Kestrel — privacy
The formal version of “what is known about you”. The plain-English version is on the terms page, and the two say the same thing.
Who is responsible
Kestrel is run by one individual operator, who is the data controller. There is no company behind it yet, and saying otherwise would be the first false statement in a document about honesty. Reach the controller at support@kestreltrade.app, or at @mnihadmm on Telegram. Both reach a real person, and are the fastest route to any request below.
If and when Kestrel is incorporated, this section changes and the change is noted at the bottom of the page. Nothing else here depends on it.
What is collected, why it is allowed, and how long it stays
| What | Why | Lawful basis | Kept for |
|---|---|---|---|
| Telegram id, first name, username | To have an account at all — the app has no password because Telegram is the identity | Contract | Until you erase the account |
| Watchlist, brief time, settings | To do the thing you asked for | Contract | Until you erase the account |
| What you paid for, and the charge id | To give you what you bought, and to refund it | Contract, then legal obligation | Kept after erasure, as an accounting record with no name on it |
| Predictions, receipts, alerts, strategies, backtests, paper positions | They are the things you made here | Contract | Until you erase them |
| Which buttons you pressed and when | To count whether the app works — never to profile you, and never sold | Legitimate interest | Four months |
| Which days you opened the app | Retention measurement | Legitimate interest | Until you erase the account |
| Messages you send the assistant, and voice notes you send it | To answer them | Contract | Answers cached 6 hours; generated audio 14 days; the model provider is contractually barred from training on them |
| That the bot met you, before you have an account | So the operator can see somebody arrived | Legitimate interest | Erased with the account, or after one year of silence if you never open one |
| How many times a shared link was opened | To know if sharing works | Legitimate interest | Attached to the link, not to a person. No identifier is set and nothing about the opener is recorded |
| A wallet address you connect | To show you which wallet it is | Contract | Until you disconnect it. It authorises nothing and cannot move funds |
There is no advertising identifier, no third-party analytics script, no tracking pixel and no cookie used to follow you. Nothing is sold.
Who else sees it
Four processors receive personal data, and they are the only four:
- Telegram — the platform the app runs inside; it is your identity provider and the payment rail.
- The model gateway and the model provider behind it — messages you send the assistant, so it can answer.
- The speech vendor — only the text of an answer you asked to hear aloud.
- The hosting provider (Hetzner, Germany) — the machine everything runs on.
Market data comes from many more sources — the exchanges, the chain-data and derivatives providers, the search vendor. None of them is told who is asking. They receive a symbol, a timeframe or a query and nothing that identifies you, which is why they are data sources rather than sub-processors.
Where it goes
The server is in Germany, inside the EEA. Some processors above are outside it. Where that is the case the transfer relies on the European Commission's Standard Contractual Clauses, or on an adequacy decision where one covers the country in question.
Your rights, and the button that exercises most of them
You can see, correct, export, restrict, object to and erase what is held about you, and you can withdraw consent where consent is what allowed it. Two of those need no request at all: everything about you is visible in the app, and erasure is a button inside the app that works immediately and without asking anybody. Use it rather than emailing about it. For anything else, ask at support@kestreltrade.app.
Two things survive erasure and both for the same reason — they were never only yours. A call you published to the public board keeps its score with your name removed, because a leaderboard whose losses can be deleted records nothing. And a receipt you chose to anchor is on a public blockchain, which nobody can take back, including the operator.
You may complain to your national data protection authority. If you think something here is wrong, saying so to support@kestreltrade.app will get it fixed faster.
Children
This is not for anyone under 18 and is not directed at children.
Automated decisions
Nothing here makes an automated decision with a legal or similarly significant effect about you. The app scores predictions and ranks markets; it does not score people.
Changes
This page is generated from the same source as the terms page, so the two cannot drift apart. When it changes materially, the app says so rather than relying on you to re-read it.