazon Web Services provides the key-management service (KMS) that wraps our encryption keys; your raw exchange keys are never sent to AWS. We disclose data to authorities only when legally required.

## 3. Retention

- Account data: for the life of the account, deleted or anonymised within 30 days of closure.
- Exchange API keys: deleted immediately when you remove them or close the account.
- Audit log: up to 24 months (security and dispute resolution).
- Backups: encrypted, rotated out within 30 days.
- Invoicing records: as long as tax law requires.

## 4. Your rights (GDPR)

You can request access, rectification, erasure, restriction, portability, and object to legitimate-interest processing, by emailing `privacy@btcmatic.com`. We respond within 30 days. You may also lodge a complaint with your local supervisory authority. Sign-in uses magic links or a Nostr signature — we store no passwords, and an email address is optional when you sign in with Nostr. Cookies: a session token only, strictly necessary, no third-party or advertising cookies.

## 5. Security

Security posture is summarised on the Security page (https://btcmatic.com/security): non-custodial design, trade-only keys with exchange-side IP allow-listing, envelope encryption at rest, isolated order execution, and immutable audit trails. If a breach affecting your data occurs, we will notify you and the supervisory authority as GDPR requires.

## 6. Changes and contact

We will announce material changes to this policy by email or in-app before they take effect. Controller: SMARTCHIP Ltd. Contact: `privacy@btcmatic.com`.

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Canonical page: https://btcmatic.com/legal/privacy  
Machine index: https://btcmatic.com/llms.txt · Agent notes: https://btcmatic.com/agents.md