Privacy Policy

Who we are

Djembely is owned and run by Melian Dialogue Limited (the "Company"). The Company is a private limited company set up in the Republic of Kenya.

Registered Office: P.O. Box B1003, Urban Oasis Apartments, Kingara Road, Lavington, Nairobi.

Company Registration No.: PVT-27ULY98K.

KRA PIN: P052416974R.

The rules we follow

This policy is written to follow the UK GDPR and EU GDPR (the main data protection laws in the UK and the European Union).

Melian Dialogue Ltd is the data controller. That means we are the ones who decide how and why your personal data is used.

What Djembely is, and what it is not

Djembely is for practice trading only. You use virtual money (GBP 10,000, or an equivalent amount in your region). No real orders are placed. There is no leverage (borrowing to trade bigger). We do not give investment advice and we do not promise any returns.

Because nothing here is real trading, the trades you make are practice trades. We still look after the information they create with care.

What we collect

Here is the information we may hold about you:

• ·Your date of birth. We ask for it at signup so we can check you are 18 or over.
• ·Your account email and your subscription status.
• ·Your practice trading activity. This means the virtual orders, fills (completed trades) and positions (what you hold) that you create.
• ·Your Autotrader and Auto-Discovery settings, and the practice trades, suggestions and plain-English rationale logs they create. A rationale log shows each signal used, its weight and its data source.
• ·The BeCo behavioural scores worked out from your practice activity (see the BeCo Engine and BeCo Index).
• ·Any trade notes or journal text you choose to write about a closed trade. You write this yourself, and it feeds your Journal Completion score. Please do not put personal or sensitive information in these notes.
• ·Your Co-pilot settings (language, how deep the explanations are, and how much it can do on its own).
• ·Your Co-pilot records, if you use it. These include feedback on its insights, reports of mistakes or misfires, any question text you send, and any trade you type or speak using prompt-to-trade.
• ·Your chosen region or language group. We use it to show you a leaderboard for people in your group as well as the global one.
• ·If you stop following a leader, a short reason if you choose to give one. Only Djembely can see it, to help improve the product. It is never shared with the leader.
• ·If you opt in, a flag showing you take part in the Co-pilot-effectiveness study or the academic-review pathway. These are off by default.
• ·Your one-time baseline answers about your investment goals and how you think and decide. We store them as a Stated Baseline Profile, kept apart from your BeCo scores (see the section on your baseline assessment below).
• ·Your answers to the Live Intent questionnaire.
• ·Your choices about phone notifications, if you turn them on.
• ·Share-card choices you make, if any. Cards are made on your own device (see the section on share cards below).

Usage information (telemetry) and location

While you are signed in, we record how you use Djembely. This is called telemetry. It includes when your session starts and ends, your device type, operating system, browser, screen size, language, time zone, and connection type (where your browser tells us). It also includes pages visited, the path you click through, where you click, how long you stay, how far you scroll, tooltips you open, prompts you send, trades you place, and any optional investing preferences you give.

We use this to improve Djembely and to understand how much people want features such as live trading.

We work out an approximate city and country from your IP address (the number that identifies your internet connection) using a third-party lookup service. We do not store your precise location.

Your browser may also ask if Djembely can use your precise device location. This only happens if you allow it. We use it to pick your region, language and features. We do not store it precisely. If you say no, Djembely still works.

Moderation records

Sometimes a Djembely administrator takes action against an account under the Acceptable Use Policy. When that happens, we keep a record of it. This means a person's Acceptable Use history stays on record even if they make a new account.

For now, that record is linked to a handle-based identifier (an ID based on the account's username). Djembely does not currently fingerprint devices or hardware (identify a device by its technical details). We will update this policy before we bring in any technique like that.

A note on your behavioural data

The BeCo behavioural scores are not "special-category data" under UK GDPR (the extra-sensitive types of data, such as health information). But they show a lot about how you make decisions. For example, they show how you size positions, set stops (limits that close a trade) and react after a loss. So we treat them with the same care we would give more sensitive data.

We explain in plain words what each score measures. We work them out only from your own practice activity. We never sell them.

Your baseline assessment (investment goals and how you think and decide)

Before you first reach the dashboard, you fill in two one-time questionnaires. One asks about your investment goals. The other asks about how you reason, how you feel about risk, and how you tend to decide. You must complete both to use Djembely. They create the Stated Baseline Profile that the Co-pilot and the BeCo Engine use for you.

