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Privacy & Data Protection

Privacy Policy

Effective Date: 1 January 2026  |  Last Updated: 12 February 2026

1. Overview & Data Controller

Vong Nganthinh ("we", "us", "our") values the trust you place in our automated software ecosystem. This Privacy Policy details the types of personal data we collect, why we process it, how it is secured, and your statutory privacy rights under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and relevant international data protection laws.

For the purposes of data protection legislation, Vong Nganthinh acts as the Data Controller with respect to personal information collected through our official digital platform.

2. Categories of Information We Collect

We collect and process personal data strictly in connection with providing quantitative algorithmic software and maintaining system security:

  • Identity & Contact Data: Full name, verified email address, telephone contact number, country of residence, and government identity document details supplied during compliance screenings.
  • Technical & Telemetry Data: IP address, browser type and version, hardware device identifiers, operating system, network latency metrics, and session diagnostic logs.
  • Trading Configuration Data: Encrypted exchange API keys, trading parameter settings, order sizing choices, automated stop-loss limits, and operational performance logs.
  • Communication Data: Records of support dialogues, service feedback, and legal communications submitted to our technical helpdesk.

We do not store your private crypto custody keys or exchange account withdrawal passwords. All API connections are restricted to trade execution permissions only.

3. Legal Bases for Processing Personal Data

We process your personal information exclusively under recognized lawful grounds:

  • Contractual Performance: Processing required to activate your automated bot configurations, calculate quantitative models, and execute service commands.
  • Legal & Regulatory Compliance: Fulfilling mandatory reporting standards, prevention of fraud, identity verification, and anti-money laundering regulations.
  • Legitimate Interests: Securing platform network infrastructure against denial-of-service exploits, optimizing algorithmic latency, and preventing abuse.
  • Consent: Where you provide express prior agreement for non-essential communications or specific analytics cookies.

4. Cookies & Tracking Technologies

Our platform uses essential technical session cookies and security tokens necessary for maintaining authenticated sessions and preventing cross-site scripting (XSRF). You may configure your browser software to block or alert you about these files; however, certain automated features of the platform may fail to operate correctly without essential tokens.

5. Disclosure of Personal Information

We do not sell, rent, or trade your personal information. We may share specific data elements with vetted third parties strictly under confidentiality and data protection agreements:

  • Cloud infrastructure providers and secure data center facilities situated in accredited jurisdictions.
  • Specialized identity verification agencies performing automated sanctions and anti-fraud evaluations.
  • Professional legal, accounting, and compliance consultants supporting operational governance.
  • Judicial bodies or law enforcement authorities when mandated by statutory law, court subpoenas, or binding regulatory orders.

6. International Data Transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area, we implement robust safeguard mechanisms, such as UK International Data Transfer Agreements (IDTA) or standard contractual clauses (SCCs), ensuring an equivalent standard of protection is maintained across all recipient environments.

7. Data Retention Periods

We retain personal information only for the duration necessary to fulfill the operational purposes for which it was gathered, including satisfying legal, tax, accounting, and regulatory compliance obligations. Following the closure of your account, operational data is safely archived or permanently anonymized according to our statutory retention schedule (typically five to seven years for compliance records).

8. Information Security Controls

We utilize rigorous institutional safeguards, including TLS 1.3 cryptographic transport protocols, AES-256 database-level encryption at rest, role-based access management, continuous vulnerability scanning, and segmented network infrastructure. Despite these proactive controls, no electronic transmission over the internet can be guaranteed to be immune from all emerging security threats.

9. Your Statutory Rights

Under UK data protection frameworks, you are entitled to exercise the following rights regarding your personal information:

  • The right to request access to and copies of the personal data we hold about you.
  • The right to demand rectification of inaccurate, outdated, or incomplete data.
  • The right to request erasure ("right to be forgotten") subject to legal retention obligations.
  • The right to restrict or object to specific processing activities.
  • The right to receive your data in a portable, structured, and machine-readable format.
  • The right to lodge a formal complaint with the UK Information Commissioner's Office (ICO).

10. Contacting Our Data Privacy Team

To exercise your rights or submit inquiries regarding this policy, please reach out to our appointed data officer:

Vong Nganthinh — Privacy Office
Park Row 76, WC1V 6AA Manchester, United Kingdom
Email: [email protected]
Telephone: +44 20 7946 5791