PRIVACY POLICY:

Last Updated: 30/01/2025

This Privacy Policy outlines how we collect, use, share, and protect your personal data when using the website braintechfinance.com and the web application app.braintechfinance.com (hereinafter referred to as the "Services").

Data Controller

1.1 Current Data Controller

The data controller is currently Braintech Finance. For any questions or requests regarding personal data processing, you can contact us at the following email address:

info@braintechfinance.com.

Personal Data Collected

We collect the following personal data from users:

Personal and Contact Information: Name, surname, date of birth, phone number, email.

Service Data: MT4 account number, account balance, transaction history via Braintech Finance's automated strategies, active strategy IDs, risk percentage, and capital allocation percentage set for each active strategy.

These datas are necessary to provide the Services and to create and manage the user account.

Legal Basis for Processing

The processing of your personal datas is based on several legal grounds under Regulation (EU) 2016/679 (“GDPR”):

Contract Performance (Art. 6(1)(b) GDPR): Personal datas (such as name, surname, date of birth, phone number, email) are necessary for registration, use of the Services, and fulfilling the related contractual obligations.

Consent (Art. 6(1)(a) GDPR): The user gives consent by expressly accepting this Privacy Policy and the Terms & Conditions during registration. Consent, where required by law (e.g., for the use of certain non-technical cookies), is voluntary and can be revoked at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

We currently do not send newsletters or commercial communications; should we introduce marketing purposes in the future, specific optional consent will be requested.

Data Use Methods and Purposes

4.1 Provision of Services

Management and maintenance of the user account.

Display and management of the MT4 account number, balance, and transaction history.

Sending of functional and technical emails (e.g., registration confirmation, password reset).

4.2 Internal Analysis and Improvement

We use the datas (in aggregate or, where possible, anonymized form) to improve user experience and resolve any technical issues.

4.3 Cookies and Google Analytics

We use technical cookies necessary for the platform's operation on our website.

We also use Google Analytics in anonymized mode, which collects aggregated browsing data (such as geographical area, pages visited) without directly identifying the user. Further details may be published in a dedicated cookie policy in the future. We do not carry out personal profiling for commercial or advertising purposes.

Data Sharing and Transfer

5.1 Third-Party Providers

The collected data may be processed on systems managed by third-party providers (e.g., hosting services, Microsoft, Google), possibly located in countries outside the European Union.

5.2 Standard Contractual Clauses (SCC)

To ensure an adequate level of protection, in case of data transfers outside the EU, we apply the Standard Contractual Clauses (SCC) provided by the GDPR, as well as additional security measures, to ensure processing in accordance with European standards.

5.3 Legal Obligations

In exceptional cases, we may share data with public or judicial authorities if required by applicable law.

Data Security

6.1 Protection Measures

We implement physical, logical, and organizational security measures (encryption, network protections, staff training, etc.) to prevent unauthorized access, disclosure, or loss of personal data.

6.2 Restricted Access

Access to personal data is limited to authorized personnel and collaborators who need it to fulfill the stated purposes.

User Rights

Under the GDPR, the user has the right to:

Access their personal data.

Rectify inaccurate or incomplete data.

Delete data (“right to be forgotten”), except where processing is required by law.

Restrict processing in cases outlined by Art. 18 GDPR.

Object to processing, when permitted.

Request data portability to another controller, if technically feasible.

To exercise these rights, the user can contact us at:

info@braintechfinance.com

with the subject “Privacy Rights Exercise Request”.

A response will be provided within 1 month of the request, unless there are exceptional complexities.

7.1 Right to Lodge a Complaint

If the user believes that their personal data has been processed in violation of data protection laws, they have the right to file a complaint with the Data Protection Authority (www.garanteprivacy.it), without prejudice to any other administrative or judicial remedy.

Data Retention Period

We retain the user's personal data for the duration of the contractual relationship or as long as the account remains active. Upon termination of the service, we will delete or anonymize the data, unless longer retention is necessary to comply with legal or fiscal obligations.

No Direct Marketing

We do not currently send any type of commercial communication or newsletters to our users. Automated emails are related solely to registration, password recovery, or essential service communications for the proper functioning of the platform.

If direct marketing activities are introduced in the future, separate and specific consent will be requested from the user.

Changes to the Privacy Policy

Any changes to this Privacy Policy will be communicated to registered users via email or made public on our website. We encourage users to periodically review this page to stay informed about any changes.

For any questions or clarification regarding this Privacy Policy, you can contact us at:

info@braintechfinance.com