Privacy Policy

The data controller is ELIBRI LTD., registration no. 2026-00305, of c/o ADCO Incorporated, #10 Manoel Street, Castries, Saint Lucia. This Policy applies to https://elibrimarkets.com, the Platform, accounts, AI Bots, support, payments, and Developer programmes.

This Policy explains the personal data we process, its sources, purposes, recipients, retention, and available rights. A Bot or integration may provide an additional notice that applies with this Policy.

• users and Developers directly;
• devices, browsers, cookies, logs, and Platform activity;
• UniPayment, banks, card networks, and compliance providers;
• AI, cloud, analytics, messaging, and data providers;
• public blockchain, social, news, and market sources; and
• organisations, corporate-account administrators, partners, and complainants.

A public blockchain address may be personal data if linked, or reasonably linkable, to a person. We do not request and should not receive private keys or seed phrases.

Where applicable law uses different legal bases, we apply the relevant basis. If required data is not provided, an account, payment, payout, or function may be unavailable.

To produce a Bot response, the Platform may send the Input, system instructions, and necessary context to the applicable AI provider, including OpenAI, DeepSeek, or another provider identified in the interface. A provider may process data in another country under its contract with ELIBRI and its mandatory rules.

• Do not submit private keys, seed phrases, payment secrets, passwords, or data not intended for the selected Bot.
• Do not submit another person's personal, confidential, medical, biometric, or brokerage data without rights and required notice.
• Outputs and safety classifications may be retained for history, security, investigation, and improvement within stated settings and retention periods.
• Any provider use of data for model improvement depends on the applicable service configuration and terms and will be disclosed where required by law.

ELIBRI may restrict an AI provider by territory or data category following privacy, transfer, retention, and contractual assessment.

Payment is processed by the applicable UniPayment group company or another provider identified at checkout. The provider receives data needed for payment, fraud screening, KYC/AML, refunds, and disputes and may act as an independent controller for its legal duties.

ELIBRI generally receives a payment identifier, amount, currency, status, masked method, country, risk result, and refund information. Full card numbers and CVV codes are entered in the provider's secure interface and are not stored by ELIBRI.

If digital-currency payment or payout is available, an independent licensed or registered provider performs the transaction and applicable checks. ELIBRI does not receive private keys or provide a wallet, exchange, transfer, or custody service.

An Author normally receives aggregated usage and revenue data. Access to identifiable Inputs or account data is allowed only where necessary for a stated function, support, or investigation and disclosed to the user.

An Author must not use data for independent lists, advertising, profiling, model training, or contact outside the Platform. ELIBRI imposes confidentiality and data-protection obligations or technically restricts access.

• AI providers required for the selected Bot;
• UniPayment and applicable banks, networks, fraud, KYC, and AML providers;
• cloud hosting, storage, security, monitoring, email, Telegram, and support providers;
• market, news, social, and blockchain data providers;
• Bot Authors to the minimum extent necessary;
• auditors, accountants, insurers, and professional advisers;
• courts, regulators, law enforcement, and other recipients required by law; and
• a business purchaser or successor under confidentiality and lawful process.

We do not sell personal data in the ordinary sense. If applicable law defines sale or sharing more broadly and an advertising technology falls within that definition, we will provide the required opt-out.

ELIBRI is incorporated in Saint Lucia, while providers and users are located in different countries. Personal data may be transferred outside the user's country and Saint Lucia.

We use available contractual and organisational safeguards, including data-processing agreements, confidentiality and security terms, approved transfer terms, standard contractual clauses, or another recognised mechanism. Where Saint Lucia law requires Data Protection Commissioner authorisation or another transfer condition, ELIBRI will follow that process.

You may request general information about the applicable transfer mechanism. Information may be limited for trade-secret and security reasons.

A period may be shorter or longer depending on data sensitivity, purpose, risk, backups, legal hold, fraud, abuse, and mandatory law. On expiry, data is deleted, anonymised, or isolated until scheduled backup deletion.

We use proportionate technical and organisational measures, including access controls, MFA for privileged accounts, encryption in transit, secrets management, logging, backup, vulnerability management, vendor review, and incident response.

No system is completely secure. Use a unique password, protect email and Telegram accounts, do not disclose secrets, and report suspected compromise.

Bots automatically analyse Inputs, public sources, and market data and may generate scores, ratings, labels, confidence measures, risk scenarios, and alerts. These Outputs do not make a legally binding decision about a user and must not automatically execute a trading or investment transaction.

If ELIBRI introduces automated decision-making with legal or similarly significant effects, it will provide any required notice, legal basis, logic information, and human review.

Depending on applicable law, you may request:

• confirmation of processing and access to personal data;
• correction of incomplete, inaccurate, excessive, or misleading data;
• deletion, blocking, restriction, or objection;
• portability of data you provided;
• withdrawal of consent without affecting earlier lawful processing;
• opt-out from direct marketing, targeted advertising, or sale/sharing where applicable;
• human review of an applicable automated decision; and
• a complaint to the Saint Lucia Data Protection Commissioner or local authority.

Send requests to partners@elibrimarkets.com with the subject "Privacy Request". We may verify identity and authority. A request may be refused or limited only on a legal ground. Ordinary requests are free; manifestly unfounded or excessive requests are handled under applicable law.

We send marketing only on a lawful basis. You may opt out through the unsubscribe link, settings, or support. Account, payment, security, and contract notices may be sent regardless of marketing preferences.

Authors may not export user contacts for their own marketing without a separate lawful basis and transparent notice.

We use cookies, local storage, SDKs, pixels, and similar technologies for sessions, security, preferences, analytics, and, with required consent, marketing. Details and controls appear in the Cookie Policy and Cookie Settings.

The Platform is intended for persons aged 18 or older. We do not knowingly collect personal data from minors. We will delete such data and close the account after reasonable notice.

The Platform is not offered to Saint Lucia residents or persons accessing it from Saint Lucia. As a Saint Lucia company, ELIBRI remains subject to applicable local data-protection law.

If ELIBRI targets users in the EEA, United Kingdom, California, or another territory with additional requirements, the applicable mandatory rights and restrictions apply. ELIBRI may publish a regional addendum and appoint a representative, DPO, or other contact where required.

We may update this Policy for product, provider, or legal changes. Material changes will receive prominent notice and renewed consent where required.

Privacy questions, rights requests, and complaints: partners@elibrimarkets.com, subject "Privacy Request". Postal address: c/o ADCO Incorporated, #10 Manoel Street, Castries, Saint Lucia.