1. Who is responsible for your data
North Sky Digital LLC (RefundHub247, we), 30 N Gould St, Ste N, Sheridan, WY 82801, USA, is the controller of the personal data processed through refundhub247.com and the Market247 app. Contact us about privacy at [email protected].
2. The data we collect
| Category | What it includes | Where it comes from |
|---|---|---|
| Account | Email, name, password (stored only as a one-way hash), country, time zone, notification settings, your referral code, who referred you, how you found us (e.g. the Market247 app) | You |
| Linked trading accounts | Platform name, UID or account number, verification status | You |
| Trading and cashback records | For your linked accounts: date, product, trading volume, fees and the cashback calculated | The trading platforms' partner reports |
| Payouts | TRC20 wallet address, amounts, status, transaction id | You and us |
| Communications | Contact form messages (name, email, message), reviews, in-app notifications | You |
| Usage data | Pages visited, links clicked (including referral links), referring website and campaign tags, device type, browser, operating system, language, approximate location (country, region, city) | Your browser and our hosting provider |
| App data | A random session id, screens viewed and actions, app version and operating system | The Market247 app |
We never ask for your platform password, API keys, seed phrase or private keys. Approximate location is derived by our network provider (Cloudflare) from your IP address; our analytics do not store the IP address itself. IP addresses may appear briefly in security and server logs.
3. How we use it and why
| Purpose | Legal basis |
|---|---|
| Create and secure your account, verify your email, reset your password | Performing our contract with you |
| Verify linked accounts, calculate and credit cashback and referral commissions, process payouts | Performing our contract with you |
| Send account, cashback and payout notifications | Performing our contract; optional emails only as set in your notification settings |
| Prevent fraud, multiple accounts and abuse; enforce country restrictions | Our legitimate interests and legal obligations |
| Measure traffic and which pages and campaigns work, to improve the Service | Our legitimate interests, or your consent where the law requires it |
| Answer your messages and moderate reviews | Our legitimate interests |
| Keep records required for accounting, tax, sanctions and anti-money-laundering rules | Legal obligation |
We do not use your data for automated decisions that have legal or similarly significant effects on you, and we do not sell or rent personal data.
6. International transfers
RefundHub247 is operated from the United States and our providers may process data in other countries. Where data leaves your country we rely on the safeguards the applicable law provides, such as standard contractual clauses, and on the protections described in this policy.
7. How long we keep it
- Account, linked accounts, cashback and payout records: while your account is open.
- When you delete your account in Settings, we immediately delete your profile, linked accounts, cashback and payout history, notifications and reviews. Traffic statistics are kept only in a form no longer linked to you. Backups are overwritten within 30 days.
- Contact form messages: up to 24 months after the conversation ends.
- Records we must keep by law (for example for tax or anti-money-laundering purposes) are kept for the period the law requires, even after account deletion.
8. How we protect it
Passwords are stored only as salted one-way hashes; sign-in, email verification and password reset tokens are stored hashed; all traffic is encrypted with HTTPS; staff access is limited to what is needed. No system is perfectly secure. If a breach affects your data, we will notify you and the authorities where the law requires.
9. Your rights
Depending on where you live (including under the EU and UK GDPR, Vietnam's Personal Data Protection Law and US state privacy laws), you may have the right to:
- access the personal data we hold about you and receive a copy;
- correct inaccurate data (you can edit most of it in Settings);
- delete your data (you can delete your account in Settings);
- restrict or object to certain processing, including our traffic statistics;
- receive your data in a portable format;
- withdraw consent at any time, where processing is based on consent;
- complain to your data protection authority.
Send requests to [email protected] from the email address of your account. We answer within 30 days and may ask you to confirm your identity. We do not charge for reasonable requests.
10. Children
The Service is only for adults (18+). We do not knowingly collect data from children. If you believe a child has given us data, contact us and we will delete it.
11. Changes to this policy
We will post any update here with a new “Last updated” date and notify you of material changes by email or in your dashboard.
12. Contact
North Sky Digital LLC, 30 N Gould St, Ste N, Sheridan, WY 82801, USA. Email: [email protected].
Questions about this document? Email [email protected].