Privacy Policy

1. INTRODUCTION

SVETOVEN MARKETING (“Company”, “we”, “us”, or “our”), a company registered in Sofia, Bulgaria at 70 str. General Yosif Gurko, Sofia 1142, Bulgaria, VAT Number: BG203425745, is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, protect, and share your personal data when you use the SignalVision platform, including all associated services, applications, bots, and tools (collectively, the “Service”).

This Privacy Policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.

2. DATA CONTROLLER

For the purposes of GDPR and other applicable data protection laws, the data controller is:

SVETOVEN MARKETING
70 str. General Yosif Gurko
Sofia 1142, Bulgaria
VAT: BG203425745
Contact: @SignalVisionBot on Telegram

3. PERSONAL DATA WE COLLECT

We collect and process different categories of personal data depending on how you interact with our Service:

3.1 Account and Identity Data
• Telegram User ID: Your unique Telegram identifier, used to identify your account in our system.
• Telegram Username: Your public Telegram username (if set).
• First Name / Last Name: As provided by Telegram and/or entered during the payment process.
• Email Address: Required for invoice delivery and account notifications.
• Language Preference: Detected from your Telegram settings to provide localized content.

3.2 Billing and Tax Data
• Country of Residence: Required for VAT calculation and compliance.
• VAT Number: For EU business customers claiming VAT exemption (optional).
• Payment Transaction Data: Order IDs, payment amounts, cryptocurrency used, payment status, and transaction timestamps.
• Invoice Records: Generated invoices containing your billing information.

3.3 Technical and Trading Data
• Exchange API Credentials: API keys and secrets for connected exchanges (Bybit, Binance). These are encrypted at rest and in transit.
• Trading Configuration: Your risk management settings, leverage preferences, safety rules, and trading mode selections.
• Signal Data: Information about signals you forward to the platform, including signal content, timestamps, and processing status.
• Trade Execution Data: Records of trades executed through the platform, including entry/exit prices, position sizes, and outcomes.
• Performance Metrics: Aggregated statistics about your trading activity (win rate, total trades, etc.).

3.4 Communication Data
• Support Conversations: Messages exchanged with our AI assistant and support team.
• Support Tickets: Issue reports and their resolution history.

3.5 Affiliate Program Data
• Referral Code: Your unique affiliate identifier.
• Affiliate Statistics: Clicks, referrals, conversions, and commission data.
• Payout Wallet Address: Your cryptocurrency wallet address for commission payments.

4. LEGAL BASIS FOR PROCESSING

Under GDPR, we process your personal data based on the following legal grounds:
4.1 Performance of Contract (Article 6(1)(b) GDPR)
We process your data to fulfill our contractual obligations to you, including:
• Providing access to the SignalVision platform and its features;
• Processing your subscription payments;
• Executing trades on your behalf through connected exchanges;
• Providing customer support;
• Managing the affiliate program and processing commission payments.

4.2 Legal Obligation (Article 6(1)(c) GDPR)
We process certain data to comply with legal obligations, including:
• Tax and accounting requirements (invoice generation and retention);
• VAT compliance for EU transactions;
• Responding to lawful requests from authorities.

4.3 Legitimate Interests (Article 6(1)(f) GDPR)
We process certain data based on our legitimate business interests, including:

• Improving and developing the Service;
• Preventing fraud and ensuring platform security;
• Analyzing usage patterns to enhance user experience;
• Protecting our legal rights and interests.

5. HOW WE USE YOUR DATA

We use your personal data for the following purposes:
(a) Service Delivery: To operate and provide the SignalVision platform, including signal processing, trade execution, and performance tracking.
(b) Account Management: To create and manage your account, authenticate your identity, and maintain your preferences.
(c) Payment Processing: To process subscription payments, generate invoices, and manage billing records.
(d) Customer Support: To respond to your inquiries, troubleshoot issues, and provide technical assistance.
(e) Affiliate Program: To track referrals, calculate commissions, and process affiliate payouts.
(f) Service Improvement: To analyze usage patterns, identify issues, and improve platform functionality.
(g) Security: To detect, prevent, and respond to fraud, security threats, and unauthorized access.
(h) Legal Compliance: To comply with applicable laws, regulations, and legal processes.

6. DATA SHARING AND DISCLOSURE

We do not sell your personal data. We may share your data only in the following circumstances:

6.1 Service Providers
We use third-party service providers to help operate our Service:
• Supabase: Database hosting and storage (EU-based servers).
• Telegram: Communication platform for bot interactions.
• NOWPayments: Cryptocurrency payment processing.
• Anthropic (Claude AI): AI-powered customer support assistance.
• n8n: Workflow automation platform.

