Privacy Policy

1. Overview and Data Controller

Rumao Provencia ("we", "us", or "our") respects the privacy rights of visitors, users, and clients. This Privacy Policy details the types of personal data we collect, the legal grounds on which we process that information, how we safeguard your data, and your statutory rights under the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

For the purposes of applicable data protection legislation, the data controller is Rumao Provencia, with operating facilities at High Holborn 115, BS1 5LJ Bristol, United Kingdom.

2. Personal Data We Collect

We may collect, record, and process the following categories of personal information:

• Identity and Contact Data: Name, professional title, contact telephone number, and email address.
• Technical and Device Data: Internet Protocol (IP) addresses, browser type, operating system version, time zone settings, device identifiers, and server response logs.
• Usage and Interaction Data: Platform feature navigation, algorithm parameters utilised, execution telemetry, visit timestamps, and user journey analytics.
• Transactional and Account Data: Subscription identifiers, transaction logs, exchange connection status, and customer support communications.

We do not hold custody of your digital wallet private keys or bank account details directly on our analytical platform servers.

3. Legal Bases for Data Processing

We only collect and process personal data where there is a lawful basis under UK GDPR, specifically:

• Performance of a Contract: Providing access to the algorithmic trading software, administering user authentication, and fulfilling customer support requests.
• Legitimate Interests: Improving platform performance, detecting fraudulent activity, auditing security architecture, and protecting computational infrastructure.
• Legal and Regulatory Compliance: Complying with statutory accounting obligations, responding to verified law enforcement requests, and meeting tax requirements.
• Consent: Where you have explicitly opted into receiving non-transactional analytical reports or marketing updates (which you may withdraw at any time).

4. How We Use Cookies and Tracking Technologies

The Platform employs strictly necessary session cookies and persistent performance tokens to authenticate user sessions, maintain display preferences, and ensure load balancing. We do not sell user behavioral data to third-party ad brokers.

You can manage or disable non-essential cookies through your browser settings, though doing so may prevent certain real-time analytical charts or dashboard modules from functioning properly.

5. Data Sharing and Third-Party Disclosures

We never sell, rent, or trade your personal data. We may share information with trusted third-party service providers solely under strict confidentiality and security terms, including:

• Cloud hosting and distributed server providers that maintain our computational architecture;
• Specialised telemetry and operational cybersecurity monitoring partners;
• Professional legal, auditing, and accounting advisors;
• Regulatory bodies, judicial authorities, or law enforcement entities when strictly required by enforceable legal process.

6. International Data Transfers

Where processing requires transferring personal data outside the United Kingdom, we ensure appropriate safeguards are implemented in accordance with UK data protection laws, such as International Data Transfer Agreements (IDTAs), standard contractual clauses, or adequacy regulations recognised by the UK Information Commissioner's Office (ICO).

7. Data Security and Retention

We implement technical and organizational security controls, including TLS/SSL encryption for data in transit, encrypted database volumes at rest, granular role-based access restrictions, and regular vulnerability assessments.

We retain personal information only for as long as necessary to fulfill the purposes for which it was gathered, satisfy contractual obligations, or comply with statutory record-keeping periods (typically up to seven years for fiscal audit records).

8. Your Statutory Rights

Under UK data protection law, you hold rights regarding your personal information, including:

• The right to request access to copies of your personal data;
• The right to rectification of inaccurate or incomplete records;
• The right to erasure ("right to be forgotten") under specific statutory criteria;
• The right to restrict or object to the processing of your data;
• The right to data portability for automated information provided under contract.

To exercise any of these rights, please submit a written request to [email protected]. You also retain the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

9. Contact Us

If you have questions or concerns regarding this Privacy Policy or our data management procedures, reach out to our data privacy officer at: