1. Who We Are
This website is operated by Brian M. Nzomo, trading as TushJunior, an independent professional trader based in Nairobi, Kenya. References to "TushJunior", "we", "us", or "our" in this policy refer to Brian M. Nzomo.
Contact: nzomobrian001@gmail.com · Nairobi, Kenya
2. Data We Collect
We collect the following categories of personal data:
- Contact enquiries — Name, email address, organisation, and message content when you submit the contact form
- Investor portal accounts — Email address and password (stored securely via Supabase, never in plain text) when an account is created
- Copy trading subscriptions — Email address, subscription plan, and payment reference (no payment card data is stored by us)
- Page analytics — Page URL visited, referrer URL, approximate browser information, and visit timestamp. We do not use third-party analytics (no Google Analytics, no Facebook Pixel)
- Cookies — A single consent cookie to remember your cookie preference. If you accept analytics, a session identifier is stored locally in your browser
3. How We Use Your Data
- To respond to your enquiries and manage investor relationships
- To provide access to the investor portal and copy trading services
- To understand how visitors use this website and improve our content
- To send service-related emails (account confirmation, password reset, subscription updates)
- We do not use your data for advertising, profiling, or automated decision-making
4. Legal Basis for Processing (GDPR / Kenya Data Protection Act 2019)
- Contractual necessity — Processing your email and name to fulfil a service you requested (investor portal access, copy trading subscription)
- Legitimate interests — Understanding site usage through anonymised analytics to improve the website
- Consent — Marketing communications and non-essential cookies, where you have explicitly opted in
5. Data Storage and Security
All personal data is stored on Supabase infrastructure hosted in the United States (AWS us-east-1). Supabase is SOC 2 Type 2 certified and encrypts data at rest and in transit. Investor portal accounts use industry-standard authentication with bcrypt password hashing.
We implement reasonable technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, or destruction.
6. Data Retention
- Contact enquiries — Retained for 2 years or until deletion is requested
- Investor portal accounts — Retained while the account is active, or until deletion is requested
- Copy trading subscriptions — Retained for 3 years for financial record purposes
- Analytics data — Retained for 12 months on a rolling basis
7. Third Parties
We share data with the following service providers only to the extent necessary to operate this website:
- Supabase — Database, authentication, and file storage
- Netlify / Cloudflare — Website hosting and delivery
- NOWPayments — Cryptocurrency payment processing (copy trading subscriptions)
- Resend — Transactional email delivery
- Anthropic Claude API — Used internally to draft responses to enquiries (no personal data is permanently stored by Anthropic)
We do not sell, rent, or trade your personal data to any third party for commercial purposes.
8. Your Rights
Under the Kenya Data Protection Act 2019 and GDPR (where applicable), you have the right to:
- Access the personal data we hold about you
- Correct inaccurate personal data
- Request deletion of your personal data ("right to be forgotten")
- Object to processing of your personal data
- Request restriction of processing
- Data portability — receive your data in a machine-readable format
To exercise any of these rights, contact nzomobrian001@gmail.com. We will respond within 30 days.
9. Cookies
We use the following cookies:
- tj_cookie_consent — Stores your cookie preference (accept/decline). Expires after 365 days. Essential.
- Supabase auth token — Stores your login session for the investor portal. Session cookie, cleared on logout.
You can clear cookies at any time through your browser settings. Declining cookies does not prevent you from using this website, but the investor portal login requires session cookies to function.
10. Changes to This Policy
We may update this Privacy Policy from time to time. The date at the top of this page reflects the most recent update. Continued use of this website after changes constitutes acceptance of the updated policy.
11. Contact
For any privacy-related questions or requests: nzomobrian001@gmail.com
Brian M. Nzomo · TushJunior · Nairobi, Kenya