PRIVACY POLICY

1. Introduction

Conclave Capital ("we," "us," "our") is operated by Andonis Christodoulou as a sole trader. We are committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained therein. This Privacy Policy explains how we collect, use, store, disclose, and protect the personal information you provide when using our website at conclavecapital.io or purchasing our services. By using our website or purchasing our services, you consent to the collection and use of your personal information as described in this policy.

2. Information We Collect

We collect the following personal information when you use our services:

3. How We Collect Information

We collect personal information directly from you when you complete our onboarding form, make a purchase through our payment processor (Stripe), verify your Telegram identity via our bot, subscribe to our email list, or contact us via email. We may also collect limited technical information (such as IP address and browser type) automatically when you visit our website, for security and analytics purposes.

4. How We Use Your Information

We use your personal information to:

• —Deliver and manage your access to our services, including granting TradingView algorithm access and Telegram channel invitations
• —Communicate with you about your membership, service updates, and support requests
• —Send automated lifecycle emails (welcome, onboarding reminders, cancellation confirmations, re-engagement, and upgrade information)
• —Process payments securely through Stripe
• —Manage and verify your Telegram channel access via our automated bot
• —Comply with our legal obligations under Australian law
• —Protect against fraud, unauthorised access, and misuse of our services
• —Improve our website and services

We will not use your personal information for any purpose other than those described above without your consent, unless required or authorised by law.

5. Email Communications

By purchasing a membership or subscribing to our email list, you consent to receiving transactional and service-related emails from Conclave Capital. These include:

• —Transactional emails — OTP codes, welcome emails, onboarding instructions, payment confirmations (cannot be opted out of while your membership is active)
• —Service emails — Telegram access instructions, TradingView access notifications, membership status updates
• —Lifecycle emails — cancellation confirmations, re-engagement offers, upgrade information

You may opt out of non-transactional emails at any time by clicking the unsubscribe link in any email or by contacting us at [email protected]. We comply with the Spam Act 2003 (Cth) in all email communications.

6. Disclosure of Information

We do not sell, rent, or trade your personal information to third parties. We may disclose your personal information to the following categories of third parties only to the extent necessary to deliver our services:

• —Stripe — for secure payment processing (governed by Stripe's own privacy policy)
• —TradingView — for the purpose of granting algorithm access to your account
• —Telegram — for channel access management via our automated bot
• —Google — for data storage via Google Sheets (member records management)
• —Resend — our email service provider for transactional and lifecycle communications

We may also disclose your information where required by law, court order, or regulatory authority, including ASIC, the ATO, or law enforcement agencies.

7. Overseas Disclosure

Some of our third-party service providers (including Stripe, TradingView, Telegram, and Resend) may store or process your data outside Australia. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the Australian Privacy Principles. By using our services, you consent to this overseas disclosure.

8. Data Security

We take reasonable technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. Payment information is processed entirely by Stripe and is never stored on our servers. Access to member data is restricted to authorised personnel only, protected by password authentication and session-based access controls. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security. If you become aware of any unauthorised access to your information, please contact us immediately.

9. Data Retention

We retain your personal information for as long as your membership is active and for a period of seven (7) years thereafter, as required for legal, tax, and business record-keeping purposes under Australian law. You may request deletion of your data at any time by contacting us (see Section 11). Note that deletion of your data will result in termination of your membership access, and we may retain certain information where required by law.

10. Your Rights Under the Australian Privacy Act

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• —Access the personal information we hold about you (APP 12)
• —Request correction of inaccurate, incomplete, or out-of-date information (APP 13)
• —Request deletion of your personal information, subject to legal retention obligations
• —Opt out of receiving marketing or promotional communications at any time
• —Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au if you believe we have breached the APPs

To exercise any of these rights, please contact us at the address in Section 11. We will respond to your request within 30 days.

11. Cookies and Tracking

Our website uses essential cookies to maintain your session and ensure the website functions correctly. We do not use third-party advertising or tracking cookies. We may use anonymised analytics data to understand how our website is used and to improve our services. By using our website, you consent to the use of essential cookies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Your continued use of our website or services after any changes constitutes your acceptance of the revised policy. We encourage you to review this policy periodically.

13. Contact and Complaints

For any privacy-related requests, questions, or complaints, please contact us at: [email protected]

If you are not satisfied with our response to a privacy complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.