By using the services available on ALTIVOR INSTITUTE altivor.institute (the "Platform"), ALTIVOR INSTITUTE, as the Data Controller, processes the personal data of users (referred to as "User" or "you"). This Privacy Policy sets out the principles governing the processing of personal data, explains how data is handled within a controlled and secure analytical environment, and informs you of the rights afforded to you under Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR"). Please read this document carefully before using the Platform.
The Data Controller responsible for the processing of personal data is:
The Data Controller is responsible for processing personal data in accordance with applicable law, including the GDPR, and for implementing appropriate technical and organisational measures to ensure an adequate level of data protection.
Personal data means any information that enables the direct or indirect identification of a natural person. We collect data through the following means:
When using the Platform, we may collect the following categories of data:
Providing personal data is voluntary; however, certain data is required in order to access specific features or services.
Certain data is collected automatically when you access the Platform:
In certain circumstances, data may be received from:
The Data Controller processes only the data necessary to achieve the purposes described in this Policy and does not process personal data beyond what is required.
Personal data is processed for the following purposes:
Enabling the creation and maintenance of a user account and access to Platform functionality.
Legal basis: Performance of a contract Art. 6(1)(b) GDPRIncluding access to educational content, participation in training programmes and challenges, access to trading tools, and management of the user dashboard.
Legal basis: Performance of a contract Art. 6(1)(b) GDPRProcessing of transactions and maintenance of financial records in accordance with applicable accounting obligations.
Legal basis: Performance of a contract & legal obligation Art. 6(1)(b)(c) GDPRResponding to enquiries, resolving issues, and sending operational communications relating to account security, service continuity, product functionality, or material policy updates.
Legal basis: Legitimate interests and, where necessary, performance of a contract Art. 6(1)(b)(f) GDPRSending newsletters and promotional communications regarding new features, products, events, or other commercial updates where the User has opted to receive them.
Legal basis: Consent Art. 6(1)(a) GDPRAnalysis of Platform usage to improve functionality, performance, system reliability, and user experience within the Platform environment.
Legal basis: Legitimate interests Art. 6(1)(f) GDPREnsuring the integrity of the Platform, detecting and preventing unauthorised access, abuse, and fraudulent activity.
Legal basis: Legitimate interests Art. 6(1)(f) GDPRPersonal data is processed and stored within a controlled and secured information environment. The Data Controller applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction, including:
Certain data processed within the Platform including trading records, performance metrics, and behavioural annotations may be considered sensitive from an operational and strategic perspective. The Data Controller implements enhanced safeguards proportionate to such processing in order to preserve the confidentiality and integrity of that data.
Notwithstanding the above, no data transmission or storage system can be guaranteed to be 100% secure. Users are encouraged to maintain the confidentiality of their account credentials.
Personal data is retained for the period necessary to fulfil the purposes for which it was collected, in particular:
Upon expiry of the applicable retention period, personal data is permanently deleted or irreversibly anonymised.
Personal data may be disclosed to third parties engaged by the Data Controller, including:
All third parties process personal data exclusively on the basis of data processing agreements and in compliance with applicable data protection law. ALTIVOR INSTITUTE does not sell personal data to any third party.
Where personal data is transferred outside the European Economic Area (EEA), such transfers are carried out exclusively with appropriate safeguards as required by the GDPR, in particular on the basis of:
Users may request information regarding the specific safeguards applicable to any such transfer by contacting the Data Controller at the address provided in Section 1.
Subject to applicable law, you have the following rights in respect of your personal data:
To exercise any of the above rights, please contact the Data Controller at contact@altivor.institute. The supervisory authority in Poland is the President of the Personal Data Protection Office (UODO).
In the course of using the Platform, users may enter data relating to their trading activity, including:
Trading and performance-related data entered by the User constitutes analytical and behavioural data used within the Platform for the primary purpose of supporting process evaluation, execution consistency analysis, and structured performance tracking.
Where necessary, such data may also be processed to preserve account security, investigate abuse, maintain Platform integrity, and comply with applicable legal obligations in accordance with this Policy.
Under no circumstances is User trading or performance data made publicly available, shared, or disclosed to third parties for benchmarking, ranking, or promotional purposes without explicit and informed consent.
The Platform uses cookies and similar tracking technologies within a controlled preference framework. Depending on the applicable settings, the following categories may be used:
Optional analytics and marketing cookies are used only in accordance with the User's preferences, and marketing cookies require explicit consent where such consent is required under applicable law.
You may modify your cookie preferences at any time through your browser settings or via the Cookie Settings option in the footer of any page. Disabling strictly necessary cookies may affect the functionality of the Platform, while disabling optional cookies will not prevent essential access.
The Data Controller does not make decisions that produce legal effects or similarly significantly affect users solely on the basis of automated processing of personal data, unless such processing is required by law, is necessary for the performance of a contract, or is carried out with the User's explicit consent.
The Platform is intended exclusively for individuals who have reached the age of majority in their country of residence. The Data Controller does not knowingly collect or process the personal data of individuals under the age of 18. If the Data Controller becomes aware that personal data of a minor has been collected, such data will be deleted promptly. If you believe that such data has been inadvertently collected, please contact us at contact@altivor.institute.
The Data Controller reserves the right to amend this Privacy Policy in the event of changes to applicable law or to the operation of the Platform. The current version of the Privacy Policy will always be accessible on the Platform. Continued use of the Platform following the publication of any amendment constitutes acceptance of the revised Policy. Where changes are material, users will be notified through appropriate channels.