Privacy notice

1. Information collected

1.1 Details you submit

When you open an account or use the Service, we may gather the following types of information:

• Identity information: your first name, surname and date of birth.
• Contact information: your email address, telephone number and home address.
• Financial information: Broker API credentials restricted to reading and submitting orders, together with your investment preferences and risk settings. We do not retain complete broker passwords or full payment-card numbers.
• Account profile: your username, strategy configuration and alert preferences.
• Correspondence: messages you send through support channels or email.

1.2 Data collected automatically

Some technical data is collected automatically when you use the Service:

• IP address, browser name and version, and operating system.
• Pages viewed, tools accessed, time spent on the platform and clickstream activity.
• Device identifiers and, where relevant, mobile advertising identifiers.
• Cookie and tracking data (see our Cookie Policy).

1.3 Data supplied by third parties

Information may come from identity-check providers, fraud-prevention services and analytics partners. We may combine it with information already held to improve dependability and safeguard the Service.

2. Uses of information

Collected information may be used to:

• Set up, administer and deliver your account and the Service.
• Handle trading signals and automated orders through connected brokers.
• Tailor your experience and show relevant market information.
• Provide service messages, including confirmations, trading notices and security alerts.
• Send marketing messages where you have opted in or the law otherwise allows.
• Identify, examine and prevent fraud or unlawful activity.
• Meet legal and regulatory responsibilities.
• Build, test and enhance the Service using aggregated, anonymised information.

3. Lawful grounds for processing (EEA and UK users)

For people in the European Economic Area or the United Kingdom, personal data is processed on these legal grounds:

• Contract performance: to deliver the Service requested when you create an account.
• Legitimate interests: to combat fraud, secure the platform and improve our product.
• Legal requirement: to satisfy financial-law and tax obligations.
• Consent: for marketing and optional cookies, which you can withdraw whenever you choose.

4. Information sharing

We do not sell personal information. We may disclose it to:

• Service suppliers: cloud hosting, email, analytics and support providers that are contractually required to keep your information secure.
• Connected brokers and exchanges: only the API instructions needed to carry out the strategy you have configured.
• Authorities: where required by legislation or a court, or where disclosure is necessary to protect our legal interests.
• Business transactions: in connection with a merger, acquisition or asset transfer, provided the recipient continues to comply with this policy.

5. Transfers of data internationally

HуrorevionуPro Inc. serves customers in international markets. Your information may be processed or transferred beyond your country of residence, including to the United States and EU Member States. Where required, international transfers rely on Standard Contractual Clauses adopted by the European Commission.

6. How long we keep data

We keep personal information while your account remains open, or for the period needed to deliver the Service. Once the account is closed, some records may be retained for up to seven years to meet financial and regulatory requirements. Information that has been aggregated and anonymised may be retained without a time limit.

7. Your rights over personal data

Subject to your location and the laws that apply, you may be entitled to:

• Request a copy of the personal information we hold about you.
• Ask us to amend information that is wrong or incomplete.
• Request deletion of your personal information, sometimes referred to as the “right to be forgotten”.
• Object to particular processing activities or ask us to limit them.
• Obtain your information in a structured, machine-readable format.
• Withdraw consent at any time; this will not affect the lawfulness of processing carried out before consent was withdrawn.

To submit a data rights request, please contact us at [email protected]. Our usual response time is 30 days.

8. Keeping information secure

Security measures include TLS 1.3 for data in transit, AES-256 encryption for stored data, multi-factor authentication, role-based permissions and independent penetration testing each year. No system can be guaranteed completely secure. Use a distinctive, strong password and turn on two-factor authentication.

9. Cookies and related technologies

Cookies and comparable technologies help us operate and improve the Service. Further information is available in our Cookie Policy.

10. Privacy for children

The Service is intended for people aged 18 or over. We do not knowingly gather personal information from children. If you think a child has provided us with data, please tell us so that we can remove it promptly.

11. Updates to this policy

This Privacy Policy may be updated periodically. Significant changes will be posted on the website or communicated by email. Continuing to use the Service once an updated policy takes effect indicates acceptance of the revised terms.

12. How to contact us

For privacy questions or requests concerning your data rights, please contact our Data Protection Officer:

• Email address: [email protected]
• Registered office: HуrorevionуPro Inc 200 Park Avenue, New York, NY 10166, United States, United States
• EU-based representative: HуrorevionуPro, 200 Park Avenue, New York, NY 10166, United States