Privacy Policy

This Privacy Policy explains how SKYWARD ORIGIN DEVELOPING SERVICE - FZCO, a company registered in Dubai Silicon Oasis, United Arab Emirates (Registration No. 73283, Licence No. 75286) (“Skyward Origin”, “we”, “us”), handles personal data when you visit this website and use Samantha, including the Samantha Terminal web app and the Samantha Telegram bot (together, the “Service”). We are responsible for the personal data described here.

1. What data we process

• Account data. When you sign in with Telegram, Google or email, we receive your username, your Telegram ID or Google account identifier, and your contact email.
• Subscription and payment data. Your plan, your subscription status and technical payment data, such as transaction identifiers and tokens. Payments are processed by our payment providers.
• Content you provide. Portfolio data and trading preferences that you enter manually, your messages and conversation history with Samantha, and other content you add to the Service, such as journal entries. If you use voice mode, the text and audio needed to generate or process speech are handled with the help of our voice provider.
• Technical data. Your IP address, the date and time of your activity, device and browser information, and cookies as described below.

2. How we use data

• to provide the Service and to process your subscription;
• to personalize Samantha’s responses and to calculate risk parameters;
• to send you timely notifications and alerts;
• to protect your account and to keep the Service secure and stable;
• to comply with legal obligations.

3. Sharing

We do not sell personal data. We share it only with service providers that help us run the Service, such as hosting, payment processing, sign-in (Telegram and Google), voice (ElevenLabs), and AI and data-processing providers, only as needed for these purposes, and with public authorities when the law requires it.

4. Storage and security

Data is processed using encryption and is stored on secure servers in Europe. Access is limited to authorized server processes and to team members who need it for their duties.

5. Retention

We keep your data for as long as your account is active and as needed to provide the Service. When you ask us to delete your data, we delete it, except for records that we must keep by law, such as payment records.

6. Your rights

Depending on where you live, you may have the right to access your personal data, to have it corrected or deleted, and to object to or restrict its processing. To exercise these rights, email us at the address below.

7. Cookies

This website does not use advertising or analytics cookies. The Samantha Terminal web app uses essential cookies and similar storage to keep you signed in and to remember your settings.

8. Children

The Service is not directed at persons under 18, and we do not knowingly collect their personal data.

9. Changes

We may update this Privacy Policy from time to time. The current version is always available on this page.

10. Contact

For privacy questions, contact us at the email address below.