6.2 Connected Exchanges
When you connect your exchange account (Bybit, Binance), we transmit trade orders to these exchanges using your API credentials. These exchanges have their own privacy policies governing how they handle your data.

6.3 Legal Requirements
We may disclose your data if required by law, court order, or government request, or if we believe disclosure is necessary to protect our rights, safety, or the rights of others.

6.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity. We will notify you of any such change.

7. INTERNATIONAL DATA TRANSFERS

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place:
• Adequacy Decisions: Transfers to countries with adequate data protection laws recognized by the European Commission.
• Standard Contractual Clauses: EU-approved contractual terms ensuring data protection standards.
• Binding Corporate Rules: Where applicable, internal rules approved by data protection authorities.

8. DATA RETENTION

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy:
• Account Data: Retained while your account is active and for 3 years after account deletion.
• Billing and Invoice Data: Retained for 7 years to comply with tax and accounting regulations.
• Trading Data: Retained while your account is active and for 1 year after account deletion.
• Support Conversations: Retained for 2 years for quality assurance and dispute resolution.
• API Credentials: Deleted immediately upon account deletion or when you remove the connection.
• Affiliate Data: Retained for 5 years after the last commission payment for audit purposes.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data:
• Encryption: API credentials and sensitive data are encrypted at rest and in transit using industry-standard encryption protocols.
• Access Controls: Strict access controls limit who can access your data within our organization.
• Secure Infrastructure: Our systems are hosted on secure, professionally managed infrastructure.
• IP Whitelisting: Exchange API access is restricted to our whitelisted server IP addresses.
• Regular Reviews: We regularly review and update our security practices.
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

10. YOUR RIGHTS UNDER GDPR

If you are located in the European Economic Area (EEA), you have the following rights regarding your personal data:

10.1 Right of Access (Article 15 GDPR)
You have the right to obtain confirmation as to whether we process your personal data and, if so, access to that data along with information about how we process it.

10.2 Right to Rectification (Article 16 GDPR)
You have the right to request correction of inaccurate personal data and completion of incomplete personal data.

10.3 Right to Erasure (Article 17 GDPR)
You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for its original purpose or when you withdraw consent.

10.4 Right to Restriction of Processing (Article 18 GDPR)
You have the right to request that we restrict processing of your data in certain circumstances, such as when you contest the accuracy of the data.

10.5 Right to Data Portability (Article 20 GDPR)
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

10.6 Right to Object (Article 21 GDPR)
You have the right to object to processing based on legitimate interests or for direct marketing purposes.

10.7 Right to Withdraw Consent
Where we rely on your consent to process your data, you have the right to withdraw that consent at any time without affecting the lawfulness of processing before its withdrawal.

10.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For Bulgaria, the supervisory authority is the Commission for Personal Data Protection (CPDP) at www.cpdp.bg.

11. EXERCISING YOUR RIGHTS

To exercise any of your rights, please contact us through our support bot @SignalVisionBot on Telegram. We will respond to your request within one month of receiving it. This period may be extended by two further months if necessary, taking into account the complexity and number of requests.

We may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We will not charge a fee to exercise your rights unless your request is clearly unfounded, repetitive, or excessive.

12. COOKIES AND TRACKING

Our primary platform operates through Telegram bots, which do not use cookies in the traditional sense. However, our web dashboard and affiliate tracking may use: • Session Data: Temporary data stored during your session to maintain your logged-in state.
• Affiliate Tracking Pixels: Used to track referrals from affiliate links to attribute commissions correctly.
• Local Storage: May be used in web interfaces to store user preferences locally on your device.

13. CHILDREN’S PRIVACY

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

14. AUTOMATED DECISION-MAKING

Our Service involves automated trade execution based on signals you forward to the platform. This automation is a core feature of the Service that you explicitly request and configure. You maintain full control over:
• Whether to enable automated trading;
• Risk management parameters;
• Which signals to forward;
• The ability to disable automation at any time.
Our AI customer support assistant provides automated responses to support inquiries. Human support escalation is available for complex issues.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:
• Posting a notice in our Telegram bots;
• Sending a notification to your registered email address;
• Updating the “Last Updated” date at the top of this policy.
Your continued use of the Service after such changes constitutes your acceptance of the updated Privacy Policy.

16. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
• Telegram Support: @SignalVisionBot
• Company: SVETOVEN MARKETING
• Address: 70 str. General Yosif Gurko, Sofia 1142, Bulgaria
• VAT Number: BG203425745