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Humphrey – Privacy Policy

1. Introduction


Humphrey (“Company”, “we”, “our” or “us”) is committed to protecting the privacy of anyone who accesses, uses, or registers to our Services (defined below). We have published this Privacy Policy (“Policy”) to outline our practices with respect to collecting, using, and disclosing your information when you use our Services. We encourage you to read this Policy carefully and use it to make informed decisions.

 

Our Services may be connected by “hyperlinks” to other third-party sites. We are not responsible in any way for the privacy practices on other third-party sites and advise you to review the privacy policies on those linked sites before using them.

 

2. Our Services


To give you a better sense of how and from whom we collect data, it is useful to start with a brief overview of our Services. The Company provides a proprietary software service that allows its end users to create and configure automated trading strategies for execution on third-party online cryptocurrency exchanges by creating their own trading models or following signals from various third-party sources through channels integrated or created within the Company’s platform (collectively, “Services”).

 

By using the Company’s Services, you agree to the collection and use of your personal information as described in this Policy as well as to the Company’s Terms of Service. Any significant changes to this Policy will be posted on the Company’s website (“Website”).

 

This Policy applies to information we collect from any person using or interacting with our Services, as well as any person visiting our Website or our web interfaces (collectively, “Users”).

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3. What Types of Data We Collect?


We collect two types of data from you: Personal Data (“Personal Data”) and non-Personal Data.

  • Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name).

  • Non-Personal Data is any information that does not relate to an identified or identifiable natural person. This may include, for example, aggregated usage information and technical information transmitted by your device (such as device type, browser and operating system, language preference, access times, etc.).

 

This section sets out how and when we collect those types of data from you.

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Contact Information. When you access our Services, we collect your username, first name, surname, country, Discord account (including Discord ID and username), and any contact information you make public.

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Transaction Information. Payments you make using our Services will typically be processed by the payment processor (e.g., Stripe, PayPal), and we will not collect or store your financial data (e.g., credit card numbers). We may still receive non-financial Personal Data related to your payment, such as your name, billing address, email address, and items purchased, to fulfill your order and for accounting purposes.

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Exchange Information. When you continue with our onboarding process, you may provide us with your API keys and API secrets. We may also collect additional details regarding your exchange and crypto investments, such as portfolio size, asset allocation, and availability.

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Usage Information. When you use our Services, we collect certain data about your interaction. This may include geolocation data, clicks, pages viewed, channel memberships, and other usage data.

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Technical Information. We collect technical information about your device, which may include geolocation data, IP address, unique identifiers (e.g., MAC address, UUID), operating system, language, and other similar details.

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Communication Information. When you contact us, we collect any Personal Data you provide, including your name, email address, and the content of your communication.

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4. Tracking Technologies


When you visit or access our Services (for example, our Website), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags, and other technologies (“Tracking Technologies”).

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Tracking Technologies help us automatically collect information about you and your device for purposes including improving navigation, enhancing performance, customizing your experience, collecting statistics, performing analytics, and delivering content and advertising tailored to your interests.

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Categories of Tracking Technologies we use:

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  • Strictly Necessary Technologies: Essential for navigating and using key features.

  • Functionality Technologies: Remember your choices and provide personalized features.

  • Performance Technologies: Collect information about your usage for analytics and statistics.

  • Advertising Technologies: Collect browsing habits to deliver relevant advertising.

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How and by whom Tracking Technologies are stored:
Tracking Technologies may be placed on your device by us (“First Party Tracking Technologies”) or by third parties (“Third Party Tracking Technologies”).

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Managing Tracking Technologies:
You can control your preferences by adjusting browser settings or using “Do Not Track” signals. Note that disabling cookies may impact the functionality of our Services.

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For more information about managing cookies, you can visit your browser’s help section or learn more here:

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5. Why We Collect Your Personal Data

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Purpose and legal basis

 

  • Consumer services (responding to inquiries) - Contract performance; consent; legal obligations; legitimate interests (improving Services)

  • Provide our Services (registration, onboarding) - Contract performance; legitimate interests

  • Improve our Services (usage analysis, development) - Contract performance; legitimate interests

  • Marketing and Advertising (personalized content, promotions) - Consent (where required); legitimate interests

  • Compliance with laws - Legal obligations

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6. Marketing


The Company may use your Personal Data, independently or through third-party partners, to provide you with promotional materials relating to our Services and those of affiliates or partners we believe may interest you.

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You can decline marketing offers at any time by contacting us at info@humphreybot.com. Even if you unsubscribe, you may continue receiving service-related notices.

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7. With Whom We Share Your Data


We may share your Personal Data with:

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  • Service Providers: For analytics, hosting, and operational support.

  • Advertising Partners: To deliver relevant marketing.

  • Legal Authorities: To comply with legal obligations or protect rights and safety.

  • Business Transactions: In the event of a merger, acquisition, or similar process.

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8. Data Protection Rights

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If you are in the EU or other jurisdictions with similar rights, you may:

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  • Request access to your data

  • Request correction or deletion

  • Object to or restrict processing

  • Request data portability

  • Lodge a complaint with a supervisory authority

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These rights may be subject to our legitimate interests and legal obligations.

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9. Transfer of Data Outside the EU


Your data may be stored and processed in jurisdictions outside your country. We will ensure appropriate safeguards to protect your data in accordance with applicable law.

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10. How We Protect Your Data


We use administrative, technical, and physical safeguards to protect your Personal Data. While we strive to protect your information, no system is completely secure, and you share information at your own risk.

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11. Retention


We retain your data as long as needed to provide Services and meet legal obligations. Retention periods depend on the type of data and the purpose of collection.

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12. Minors


We do not knowingly collect data from individuals under the legal age of consent. If we become aware that we have collected such data without verified consent, we will delete it promptly.

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13. Updates to This Policy


We reserve the right to update this Policy. The most current version will be posted on our Website. Continued use of the Services constitutes acceptance of the updated Policy.

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14. Contact Us
 

If you have questions, please contact us at:


📧 info@humphreybot.com

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Last Updated: 10-07-2025

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