PRIVACY POLICY

TRUDO TECHNOLOGIES LTD · LAST UPDATED: JULY 10, 2026

Legal documents are provided in English; the English version governs.

1. CONTROLLER

TRUDO TECHNOLOGIES LTD ("TRUDO", "we") is the data controller for personal data processed in connection with The Confluence Show. Registered office: Victoria House, Victoria, Mahé, Republic of Seychelles. Contact: privacy@theconfluence.show.

2. DATA WE COLLECT

Account data, name or handle, email address, password hash, language and preferences. Billing data, subscription selections (exchange, assets, billing cycle), invoices and payment status; full card details are collected and stored by our payment processor (e.g. Stripe), not by us. Usage data, pages viewed, features used, stream watch time, device and browser type, IP address, approximate location, cookie identifiers. Content data, chat messages, questions submitted to the Q&A, and votes. Communications, support requests and emails.

3. HOW WE USE DATA & LEGAL BASES

To provide the Service (account, streaming, membership management, Q&A), performance of a contract. To process payments and prevent fraud, performance of a contract and legitimate interests. To operate, secure and improve the Service, including aggregate analytics, legitimate interests. To send service communications, legitimate interests / contract; marketing communications only with your consent, which you can withdraw at any time. To comply with legal obligations (tax, accounting, lawful requests), legal obligation.

4. AI PROCESSING & CHAT

Questions and chat messages you submit may be processed by our AI systems to rank, moderate, answer and display them, including reading them out or showing them on the public stream. Do not include personal or sensitive information in chat or questions. Automated processing of chat does not produce legal or similarly significant effects about you.

5. COOKIES & SIMILAR TECHNOLOGIES

Essential cookies keep you signed in, remember your preferences (language, theme) and deliver the stream, these are always on. Optional analytics cookies help us understand usage and improve the Service; they are set only if you choose "Accept all" in the cookie banner. You can change your choice at any time by clearing cookies for this site; browser settings can also block cookies (some features may stop working).

6. SHARING

We share personal data with processors acting on our instructions: payment processing (e.g. Stripe), cloud hosting and content delivery, email delivery, analytics, and customer support tooling. We share data with authorities where required by law, and in connection with a merger, acquisition or asset sale (with safeguards). We do not sell personal data.

The free tier runs on third-party platforms (YouTube, Twitch, Kick); when you watch or chat there, those platforms are independent controllers under their own privacy policies.

7. INTERNATIONAL TRANSFERS

Where personal data is transferred outside the UK/EEA, we use appropriate safeguards such as adequacy decisions, the EU Standard Contractual Clauses and the UK International Data Transfer Addendum.

8. RETENTION

Account and billing records are kept for the life of the account and thereafter as required for legal, tax and accounting purposes (typically up to 6 years). Chat and Q&A content is retained for the operation of the Service and moderation, then deleted or anonymised. Analytics data is retained in aggregate form.

9. YOUR RIGHTS

Depending on your location, you may have rights to access, rectify, erase, restrict or object to processing, data portability, and to withdraw consent at any time (without affecting prior processing). EU/UK residents may lodge a complaint with their supervisory authority (in the UK, the ICO). California residents have rights under the CCPA/CPRA, including to know, delete, correct, and opt out of "sale"/"sharing" (we do not sell personal data). To exercise rights, contact privacy@theconfluence.show; we may need to verify your identity.

10. SECURITY

We apply technical and organisational measures appropriate to the risk: encryption in transit, access controls, least-privilege infrastructure, logging and monitoring. No system is perfectly secure; notify us immediately of any suspected compromise of your account.

11. CHILDREN

The Service is not directed to persons under 18, and we do not knowingly collect data from them. If you believe a minor has provided us data, contact us and we will delete it.

12. PROCESSORS & SUB-PROCESSORS

We use vetted service providers acting under data-processing agreements: payment processing (Stripe), cloud hosting and content delivery, email and notification delivery, product analytics, error monitoring, and customer-support tooling. Processors act only on our documented instructions, are bound by confidentiality, and are assessed for appropriate technical and organisational safeguards. A current list of sub-processors is available on request at privacy@theconfluence.show.

