Privacy Policy
Transyg Distribution Inc., a Florida corporation (document no. P17000041803) trading as FOMO Club (“FOMO”, “we”, “us”), operates FOMO Club and its trading services — David (crypto copy-trading) and Solomon (U.S. stocks). This policy explains what personal data we collect, why, who sees it, and what you can do about it. We have tried to write it in plain language rather than boilerplate.
We collect the minimum we need to run the Service: your email, your name, your wallet address, your settings, and how you use the product. We never see your card number, and we never see your private key in a form we can read. We do not sell your data to anyone, ever.
1What this covers
This policy applies to the FOMO Club website, the David dashboard, the Solomon dashboard, and everything you do inside them. It does not apply to blockchains, wallets, exchanges or other third-party services you use, which have their own terms and their own visibility.
2What we collect
| Category | What exactly | Why |
|---|---|---|
| Account | Email address, name you give at checkout, chosen nickname, profile picture if you upload one | To create and identify your account, and to contact you |
| Authentication | Password, stored only as a salted hash; sign-in tokens; sign-in timestamps | To keep your account yours |
| Wallet | Your public Solana address; addresses generated for you on other chains; your encrypted private key | To execute the trades you configure |
| Trading | Your settings, trade sizes, positions, trade history, realised and unrealised results, capital figure if you set one | To run the strategy and show you your own numbers |
| Billing | Subscription status, plan, promo code, Stripe customer and subscription identifiers | To bill you and manage your membership |
| Community | Messages, images, voice notes, stickers and GIFs you send; what you choose to share on your profile | To run the club spaces you take part in |
| Usage | Which areas of the product you open, when, and for how long; IP address and browser user-agent at sign-in and at consent | To understand what members actually use, and to keep a record of consent |
| Support | Anything you send us by email | To help you |
3Your private key
Your Solana private key is encrypted inside your own browser before it is transmitted. Our server receives and stores only ciphertext. It is decrypted only by your running David instance, in memory, at the moment it needs to sign a transaction you have configured. No person at Transyg Distribution Inc. can read your private key, and we cannot recover it for you.
Providing a key is nonetheless a serious step. We recommend connecting a wallet funded only with what you intend to trade, never your main holdings. You can remove your key at any time.
4What we never do
- We do not sell your personal data. Not to advertisers, not to data brokers, not to anyone.
- We do not share it for advertising, and we do not run ads or advertising trackers.
- We do not see your full card number — card details go from your browser to Stripe directly and never touch our servers.
- We do not read your private key. See above.
- We do not use your data to train machine-learning models.
5How we use your data
Only to run the Service and to keep it safe: to operate your account and execute your configured strategy; to bill you; to show you your own performance; to run the community spaces; to provide support; to detect and prevent fraud, abuse and security incidents; to understand aggregate product usage; and to meet our legal obligations. If you are in the UK or EEA, our legal bases are performance of our contract with you, our legitimate interests in securing and improving the Service, your consent where we ask for it, and compliance with law.
6Who we share it with
We use a small number of service providers. They process data on our instructions, for these purposes only:
| Provider | What it handles |
|---|---|
| Stripe | Payments, subscriptions and card data — Stripe is the controller of your card details, not us |
| DigitalOcean | The server the Service runs on, and where its database is stored |
| Email delivery provider | Sending sign-in links and account email |
| Blockchain RPC and routing providers | Reading chain state and submitting the transactions you configure |
| GIPHY | Sticker and GIF search in chat — requests are proxied through our server, so GIPHY does not receive your identity |
We may also disclose data if we are legally required to, to enforce our Terms, or to protect the rights, safety or property of members, the public or ourselves. If the business is ever sold or merged, your data may transfer as part of it; we would tell you first.
7What other members see
FOMO Club is a club, so some things are shared by design: your chosen public name and picture, your performance figures, your strategy settings, your capital figure if you set one, and anything you post in the community spaces.
You control this, item by item. In your dashboard you can turn your profile private, which removes you from the leaderboard and the members directory entirely. You can also stay in the club and switch off individual things: your numbers (capital, value, profit, open trades), your strategy (trade sizes and exit rules), your place on the leaderboard, and your blocked tokens. Each is independent, each takes effect immediately, and you can change any of them at any time.
