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How we handle your personal data.

Policy issued under Law No. 171 of 21 December 2018 of the Republic of San Marino, “Protection of natural persons with regard to the processing of personal data”, in force since 5 January 2019 and aligned with Regulation (EU) 2016/679.

Last updated: 25 July 2026 · Version 1.2

This English text is a courtesy translation. The Italian version at sinottica.ai/privacy.html is the only binding one: in case of any discrepancy, the Italian text prevails.

1. Data controller

Sinottica is a trade name, not a company. The data controller is Piero Martino, Via Oreste Brizi 1, 47891 Dogana, Republic of San Marino.

For any matter concerning personal data you can write to privacy@sinottica.ai. The contact details of the data protection officer, where appointed under article 38 of Law No. 171/2018, are published on this page and notified to the Autorità Garante (the San Marino data protection authority).

2. Data we process

CategoryData

Bulletin sign-upEmail address, your name if you choose to give it, the date and time of sign-up, proof of the consent given. After that: opens and clicks on the emails we send you.

Service registrationRegistration happens through Telegram: we receive your account identifier, your username and your display name. We do not create passwords and we do not store any.

SubscriptionPlan, billing details, payment history. Card data is handled directly by the payment provider: it never passes through our systems.

Site browsingIP address, browser and device type, pages visited. Some of this data is also technically visible to the providers that serve resources for the site: see point 5.

Use of the serviceReads opened, alerts received, technical access logs.

SupportThe content of the messages you send us and the data needed to reply to you.

We do not process special categories of data under article 8 of Law No. 171/2018 and we never ask you for data about your assets, your positions or your trading accounts.

3. Purposes and legal bases

PurposeLegal basis

Providing the service, managing accounts and subscriptionsPerformance of the contract

Sending the bulletin, the alerts on the reads and the welcome sequence that explains how to join the group and what the Free plan includesConsent, which you can withdraw at any time

Measuring email opens and clicks to understand whether the content is usefulConsent, given when you sign up

Keeping proof of consent to receive communicationsAccountability obligation, art. 24 of Law No. 171/2018

Replying to messages sent through the contact formResponding to your request: pre-contractual measures if it concerns the subscription, otherwise legitimate interest in replying to you

System security and prevention of abuseLegitimate interest of the controller

Aggregate statistics on use of the serviceLegitimate interest, on aggregated data

Accounting, invoicing and tax obligationsLegal obligation

Providing the data needed to perform the contract is mandatory: without it we cannot activate the account. Providing data so we can send you the bulletin is optional, and withdrawing consent does not affect the lawfulness of processing already carried out.

Writing to us through the contact form does not subscribe you to anything: we use your name, address and message only to reply, and we do not add them to the bulletin list.

4. How long we keep it

Account data: for the whole duration of the relationship and for 12 months after it closes, unless you ask us to erase it sooner.
Bulletin sign-up: until you unsubscribe, which you can do with one click at the bottom of every email. After you unsubscribe we keep for five years only the data we need to show that consent had been given — address, date, time and the text of the policy accepted — and nothing else.
Email open and click statistics: 24 months, then erasure.
Accounting and tax data: for the period required by San Marino law on the retention of accounting records.
Technical access logs: 12 months, then erasure or anonymisation.
Support messages: 24 months from the closure of the request.

5. Who we share the data with

Your data is accessible to authorised staff and to the providers that process data on our behalf, appointed as processors under article 29 of Law No. 171/2018 and bound by contract. As of today, these are:

ProviderWhat it does and what data it sees

Hostinger International LtdHosts the site and the domain email. It sees the server logs, the IP addresses of site visitors and the content of the emails you write to us.

Hostinger ReachThe bulletin sign-up form and the sending of the emails. It receives your address, your name if you give it, proof of consent and the open and click statistics. The form is protected by an anti-spam filter from Cloudflare, Inc.

BotSubscription (subhere.net)Manages registration, subscriptions and access to the groups. It sees your Telegram account data and the plan you chose.

Telegram FZ-LLCThe messaging platform the bulletin and the groups run on. Your relationship with Telegram is governed by Telegram's own privacy policy, which is outside our control.

Payment providerCollects paid subscriptions and stores the card data, which never passes through our systems.

unpkg (Cloudflare, Inc.) and Google FontsThey serve a technical library and the site's typefaces. They do not receive data you have given us, but your browser tells them its own IP address at the moment it downloads those files.

We also use an accountant for tax compliance. The list is up to date as of the date shown at the top of this page; you can ask us for an updated copy whenever you like.

We do not sell, rent or transfer your data to third parties for their own commercial purposes. We receive no payment from brokers, exchanges or intermediaries in return for sending communications. Data may be disclosed to public authorities where required by law.

6. Transfers outside San Marino territory

Some of the providers listed in point 5 are based, or have servers, outside San Marino territory: in the European Union (Hostinger), in the United States (Cloudflare, Google, the payment provider) and in the United Arab Emirates (Telegram). Transfers take place in compliance with articles 44 and following of Law No. 171/2018: to countries covered by an adequacy decision, or on the basis of standard contractual clauses and adequate safeguards, with supplementary measures where necessary. You can ask us for the updated list of providers and a copy of the safeguards adopted by writing to privacy@sinottica.ai.

7. Your rights

At any time you can exercise the rights granted by articles 15 and following of Law No. 171/2018:

access to the data concerning you and to information about the processing;
rectification of inaccurate data and completion of incomplete data;
erasure, in the cases provided for by law;
restriction of processing and objection to processing based on legitimate interest;
portability of the data you have given us, in a structured, machine-readable format;
withdrawal of consent, at any time and without formalities.

Write to privacy@sinottica.ai: we reply without undue delay and in any case within thirty days. If you believe the processing breaches the rules, you can lodge a complaint with the Autorità Garante per la protezione dei dati personali della Repubblica di San Marino, the San Marino personal data protection authority (garanteprivacy.sm), or bring the matter before the San Marino courts.

9. Security

We adopt technical and organisational measures appropriate under article 32 of Law No. 171/2018: encryption of traffic, authentication delegated to Telegram so that we store no passwords at all, access limited to authorised staff, logging of administrative access, periodic backups. In the event of a personal data breach that entails a high risk to your rights, we will inform you without undue delay and notify the Autorità Garante within the prescribed deadlines.

10. Minors

The service is intended for adults. We do not knowingly collect data on people under eighteen. If we learn that an account belongs to a minor, we close it and delete the related data.

11. Changes to this policy

If we change the way we handle data, we update this page and state the date. Substantial changes are notified to you by email at least fifteen days before they take effect. Previous versions remain available on request.

This policy is drafted under San Marino law. It is not a substitute for legal advice: before final publication it should be reviewed by a professional qualified in the Republic of San Marino.