Privacy Policy

Last updated 18.11.2024

Introduction

This Privacy Policy governs the manner in which Smartpositions collects, uses, maintains and discloses information collected from users (each, a "User") of the http://www.smartpositions.io website ("Site"). This privacy policy applies to the Site, it’s subdomains and all products and services offered by SmartPositions (a trade name of BlockTradingSaas B.V.) and it’s mother company BlocktradingSaas B.V.

Personal Identification Information

We collect personal data when Users:
- Visit our Site
- Register or place orders
- Fill out forms or subscribe
- Engage with our services

We collect:
- Name
- Email address
- Mailing address
- Phone number

Users may browse anonymously. We only collect personal data voluntarily submitted, though this may limit access to certain features.

Legal basis for processing

We process your personal data based on one or more of the following legal grounds:
- Performance of contract when providing our services
- Legal obligations for financial and tax requirements
- Legitimate business interests for improving our services
- Your explicit consent for marketing communications and cookies

Each type of data processing is based on specific legal grounds as required by GDPR Article 6.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email and by posting a notice on our website.
Your Privacy Rights and Choices

Your GDPR Rights
You have the right to:
- Access or correct your data
- Request erasure ('right to be forgotten')
- Restrict processing
- Request data portability
- Object to processing
- Withdraw consent

Contact legal@smartpositions.io to exercise these rights.

Account Management

- Deactivate your account via Settings → "Deactivate your account"
- 30-day recovery period before permanent deletion
- All data, subscriptions, and configurations will be deleted
- Change username/email without account deactivation

Data Collection Technologies

We use cookies and similar tracking technologies to analyze site usage and improve your experience.

These technologies collect:
- Usage data (pages visited, time spent, links clicked)
- Device information (browser type, operating system)
- IP address

Your Choices

- Accept or decline cookies through our consent banner
- Adjust browser settings to manage cookies
- Opt out of marketing tracking via your account preferences

Note: Some site features may not function properly if tracking is disabled.

Marketing and Analytics

We use tracking data to:
- Analyze site performance
- Remember your preferences
- Show relevant advertisements on other websites
- Measure marketing effectiveness

You can opt out of marketing tracking while maintaining essential site functionality. For detailed cookie information, see our Cookie Policy at smartpositions.io/cookies.

Data Sharing and Protections

Data recipients, we share your data with:
- Payment processors (for transactions)
- Trade execution services (for trades)
- Cloud service providers (for hosting)

All third-party providers comply with relevant data protection regulations and security standards.

Security

- We use SSL encryption for data transmission
- We implement industry-standard security measures
- Payment data is handled by PCI-DSS compliant processors
- We do not store your payment card details

Data Breaches

If a breach occurs, we will:
- Notify authorities within 72 hours
- Inform affected users promptly if high risk
- Provide details about the breach and remediation steps

Contact our Data Protection Officer at dpo@smartpositions.io for security concerns.

Third-party Websites

Our Site may contain links to other websites. We are not responsible for the privacy practices or content of such websites. When you leave our Site, we encourage you to read the privacy policy of each website you visit. This privacy policy applies solely to information collected by SmartPositions.

Changes to this privacy policy

Smartpositions has the discretion to update this privacy policy at any time. When we do, revise the updated date at the bottom of this page,. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

International Data Transfers

We may transfer your personal data to countries outside the European Economic Area (EEA).

When we do so, we ensure appropriate safeguards are in place through:
- Standard contractual clauses approved by the European Commission
- Adequacy decisions issued by the European Commission
- Other valid transfer mechanisms under GDPR Article 46

Data Protection Officer

For questions about our privacy practices or to exercise your privacy rights, you can contact our Data Protection Officer at:

Prins Willem-Alexanderlaan 415
7311SX Apeldoorn
The Netherlands
Email: dpo@smartpositions.io