Other members never see your email address or your wallet addresses, whatever your settings are — those are hidden from member-facing views by design, not just by convention.
8Operator access
FOMO’s two operators can see your account details, settings, balances and trading activity. This is how the Service is run and supported, and you consent to it explicitly when you join. It continues to apply whatever you hide from other members: the sharing controls described above hide you from other members, not from the operators who have to keep your David running. Concretely, the operator running support can see the figures and settings you have switched off, because otherwise we could not help you when something goes wrong with them. Operator access to that support view is recorded in our audit log.
9The public blockchain
Every trade David makes for you happens on a public blockchain. Wallet addresses, transactions, amounts and timings are permanently public and outside our control. Anyone can inspect them, and they can potentially be linked to you by anyone able to associate an address with your identity. We cannot delete, hide or alter on-chain data. This is a property of blockchains, not a choice we made.
9ASolomon and your brokerage account
Added in v1.1 (5 August 2026).
If you join Solomon, you connect your own brokerage account through the brokerage’s official authorization flow. We never see or store your brokerage username or password — the brokerage issues us a revocable access credential instead, and you can revoke it at any time from your dashboard or your brokerage’s security settings.
To run Solomon we receive and store what the strategy needs and nothing more: that access credential (encrypted at rest), your account’s balances, positions and orders, and the trades Solomon places. Solomon’s trades happen inside your brokerage account, not on a public blockchain, so Section 9 does not apply to them; what your brokerage itself does with your data is governed by its own privacy policy. Everything else in this policy — collection, use, sharing, protection, retention and your rights — applies to Solomon data exactly as it applies to David data.
10How we protect it
- All traffic runs over HTTPS.
- Passwords are stored as salted bcrypt hashes, never in readable form.
- Private keys are encrypted in your browser before transmission; the server holds only ciphertext.
- Member-facing responses are built from an explicit allowlist of fields, so data is shared only where we deliberately chose to share it — the default is not shared.
- Sensitive actions are rate limited and written to an audit log.
- Access to production is limited to the two operators, over key-based SSH.
- We review the platform’s security periodically and fix what we find.
No system is perfectly secure, and we cannot guarantee absolute security. If a breach affects your personal data we will tell you and any required regulator without undue delay.
11How long we keep it
Account, trading and billing records are kept while you are a member and afterwards for as long as we need them for legal, tax, accounting and dispute purposes — generally up to seven years for financial records. Product-usage analytics are pruned automatically after 90 days. Sign-in links expire and are pruned shortly after use. Community messages remain until deleted by you or by an operator. When you close your account we delete or anonymise what we no longer need.
12Your rights
Whatever your location, you can ask us to: give you a copy of your data; correct anything wrong; delete your account and data; export your data; or stop a particular use. Email info@mentesinc.com and we will respond within 30 days. We will not discriminate against you for exercising any of these rights.
Some of it you can do yourself, immediately, from your dashboard: edit your profile, set yourself private, remove your key, cash out and cancel.
If you are in the UK or EEA you also have the right to object to processing, to restrict it, to data portability, and to complain to your local data protection authority. If you are a California resident you have rights under the CCPA/CPRA — including to know, delete, correct, and to opt out of sale or sharing; as stated above, we do not sell or share personal information.
13Cookies and local storage
We use no advertising cookies and no third-party analytics trackers. The Service stores a small amount of data in your browser — your sign-in token and your language preference — which is necessary for it to work. Clearing it signs you out.
14Children
The Service is not for anyone under 18, and we do not knowingly collect data from children. If we learn we have, we will delete it.
15International transfers
We operate from the United States and our servers are located there. If you use the Service from elsewhere, your data is transferred to and processed in the United States, which may not offer the same protections as your home country. By using the Service you understand and accept this.
16Changes
We reserve the right to change this policy at any time, without notice. Every version carries a version number and effective date at the top, and the current version is always available on this page. Continuing to use the Service after a change takes effect means you accept the new version.
17Contact
Questions, requests, or complaints about privacy:
Transyg Distribution Inc. · info@mentesinc.com