13. MARKETING PREFERENCES

Service communications (receipts, renewal notices, security notices, material-change notices) are part of the contract and cannot be opted out of while you hold an account. Marketing communications are sent only with your consent, or, where permitted, on a soft opt-in basis for similar services, and every message includes a one-click unsubscribe. We do not share personal data with third parties for their own marketing purposes.

14. AUTOMATED PROCESSING & PROFILING

We use automated systems to rank and moderate chat and Q&A, to detect fraud and abuse, and to produce aggregate usage analytics. These processes do not produce legal or similarly significant effects concerning you without human involvement. You may contest a moderation or fraud decision, and request human review, via privacy@theconfluence.show.

15. SECURITY INCIDENTS

Where a personal-data breach is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority without undue delay (and within 72 hours where the UK/EU GDPR requires) and will inform affected users without undue delay where the risk is high. Incident reports can be sent to privacy@theconfluence.show.

16. DO-NOT-TRACK & GLOBAL PRIVACY CONTROL

We honour the Global Privacy Control (GPC) signal where legally required, treating it as an opt-out of optional analytics cookies. Because there is no common industry standard for legacy Do-Not-Track browser signals, we do not respond to DNT headers.

17. CONTACT, DPO & COMPLAINTS

Privacy questions and data-subject requests: privacy@theconfluence.show. We aim to respond within 30 days (extendable where requests are complex, with notice). If you are unsatisfied with our response, you may lodge a complaint with your supervisory authority, in the UK, the Information Commissioner's Office (ico.org.uk); in the EU, the data-protection authority of your member state; elsewhere, your local privacy regulator.

18. TELEPHONE NUMBERS & TRIAL ANTI-ABUSE

To activate a free trial we process your mobile telephone number and email address for the sole purposes of (a) confirming that you control them, (b) enforcing the limit of one trial per person and household, and (c) detecting and preventing fraudulent or automated sign-ups. The lawful bases are performance of a contract (providing the trial you requested) and our legitimate interest in preventing abuse of a free offer.

Account creation, login and email/SMS verification are operated for us by Clerk, Inc. (a US-based authentication provider acting as our processor under a data-processing agreement with standard contractual clauses for international transfers); Clerk in turn uses a telecommunications carrier to deliver SMS codes. Clerk processes your email address, telephone number, authentication events and device/IP metadata solely on our documented instructions and may not use them for its own purposes. We store a one-way cryptographic hash of the telephone number for abuse-prevention purposes for 24 months after the trial ends, and the number itself only while your account remains open. We do not use trial telephone numbers for marketing, do not send promotional SMS, and do not sell, rent or share them with third parties for their own purposes. Standard carrier message rates may apply to messages you receive.

You may object to this processing, but because verification is a precondition of the free trial, we will then be unable to provide a trial. Paid memberships do not require a telephone number.

19. US STATE PRIVACY DISCLOSURES

For residents of California and other US states with comprehensive privacy laws: in the preceding 12 months we have collected the categories of personal information described in Section 2 (identifiers, commercial information, internet or network activity, and inferences), sourced directly from you and from your devices. We disclose these categories to service providers for the business purposes described in Section 3. We do not sell personal information, do not share it for cross-context behavioural advertising, and do not collect or use sensitive personal information other than account credentials. Personal information is retained as described in Section 8.

You have the rights to know/access, correct, delete, and port your personal information, and the right not to be discriminated against for exercising them. Submit requests to privacy@theconfluence.show; we verify requests against your account email. An authorised agent may submit a request on your behalf with your written permission. We respond within the timeframes required by applicable state law.

20. CHANGES

We may update this Privacy Policy; material changes will be notified in-product or by email. The "last updated" date above reflects the current version. Contact: privacy@theconfluence.show.