นโยบายความเป็นส่วนตัว

1. Who processes your data

The owner and operator of your personal data is Star Light Inovation,ltd, a company incorporated in the Republic of Uzbekistan, which operates トクバク (the “Site”).

Operator

Star Light Inovation,ltd

Registered address

Махтумкули 1А, 100047, Тоshkent, Toshkent

Contact for data questions

support@tokubaku.com, or the contact form on the Site

This Policy is written to meet the Law of the Republic of Uzbekistan “On Personal Data” (No. ZRU-547 of 2 July 2019, as amended). It explains what we collect, why, who else sees it, how long we keep it, and what you can require us to do.

2. What we collect

• Registration data — your email address, your name as you enter it, your password in hashed form, and the language you choose.
• Trading account data — the broker, account number and account type you register, and the trading volume and commission that the broker reports for that account.
• Identity documents — a copy of an identity document and, where required, proof of address, together with the result of our review.
• Payment data — your USDT (TRC20) receiving address, the amounts you request, and the transaction identifier of each payment.
• Correspondence — your enquiries and our replies.
• TradingView username — if you apply for a trading tool that we distribute through TradingView, the username you give us, and the record of when access to that tool was granted and when it ended.
• Technical data — IP address, browser and device information, and the times of sign-in and of actions in your member account, kept for security.

We do not ask for, and you should not send us, information about your health, religion, political views, ethnic origin or trade-union membership. We do not process genetic data. We do not perform biometric identification: we do not create a face template from your photograph and we do not match photographs automatically. A document that contains your photograph is reviewed by a person.

3. Why we process it, and on what basis

• To provide the service you asked for — to create and operate your member account, to attribute your trading account to us with the broker, to calculate cashback, and to pay it. Basis: your consent, and performance of the agreement between us (the Terms of Use).
• To verify your identity before a payment, and to prevent impersonation, multiple accounts and fraud. Basis: your consent, performance of the agreement, and our compliance with law.
• To answer your enquiries. Basis: your consent.
• To give you access to a trading tool you applied for, and to check that you still meet the published conditions for it. Basis: your consent, given when you apply, and performance of the agreement between us.
• To keep the Site secure and to investigate abuse. Basis: performance of the agreement and our compliance with law.
• To meet obligations under the law of the Republic of Uzbekistan, including accounting and tax records, and to respond to a lawful request from a State body. Basis: compliance with law.

We do not sell your personal data, and we do not use it for advertising profiling.

4. Your consent, and withdrawing it

You give consent when you register and when you submit information to us. You may withdraw consent at any time by writing to the contact address above.

Some data is necessary for the service to exist. Your email address, the trading account numbers, the result of identity verification and your receiving address cannot be removed while we are operating your member account, because without them we cannot attribute trading to you or pay you. Withdrawing consent to those therefore means closing the member account. We will tell you what that means for any balance you hold before we act on it.

5. Where your data is stored, and cross-border processing

Our application and database run on a virtual server rented from Vultr Holdings, LLC, physically located in Singapore. Backups are held in the same environment. Our outgoing email is sent through the provider named in clause 6.

This means that personal data collected through the Site is processed outside the Republic of Uzbekistan. We rely on Article 27¹ of the Law “On Personal Data”, which permits storage and processing abroad where information-security requirements are met, the level of protection is comparable to the requirements of the Republic of Uzbekistan, and State oversight is not impaired. We do not process biometric, genetic or telecommunications-subscriber data, which must remain within the Republic of Uzbekistan.

If you are a citizen of the Republic of Uzbekistan, please contact us before registering, so that we can confirm how your data would be handled.

6. Who else sees your data

• Brokers. To attribute your trading account to us and to obtain the commission report, we identify the account number to the broker concerned. Each broker processes data under its own privacy policy.
• Hosting. Vultr Holdings, LLC, as the operator of the server described in clause 5.
• Email delivery. An external email delivery service delivers our verification and notification messages, and therefore processes your email address and the content of those messages.
• The TRON blockchain. When we pay you, the receiving address, the amount and the time become part of a public ledger that anyone can read and that cannot be erased. This is inherent to payment in USDT and you should consider it before giving us an address that is linked to your identity elsewhere.
• TradingView, Inc. The economic calendar page and the market board page load widgets served by TradingView. Opening those pages sends your IP address, browser information and the page address (and, on the market board, the symbols of the charts shown) to TradingView, which handles it under its own privacy policy (https://www.tradingview.com/privacy-policy/). The widgets are loaded on those pages only. Separately, if you apply for a trading tool that we distribute through TradingView, we add the TradingView username you give us to the access list of that script, which discloses that username to TradingView. We do this only when you apply, and we remove it when your access ends.
• State bodies and courts, where we are required to disclose by a lawful request.
• A successor of our business, if it is transferred, on notice to you.

We do not otherwise disclose your personal data to third parties without your consent.

7. What we publish

We may publish on the Site the date and the amount of completed payments, in order to show that the service pays. We do not publish names, email addresses, trading account numbers, receiving addresses or transaction identifiers, and we do not publish this at all while the number of payments is small enough for an individual to be inferred.

8. How long we keep it

• Member account data: while the account exists, and for 12 months after closure, so that a later question about a payment can be answered.
• Identity documents: for 5 years after the last payment, which is the period we may need to evidence that a payment was properly made.
• Cashback, commission and payment records: for the period required by the accounting and tax law of the Republic of Uzbekistan.
• Security logs: 12 months.
• Enquiries: 24 months.

When a period ends we delete the data or anonymise it so that it can no longer be attributed to you.

9. Your rights

Under the Law “On Personal Data” you may require us to:

• tell you whether we hold personal data about you, and give you access to it;
• correct data that is inaccurate or incomplete;
• block processing, or delete data, where it is processed unlawfully, is inaccurate, or is no longer needed for the purpose it was collected for;
• stop processing based on your consent, by withdrawing that consent; and
• explain the legal grounds and purposes of the processing, and who has received the data.

Write to the contact address above. We answer within 30 calendar days. We may ask you to confirm your identity first, so that we do not disclose your data to someone else. Where we cannot meet a request in full — for example because we must keep a record by law — we will tell you why.

10. Security

The Site is served only over HTTPS. Passwords are stored hashed and cannot be read by us. Identity documents are stored outside the public web directory and are accessible only to the operator. Administrative access requires two-factor authentication, and the administration area sits behind an additional authentication layer. Access to the member area and to administration is logged. We check the integrity of the deployed application and are alerted to unexpected changes.

No measure is perfect. If a breach occurs that is likely to affect your rights, we will inform you and the authorised State body without undue delay.

11. Children

The Service is not for persons under 18. We do not knowingly process their data, and we delete it if we learn that we have.

12. Changes to this Policy

We may amend this Policy. The amended version is published on the Site with a new effective date, and where the change is material we notify registered members by email at least 14 days before it takes effect.

13. Complaints

Please raise any concern with us first, at the contact address above. If you are not satisfied, you may complain to the authorised State body of the Republic of Uzbekistan responsible for the protection of personal data, or bring the matter before a court.

14. Governing language

This English version is the authoritative version of this Policy. Translations are provided for convenience only, and this English version prevails if they differ. Where a translation into the Uzbek or Russian language is required for a court or an authority of the Republic of Uzbekistan, a certified translation of this English version shall be used.