Privacy Policy

1. Who is responsible

The data controller is Bold Reckonavence Digital Services — demo entity, trading as Bold Reckonavence, with its office in Manchester, United Kingdom. Contact for everything in this policy, including requests and complaints: [email protected].

2. Data we collect when you browse

Browsing the site collects a small technical footprint: the pages requested, approximate region derived from your IP address, browser type and referrer. This feeds security monitoring, the currency shown by the calculator and aggregate, non-identifying usage statistics. Where analytics is enabled, a cookie identifier is used under the consent choice you are offered; with the measurement identifier left unconfigured, nothing is sent to any third party.

3. Data we collect when you register

Creating an account collects your name, email address and phone number, plus the fact and time of your adviser calls. If you apply for a role through the careers form, the details you submit are handled as a recruitment record and kept only for that process unless you ask otherwise.

4. Identity verification data

Before trading and withdrawal access, we collect a photo identity document, a liveness selfie and, where needed, address evidence, as the law requires. This material is stored encrypted, access is limited to compliance functions, and retention follows the anti-money-laundering rules described on the AML / KYC page: five years after the relationship ends, and no longer.

5. Transaction and platform data

Using the service generates records of deposits, withdrawals, watchlists, alerts and decisions, together with the audit log entries described on the security page. These records exist to operate your account, meet our legal obligations and resolve any dispute about what happened and when.

6. Marketing data

If you opt in, we store your email with a marketing flag and send service news and market commentary. Every message carries an unsubscribe link that works immediately, and withdrawing consent never affects your access to the platform. We do not sell or rent your contact details to advertisers, and we do not run advertising profiles on you.

7. Legal bases for processing

• Contract: running your account, payments, the analysis you signed up for.
• Legal obligation: identity verification, AML monitoring, record keeping, tax-related record provision to you.
• Legitimate interests: site security, fraud prevention, service improvement using aggregated data.
• Consent: optional marketing, optional cookies beyond the strictly necessary.

Where we rely on legitimate interests, the interest is the secure and honest operation of a financial service, and we have weighed it against your expectations as a user of that service.

8. Who we share data with

We share the minimum necessary, for stated purposes only: payment providers to process your deposits and withdrawals; the verification provider that checks your documents; the exchanges you connect, under their own terms when you use keys you created; professional advisers and auditors under confidentiality; and authorities where the law requires reporting. Every recipient is bound by contract to process only for the purpose received, and no recipient may use your data for its own marketing.

9. International transfers

Some processors, including major cloud and verification services, operate outside the United Kingdom. Where data leaves the UK, transfers rely on UK adequacy regulations or, failing those, the International Data Transfer Agreement or equivalent clauses, with supplementary measures where needed. We keep the list of destinations current and review it annually.

10. How long we keep data

11. Your rights

You have the right to access your data, to correct it, to erase it where no legal obligation retains it, to restrict or object to particular processing, to data portability for records you provided, and to withdraw consent at any time where consent is the basis. Requests go to [email protected], are answered within one month, and are free unless manifestly excessive.

12. When we may refuse a request

Verification and AML records cannot be erased while the law requires us to hold them, and data needed for an open complaint or legal claim may be retained until it closes. Where we refuse in whole or part, we say which part and why, and we tell you that you may complain to the Information Commissioner's Office, the UK supervisory authority for data protection.

13. Cookies

Strictly necessary cookies keep your session secure. Optional analytics cookies, if enabled by the site operator, measure usage in aggregate. No advertising cookies are set by us. You can block or delete cookies in your browser; the site keeps working, with the loss of convenience features only.

14. Security of your data

Measures include TLS for data in transit, encryption at rest, role-limited access, audit logging of administrative actions and the account protections described on the security page. No system is perfectly secure, so we also maintain an incident process: containment, investigation, and notification to you and to the regulator where the law requires it.

15. Automated decisions

The platform's analysis is automated in the sense that software calculates it, but it makes no automated decisions with legal effect on you. Monitoring for AML purposes may pause a payment for human review; a pause is a checkpoint, not a decision, and a compliance person always concludes it.

16. Children

The service is for adults. We do not knowingly collect data from anyone under 18, and if we learn that we have, we delete it promptly. If you believe a child has registered, write to [email protected].

17. Changes and complaints

This policy may change with the service or the law; material changes are emailed to your registered address before they take effect. Complaints about data handling go first to the email above under the process on our complaints page, and then, if unresolved, to the Information Commissioner's Office at ico.org.uk.