Privacy Policy
Up Your Game LLC operates Lemoney. This policy explains what personal data we collect, why, who else handles it, how long we keep it, and what you can ask us to do with it. It applies to the website, the Lab, and any API or MCP server we offer.
We keep your email address, your plan, the portfolios you save, and records of how you use the product. If you publish a portfolio, it is public, with your public name beside it. Payments are handled by Stripe, and we never see your card number. We use one analytics tool, PostHog, hosted in the EU, with everything you type masked. No advertising trackers. We do not sell your personal data or share it for advertising.
1. Who is responsible
The data controller is Up Your Game LLC, registered in Sharjah Media City (Shams), Sharjah, United Arab Emirates. Privacy contact: privacy@lemoney.money.
2. What we collect
3. What is public
Portfolios are private by default. When you publish one, anyone on the internet can see its name, its instruments, weights, settings and results, and the public name of the person who published it. You choose that name the first time you publish, or leave it blank and we generate a random one. It is never taken from your email address. A published portfolio can be copied, linked and indexed by search engines. Making it private or deleting it removes it from Lemoney, but cannot recall copies others have already made. Do not put personal information in a portfolio name.
4. What we do not do
- We do not sell personal data, and we do not share it for cross-context advertising.
- No advertising pixels, ad networks or cross-site tracking.
- No keystrokes or form values in session replay.
- No device fingerprinting, and no IP addresses stored in our own database.
- We do not buy personal data or enrich your record from outside sources.
- No automated decisions that have legal or similarly significant effects on you. Plan limits are applied automatically, but they are the same for everyone on a plan.
- We do not ask for your finances, holdings or identity documents, and you should not send them. The Lab needs none of it. Please do not send us special-category data such as health or religious information.
5. Why we use it, and our legal basis
We process personal data under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Where the EU or UK GDPR applies, we rely on the legal bases below.
6. Cookies and similar storage
All are first-party. None are for advertising.
7. Who else handles it
Each processes personal data under a written agreement and on our instructions. We update this list when we add a provider. We also disclose data when the law requires it, to protect our rights, users or the Service, and to a buyer or successor if the business or its assets are transferred, in which case this policy continues to apply to your data.
8. International transfers
We operate from the United Arab Emirates, and our providers run infrastructure elsewhere, including the United States and the European Union. Where EU or UK GDPR data is transferred outside those areas, the transfer relies on Standard Contractual Clauses or an equivalent safeguard in the provider’s agreement. Where the PDPL applies, transfers are made as that law permits.
9. How long we keep it
- Account, email and portfolios: while the account exists, then up to 90 days after it is closed, so an accidental closure can be undone.
- Payment and tax records: as long as tax law requires, currently five years from the end of the tax period.
- Support messages: up to 24 months after the last message, even if the account is closed, as the record of what was asked and answered.
- API key hashes: until revoked, then up to 12 months.
- API request logs: 13 months. Monthly totals for as long as the account exists.
- Session replays: 90 days.
- Analytics events: 12 months. Totals with no identifier may be kept indefinitely.
- Legal holds: anything needed for a dispute, investigation or legal obligation, until it is resolved.
10. Your rights
Depending on the law that applies to you, you can ask us to give you a copy of your personal data, correct it, delete it, restrict or object to how we use it, or send it to you in a portable format, and you can withdraw any consent you gave. Residents of some US states have similar rights to know, delete and correct, and to opt out of sale or sharing, which we do not do. We will not treat you differently for using any of these rights.
Email privacy@lemoney.money from the address on your account. We reply within 30 days, or tell you if we need longer as the law allows. It is free unless a request is clearly unfounded or excessive. We may need to verify your identity first. Some data must be kept for legal reasons, and if so we say which and why.
Closing your account deletes your account record, email and saved portfolios, including published ones, and we delete your analytics profile and replays. Records we must keep, such as invoices and support correspondence, are kept for the periods in section 9.
11. Security
Traffic is encrypted in transit. Sign-in is by one-time email code, so there is no password to steal. API keys are stored only as hashes. Database access is limited to the application and the operator. No system is perfectly secure, and we cannot guarantee that yours will not be accessed without authorisation. If a breach affects your personal data in a way that creates a risk to you, we will tell you and the relevant authority as the law requires.
12. Children
The Service is not for anyone under 18, and we do not knowingly collect their data. If you believe a child has given us personal data, email privacy@lemoney.money and we will delete it.
13. Changes
We update this policy when what we do changes. The effective date at the top shows the current version. We will email account holders before a material change takes effect.
14. Contact and complaints
Up Your Game LLC, Sharjah, United Arab Emirates. Privacy contact: privacy@lemoney.money.
Please contact us first, so we can put it right. If you are not satisfied, you can complain to the UAE Data Office, or, where the EU or UK GDPR applies, to the data protection authority where you live or work.
Version effective 2026-09-15. See also the Terms of Service.