These are things you tell us about yourself. Like your BeCo scores, they say a lot about how you make decisions. So we treat them with the same care as more sensitive data, even though they are not special-category data. We store them apart from your BeCo scores. We never use your answers in any BeCo formula. The two are kept separate on purpose.

One purpose is to run and personalise your own Djembely experience. A different purpose is using anonymised, combined versions of your answers for research. For research we ask for separate, optional consent, once, after you finish the questionnaires.

That research consent is truly optional. If you say no, you lose nothing in your Djembely experience. If you say yes, your answers go into the same research pool as the Co-pilot-effectiveness study and the academic-review pathway. There is no separate pool.

The Live Intent questionnaire

Your Live Intent answers are stored with your account. We use them in combined form to judge whether people are ready for real-money trading. You can ask us to delete your usage data and your answers at any time through the Contact page.

The Co-pilot, prompt-to-trade and voice

The Co-pilot is an AI assistant. It uses OpenAI GPT 6 Luna through the Company's own OpenAI account. If that is not available, we use the Emergent universal key as a backup.

With prompt-to-trade, you can type or speak a practice trade. If you use voice, OpenAI speech-to-text turns your speech into words, and OpenAI text-to-speech reads answers back to you.

Only the facts already worked out about a trade, and any question you type or say, are sent for the AI to put into words. We do not send special-category data.

AI answers can be wrong. Please check them yourself and do not treat them as advice.

The Autotrader and Auto-Discovery

The Autotrader makes practice trades automatically, in up to 5 slots. Auto-Discovery runs scheduled scans on weekdays. It can suggest or add instruments, but only within your settings.

Each decision mixes several signals into one confidence score. The signals are: price and volume; EODHD financial news and sentiment; company events (dividends, earnings dates, price-to-earnings figures and profit figures); the EODHD economic calendar (such as interest-rate decisions and inflation); and, for African shares, Mansa Markets company announcements.

Every trade and recommendation comes with a plain-English rationale log. It shows each signal, its weight and its data source.

Backtests (tests on old prices) use past prices only. They do not predict the future.

Market data

The prices and facts you see come from these providers:

• ·EODHD: prices, company facts, news and the economic calendar.
• ·Mansa Markets: African exchanges. This includes price history over several years where their plan allows. Short gaps of up to 3 trading days are filled in and flagged.
• ·Coinpaprika: crypto data.
• ·Alpaca: data for paper trading (practice trading).

Third-party processors

Market data can be late or wrong, so please do not rely on it for real decisions.

• ·Stripe: subscription billing and payment processing.
• ·EODHD: market data shown in the product. We send no personal data to EODHD.
• ·OpenAI: powers the Co-pilot's AI answers, and voice (speech-to-text and text-to-speech), through the Company's own account.
• ·Emergent: provides the universal key we use as a backup for the Co-pilot's AI.
• ·Our object storage provider: stores files for the platform, including images, videos and files uploaded for newsletters.
• ·GIPHY and Unsplash: supply GIFs and photos for the share-card builder (see below).

Phone notifications and the installable app

We send phone notifications (web push) only after you opt in. You can pause or turn them off whenever you like.

Djembely can be installed as an app on your device (a PWA, or progressive web app). It supports swipe gestures.

Languages

Djembely is offered in seven languages: English, Spanish, French, Swahili, Sheng, Luganda and Kinyarwanda. The translations are drafted by AI. If a translation and the English version say different things, the English version is the one that counts.

Newsletters and emails

The Super Admin sends newsletters. Platform updates go to every account holder. Marketing emails go only to people who have not unsubscribed. Every email has an unsubscribe link.

Our emails may contain a tracking pixel (a tiny hidden image that gives us an approximate count of opens) and tracked links (which count clicks). We use these only to measure how well newsletters perform.

Images, videos and files uploaded for newsletters are stored with the platform's object storage provider.

The share-card builder

You can design share cards with themes, photos (from Unsplash), badges, emoji and, if you like, animated GIF backgrounds from GIPHY. Only G and PG rated GIFs are shown, and we show "Powered by GIPHY".

When you search for GIFs, your browser sends the search straight to GIPHY. This happens under GIPHY's terms.

Cards are made on your own device. Djembely does not post anything for you on any other site.

Retention (how long we keep data)

We keep your account and behavioural data for as long as your account is active. After that, we keep it for a limited time where the law or accounting rules require it. Then we delete it or make it anonymous.

Your rights

You have the right to see your data, fix it, erase it, and take a copy of it to use elsewhere. You can also object to some uses of your data, or ask us to limit them. Contact us to use any of these rights.

You can also ask us at any time, through the Contact page, to delete your usage data and your Live Intent answers.