At Procuritage ("we", "us", or "our"), data privacy, confidentiality, and data minimization are core principles of our platform architecture. This Privacy Policy details the types of personal data we collect, why we collect it, how it is processed and protected, and the statutory privacy rights granted to you under Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR) and the Irish Data Protection Act 2018.
Please read this document carefully to understand our practices regarding your information and how we safeguard your personal data across the Procuritage ecosystem.
1. Identity of the Data Controller
The entity responsible for processing your personal data is:
Procuritage Data Controller
Patrick Street 200, T12 Y9YF Cork, Ireland
Data Protection Officer Email: [email protected]
Direct Phone: +353 1 645 3965
2. Categories of Data We Collect
We restrict data collection to information required to provide, secure, and refine our analytical infrastructure:
- Identification and Contact Details: Full name, verified email address, telephone contact number, country of residence, and communication records when reaching our technical support desk.
- Technical and Telemetry Data: IP addresses, browser specifications, operating system versions, device identifiers, session timestamps, and interaction logs captured during platform sessions.
- Operational and Trading Parameters: Custom signal preferences, configured risk thresholds, algorithmic model selections, and transaction hash logs generated via authorized API links. We never store non-encrypted exchange private credentials.
- Verification Records (KYC/AML): Identity verification documentation, proof of address, and risk profile ratings when mandated by anti-money laundering regulations.
3. Legal Grounds for Processing
In adherence to Article 6 of the GDPR, we process personal data under the following legitimate grounds:
- Contractual Necessity: To deliver algorithmic platform functionality, maintain active user accounts, and execute requested services under our Terms of Service.
- Legal and Regulatory Compliance: To satisfy mandatory European anti-money laundering (AML) directives, combat terrorism financing, and respond to legitimate requests from Irish or EU regulators.
- Legitimate Interests: To optimize system security, detect fraudulent activities, prevent denial-of-service disruptions, and conduct quantitative platform analytics.
- Explicit Consent: Where you have opted in to non-essential analytical cookies or requested specialized technical updates.
4. How We Use and Process Collected Data
Your personal data is deployed exclusively for legitimate business purposes, specifically:
- Delivering real-time algorithmic market insights, portfolio alerts, and dashboard features.
- Verifying user identity and preventing unauthorized access or account takeover attempts.
- Auditing system latency, model response rates, and infrastructure reliability.
- Communicating security patches, service maintenance schedules, and critical administrative notices.
5. Data Disclosure and Third-Party Processors
We do not sell, rent, or trade your personal information. Data transfers to third parties occur strictly under binding Data Processing Agreements (DPAs) that enforce GDPR compliance:
- Cloud Infrastructure Providers: ISO/IEC 27001-certified hosting and computational clusters located inside the European Economic Area (EEA).
- Identity Verification Specialists: Regulated compliance providers performing automated AML/KYC checks.
- Regulatory and Law Enforcement Authorities: Statutory bodies where disclosure is compulsory under Irish or European Union law.
6. Cross-Border Data Transfers
Primary data storage resides within the European Union. In scenarios where service providers operate outside the EEA, transfers are governed by the European Commission's standard contractual clauses (SCCs) alongside supplementary technical encryption measures to ensure data protection equivalent to GDPR standards.
7. Data Retention and Security Protocols
We retain personal information only for as long as necessary to fulfill the operational purposes outlined herein, or to satisfy statutory record-keeping obligations (typically 5 to 7 years for compliance and audit logs). We apply robust technical safeguards including AES-256 encryption at rest, TLS 1.3 encryption in transit, strict role-based access controls, and automated vulnerability audits.
8. Your Statutory Rights Under the GDPR
As a data subject in Ireland and the European Union, you have the right to:
- Request access to your stored personal data and obtain a copy.
- Request correction of inaccurate or incomplete personal records.
- Request erasure ("right to be forgotten") under qualified legal conditions.
- Object to or request restriction of data processing under certain operational contexts.
- Request data portability in a structured, machine-readable format.
- Lodge a complaint with the Data Protection Commission (DPC) of Ireland (www.dataprotection.ie).
9. Updates to This Policy
We periodically update this Privacy Policy to reflect evolving regulatory frameworks or platform enhancements. Updated versions will be posted to this URL with a revised effective timestamp.