Privacy Policy
1. Overview & Data Controller
Thach Nganvinh ("Company," "we," "us," or "our") is dedicated to safeguarding the personal data and privacy rights of users accessing our platform. This Privacy Policy details the types of personal data we collect, how that information is utilized, disclosed, stored, and protected in compliance with the Data Protection Act 2018 and the United Kingdom General Data Protection Regulation (UK GDPR).
For the purposes of applicable data protection legislation, the data controller is Thach Nganvinh, King William Street 114, BS1 5LJ Bristol, United Kingdom.
2. Categories of Data We Collect
We collect data that you provide directly, as well as technical information gathered automatically when you interact with our website and algorithmic systems:
- Identity & Contact Details: Full name, email address, telephone contact, country of residence, and communication history when you submit an inquiry.
- Technical & System Information: IP address, browser type and version, time zone setting, operating system, device identifiers, and network connection metadata.
- Platform Usage Data: Analytical logs, visited pages, interaction duration, clickstream data, diagnostic crash logs, and referral source URLs.
- Configuration Data: User interface preferences, selected analytical parameters, algorithmic sensitivity levels, and system telemetry.
3. Lawful Bases for Processing
Under UK GDPR Article 6, we process your personal data under the following legal frameworks:
- Performance of a Contract: Processing necessary to provide technical platform access, software integrations, and customer service.
- Legitimate Interests: Processing required to maintain cybersecurity, improve algorithmic reliability, detect and prevent fraud, and optimize user experience.
- Legal Obligation: Processing necessary to satisfy mandatory reporting, regulatory compliance, and lawful law enforcement requests.
- Consent: Where you have granted explicit consent for specific non-essential cookies or direct marketing communications.
4. Purpose of Data Utilization
We process your personal information strictly for legitimate commercial and technical purposes, including:
- Deploying and operating automated trading intelligence models and user dashboards.
- Verifying user identities and maintaining platform security against DDoS attacks and brute-force intrusion.
- Responding to technical inquiries, customer support requests, and billing notices.
- Monitoring server load, optimizing algorithmic execution speeds, and rectifying software bugs.
5. Cookies & Tracking Technologies
We employ essential session tokens, technical cookies, and anonymous performance analytics to ensure consistent platform stability and security. Essential technical cookies are required for navigation and server routing. Performance cookies help us understand aggregate traffic patterns without identifying individual users. You may adjust your browser preferences to reject non-essential cookies at any time.
6. Data Sharing & Third-Party Processors
We do not sell, rent, or lease personal information to third parties. We may disclose your personal data exclusively to trusted service providers operating under strict confidentiality and data protection agreements, including:
- Secure cloud infrastructure and server hosting facilities located within the United Kingdom and the European Economic Area (EEA).
- Cybersecurity auditing and fraud prevention specialists.
- Legal, compliance, and regulatory authorities where compelled by valid UK judicial process or statutory duty.
7. International Data Transfers
Where personal data is transferred outside the United Kingdom, we ensure that adequate safeguards are enforced in accordance with UK GDPR. Such safeguards include the International Data Transfer Agreement (IDTA), standard contractual clauses approved by the Information Commissioner's Office (ICO), or transfers to jurisdictions with recognized adequacy decisions.
8. Data Retention & Safeguards
We retain personal information only for as long as necessary to fulfill the operational purposes for which it was collected, or to satisfy legal, tax, or regulatory recordkeeping requirements. We implement state-of-the-art technical security controls, including TLS 1.3 encryption in transit, AES-256 encryption at rest, restricted administrative access protocols, and regular penetration testing.
9. Your Data Subject Rights
Under the UK Data Protection Act 2018 and UK GDPR, you have the right to:
- Request access to the personal data we hold about you.
- Request rectification of inaccurate, outdated, or incomplete data.
- Request erasure ("right to be forgotten") under qualifying legal conditions.
- Object to or restrict the processing of your personal data.
- Request the transfer of your data to another controller (data portability).
- Lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.
10. Contacting Our Data Protection Team
To exercise your privacy rights, file a query, or request information regarding this policy, please reach out to our privacy compliance officer:
- Data Protection Officer: Thach Nganvinh Privacy Office
- Physical Address: King William Street 114, BS1 5LJ Bristol, United Kingdom
- Email: [email protected]
- Phone: +44 20 7946 5179