Privacy Policy

1. INTRODUCTION & CONTROLLER INFORMATION

TipTrust.eu ("we," "us," "our," or "Platform") is committed to protecting your privacy and ensuring you have a transparent experience on our platform. This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard your personal data.

Operating Entity: K. Agency LLC
Address: 16192 Coastal Highway, Lewes, Delaware 19958, United States
Contact: support@tiptrust.eu
Service operated from: United States

This Policy applies to all users of the Platform, including Users, Tipsters, and Subscribers. By using TipTrust.eu, you agree to the collection and processing of your data as described herein. Although the service is operated from the United States, we are committed to complying with the General Data Protection Regulation (GDPR) for all users, regardless of their location.

2. PERSONAL DATA WE COLLECT

Registration & Account Information

When you create an account via our authentication provider, we collect:

• Full name and email address (provided by your login provider, e.g. Google)
• Account creation date
• Profile picture (if you choose to upload one)
• Language preference

Tipster-Specific Data (KYC Verification)

Tipsters applying to sell tips on the platform must provide:

• Full legal name (first and last name)
• Residential address (street, city, state/region)
• Nationality
• Government-issued ID (passport or national ID card) — front and back photos
• IBAN for SEPA bank transfers (payouts)
• Public display name, biography, and profile avatar
• Social media links (Telegram, Instagram, TikTok, X, YouTube, Facebook — all optional)
• Betting slips and match result documentation for tip verification

Payment Information

We do NOT store credit card data. All payments are processed through Stripe, which is PCI-DSS Level 1 certified. We receive only:

• Payment confirmation, transaction IDs, and payment intent IDs from Stripe
• Subscription status and billing cycle information
• Purchase history (tip purchases, product purchases, subscription records)

Usage & Interaction Data

We automatically collect:

• Pages visited within the platform
• Tips viewed, tips purchased, tips liked
• Follow/unfollow actions on tipsters
• Reviews and ratings submitted
• Notification interactions

Device & Technical Information

For analytics and security purposes, we collect:

• Browser type and user agent string
• Referrer URL (how you found the Platform)
• Hashed visitor identifier (for anonymous traffic analytics)

Advertising & Conversion Tracking

We use Google Ads (gtag.js) conversion tracking to measure the effectiveness of our advertising campaigns. This may collect:

• Conversion events (e.g., when a user first visits their dashboard after registration)
• Google Ads cookies for attribution and measurement
• Anonymized interaction data shared with Google for ad performance reporting

Google may use this data in accordance with their own privacy policy: policies.google.com/privacy

We use local storage to remember your language preference. We do not use third-party advertising trackers or marketing cookies.

Communications

When you contact us via the contact form or email, we collect your name, email address, subject, and message content. We also send transactional and notification emails (purchase confirmations, subscription updates, tip results, payout notifications).

3. LEGAL BASIS FOR PROCESSING (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract Performance (Art. 6(1)(b)): Processing necessary to provide the Platform, fulfill purchases, manage subscriptions, and process tipster payouts
• Legitimate Interest (Art. 6(1)(f)): Operating and improving the Platform, fraud prevention, security monitoring, and platform analytics
• Legal Obligation (Art. 6(1)(c)): Compliance with applicable financial regulations, tax requirements, and KYC obligations
• Explicit Consent (Art. 6(1)(a)): Where required, for optional marketing communications (you can withdraw consent anytime)

4. HOW WE USE YOUR DATA

To Provide & Improve the Platform

• Process registrations and manage your account
• Deliver purchases, subscriptions, and content access
• Calculate and display Tipster statistics (ROI, win rate, profit/loss)
• Send in-app notifications about new tips, purchases, subscriptions, and results
• Provide customer support via email
• Analyze platform usage to improve features and user experience

Payment & Financial Processing

• Process one-time and recurring subscription payments via Stripe
• Send payment confirmation and subscription update emails
• Calculate and facilitate payouts to Tipsters via SEPA bank transfer
• Maintain transaction records for reconciliation and accounting

Compliance & Security

• Verify Tipster identity (KYC) for payouts and fraud prevention
• Detect and prevent fraud, manipulation, and platform abuse
• Enforce Terms of Service and investigate violations
• Maintain audit logs for administrative actions
• Respond to legal requests from authorities

5. DATA SHARING & THIRD PARTIES

We DO NOT sell personal data to third parties.

We share personal data only in the following limited circumstances:

Payment Processor — Stripe

We share payment-related data (email, transaction details) with Stripe to process payments, manage subscriptions, and handle refunds. Stripe is PCI-DSS Level 1 certified. See: stripe.com/privacy

Infrastructure & Email Services

We use cloud hosting (Base44 platform infrastructure) and transactional email services to operate the Platform and send notifications. These providers process data on our behalf under data processing agreements.

