Privacy Policy

At Pevna Uctarna, we are committed to safeguarding your personal data and respecting your privacy rights. This Privacy Policy details the types of personal information we collect, the purposes for which we process it, the legal grounds under which we operate, and the protective measures implemented in full compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Data Controller Information

The data controller responsible for the processing of your personal data on this platform is:

Pevna Uctarna
Registered Address: Park Row 56, WC1V 6AA Manchester, United Kingdom
Contact Email: [email protected]
Telephone: +44 20 7946 3967

2. Categories of Data We Collect

Depending on your interactions with the Platform, we may collect and process the following categories of data:

• Identity Data: Full name, title, date of birth, and identity verification records where required for anti-money laundering (AML) compliance.
• Contact Data: Primary email address, telephone contact number, and billing/mailing address.
• Technical & Telemetry Data: IP address, browser type and version, operating system, device identifiers, time-zone settings, and access log timestamps.
• Usage & Performance Data: Information on how you interact with our algorithmic platform, feature invocation frequency, and diagnostic error reports.
• Transactional Data: Payment transaction identifiers, billing history, and record of subscription entitlements. We do not store full credit card numbers on our servers; payments are processed securely by PCI-DSS compliant third-party payment gateways.

3. Legal Bases for Data Processing

We process your personal data only when lawful bases under Article 6 of the UK GDPR apply, including:

• Contractual Performance: Processing necessary to provide you with access to our automated trading tools, maintain your account, and fulfill our contractual obligations.
• Legitimate Interests: Securing our systems, preventing fraudulent activities, optimizing algorithm performance, and enhancing platform reliability.
• Legal Obligations: Retaining financial and administrative records to comply with statutory accounting, reporting, and anti-fraud mandates in the United Kingdom.
• Consent: Where you have explicitly opted in to receive marketing digests, analytical newsletters, or voluntary platform updates. You may revoke consent at any time.

4. Cookies and Analytical Tracking

The Platform uses essential technical cookies and anonymous analytics to maintain your active session, store preference settings, and ensure security. We do not use third-party behavioral profiling trackers across unrelated web properties. You can configure your browser to block or alert you about cookies, though certain components of our dashboard may fail to function correctly if essential cookies are disabled.

5. Data Disclosure and Third-Party Sharing

Pevna Uctarna does not sell, rent, or trade your personal data to advertisers. We share data only with trusted technical and operational service providers under strict data processing agreements, including:

• Cloud hosting providers and infrastructure vendors located within the UK or European Economic Area.
• Authorized payment service gateways handling payment authorisations.
• Regulatory authorities, law enforcement bodies, or judicial agencies when strictly mandated by enforceable legal orders or statutory UK requirements.

6. Data Security and Storage

We enforce institutional-grade administrative, technical, and physical security measures to protect your personal data from accidental destruction, loss, alteration, or unauthorized disclosure. Data in transit is protected using modern TLS encryption protocols, while sensitive records at rest are secured using AES-256 encryption. We enforce strict role-based access controls for internal personnel.

7. Data Retention

We retain your personal data only for as long as is necessary to fulfill the purposes for which it was originally collected, including the satisfaction of legal, tax, accounting, or regulatory requirements. In general, active account data is retained for the lifetime of your registration plus six (6) years following account termination in accordance with UK statutory limitation periods.

8. Your Statutory Rights

Under the UK GDPR, you have the following enforceable rights concerning your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data when retention is no longer justified by law or contract.
• Right to Restriction: Request the temporary suspension of processing under specific circumstances.
• Right to Data Portability: Obtain your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: Object to processing carried out under the basis of legitimate interests.

To exercise any of these rights, please email our Data Protection team at [email protected]. You also have the right to lodge a formal complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

9. Policy Updates

We may amend this Privacy Policy from time to time to accommodate changes in our platform features, technology stack, or legal obligations. When material modifications take place, we will update the date at the top of this document and notify active users via email or on-platform notification.