Advertising — Google Ads

We use Google Ads conversion tracking (gtag.js) to measure the effectiveness of our advertising campaigns. Google may receive anonymized conversion event data and set cookies for attribution purposes. Google processes this data under its own privacy policy. See: policies.google.com/privacy

Public Information on the Platform

Certain data is publicly visible by design:

• Tipster profiles: Display name, avatar, biography, sports covered, social links, statistics (ROI, win rate, total tips, followers count)
• Tips: Public description, cover image, sport, odds, match date. Hidden content (teams, prediction, analysis) is only visible to purchasers/subscribers
• Reviews: Ratings and comments are visible on tipster profiles

User account data (email, full name) is never publicly displayed. Only your profile picture and display name (if set) may be visible in certain contexts.

Legal Authorities

We may disclose personal data if required by law, court order, or government request, or to protect our legal rights.

Business Transfers

If K. Agency LLC is acquired, merges, or sells assets, personal data may be transferred as part of that transaction. We will notify you of such changes.

6. INTERNATIONAL DATA TRANSFERS

TipTrust.eu is operated by K. Agency LLC from the United States. Your personal data is transferred to and processed in the United States, where data protection laws may differ from those in the European Economic Area (EEA).

For users in the EEA, we ensure adequate protection for international data transfers through:

• The EU-U.S. Data Privacy Framework (where applicable)
• Standard Contractual Clauses (SCCs) approved by the European Commission
• Ensuring all sub-processors maintain appropriate data protection safeguards

By using the Platform, you acknowledge and consent to the transfer of your data to the United States for processing as described in this Policy.

7. DATA SECURITY

We implement industry-standard security measures to protect your personal data:

• Encryption: Data in transit is protected via TLS/SSL encryption
• Authentication: Managed through secure authentication providers
• Access Controls: Only authorized administrators access personal data on a need-to-know basis
• Payment Security: Credit card data is never stored on our servers — handled entirely by Stripe
• KYC Documents: Identity documents are stored securely and only accessible to admin staff for verification

Important: No method of transmission over the Internet is 100% secure. We recommend using strong, unique passwords for your account.

8. DATA RETENTION

Account Data

We retain active account data for as long as your account exists. Upon account deletion request, we delete or anonymize your personal data within 30 days, except where retention is required by law.

KYC & Identity Documents

KYC documents (ID photos, address verification) are retained for up to 7 years to comply with applicable financial and anti-money laundering regulations, then securely deleted.

Financial Records

Payment history, transaction records, and payout records are retained for 7 years for tax and regulatory compliance.

Tip & Verification Data

Tips, betting slips, and verification records are retained indefinitely to maintain the historical integrity of Tipster statistics and prevent fraud. This is a core platform feature.

Analytics & Visit Data

Anonymous site visit logs are retained for 12 months, then deleted.

9. YOUR RIGHTS UNDER GDPR

Regardless of your location, we extend the following GDPR rights to all users:

• Right to Access (Art. 15): Request a copy of all personal data we hold about you
• Right to Rectification (Art. 16): Correct inaccurate or incomplete data
• Right to Erasure / "Right to Be Forgotten" (Art. 17): Request deletion of your personal data, subject to legal retention obligations
• Right to Restrict Processing (Art. 18): Limit how we process your data in certain circumstances
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format
• Right to Object (Art. 21): Object to processing based on legitimate interests, including direct marketing
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent for optional processing at any time
• Right to Lodge a Complaint: File a complaint with a data protection authority in your jurisdiction

10. COOKIES & LOCAL STORAGE

TipTrust.eu uses minimal cookies and local storage:

• Authentication cookies: Essential for keeping you logged in (managed by our auth provider)
• Language preference: Stored in local storage to remember your selected language
• Tutorial progress: Stored in local storage to track onboarding completion
• Google Ads cookies: Used for conversion tracking and advertising attribution (set by Google via gtag.js)

Apart from Google Ads conversion tracking, we do not use retargeting pixels or invasive third-party tracking technologies. You can manage or block cookies through your browser settings at any time. You can also opt out of Google Ads personalization at adssettings.google.com.

11. CHILDREN'S PRIVACY

TipTrust.eu is not intended for users under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that a child has provided personal data, we will promptly delete that information and terminate the account. If you believe a minor has registered, please contact support@tiptrust.eu immediately.

12. CHANGES TO THIS POLICY

K. Agency LLC may update this Privacy Policy to reflect changes in our practices or legal requirements. Significant changes will be communicated via email or displayed on the Platform. Your continued use following notification constitutes acceptance of the updated Policy.

13. CONTACT US

For questions, concerns, data access requests, data deletion requests, or to exercise any of your privacy rights:

Email: support@tiptrust.eu
Entity: K. Agency LLC
Address: 16192 Coastal Highway, Lewes, Delaware 19958, United States
Response Time: We aim to respond within 30 days