1. Introduction
Pocketfolio (CORPORATE ID: 3-102-938342) ("Pocketfolio," "we," "our," or "us") respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, store, and protect your information when you use our website, platform, API integrations, or mobile application (collectively, the "Services").
By using our Services, you agree to the terms of this Privacy Policy and our Terms & Conditions.
If you disagree, please discontinue use immediately.
2. Information We Collect
We collect both personal information (data that can identify you) and non-personal information (aggregated or anonymised data).
a. Information You Provide
- Name, email address, contact details
- Date of birth, nationality, and identification documents (for KYC)
- Wallet addresses or exchange account identifiers
- Exchange account identifiers and trade-related metadata (via API connections)
- Support requests or communication history
b. Information Automatically Collected
- IP address, device ID, browser type, operating system
- Platform usage data (pages visited, session time, click activity)
- Exchange API metadata (account identifiers, order references, execution logs)
- Cookies and similar technologies (see Section 8 below)
c. Third-Party Data
We may receive information from
- Exchange APIs (balances, positions, order history)
- Identity verification providers (for AML/KYC)
- Blockchain analytics and risk monitoring tools
- Marketing or analytics partners
3. How We Use Your Information
We use your data to:
- Provide and maintain our Services
- Support automated strategy execution through user-authorized exchange APIs
- Verify your identity and comply with AML/CFT laws
- Improve and personalise the user experience
- Communicate essential notices, updates, or promotions
- Monitor and prevent fraud, abuse, or unauthorised activity
- Fulfil legal, regulatory, and contractual obligations
4. Legal Basis for Processing (GDPR Compliance)
If you are located in the European Economic Area (EEA), we process your personal data under the following legal bases:
- Contractual necessity (to provide the Services you requested)
- Legal obligation (AML/KYC requirements)
- Legitimate interest (to improve and secure our Services)
- Consent (for marketing communications or optional data sharing)
5. Data Retention
Pocketfolio retains personal data only as long as necessary to:
- Fulfil the purposes described in this Policy
- Comply with legal and regulatory obligations
- Resolve disputes or enforce agreements
When data is no longer required, we securely delete or anonymise it to ensure its confidentiality.
6. Data Sharing and Disclosure
Pocketfolio does not sell user data.
However, we may share limited data with:
- Service providers and partners assisting in operations, KYC, or analytics
- Regulators or law enforcement, if legally required
- Cloud infrastructure providers (for hosting, security, or data processing)
- Affiliated entities under Pocketfolio’s corporate group, where applicable
All third parties are bound by confidentiality and data protection agreements.
7. International Data Transfers
Your information may be processed in countries outside your country of residence, including jurisdictions with different data protection standards.
Pocketfolio ensures adequate safeguards through contractual protections and compliance with applicable data laws.
8. Cookies and Tracking Technologies
Pocketfolio uses cookies and similar tools to improve user experience and analyse performance.
a. Types of Cookies
- Essential cookies: Required for platform functionality (e.g., login sessions)
- Analytics cookies: Measure traffic and usage patterns (e.g., Google Analytics)
- Preference cookies: Remember user settings and preferences
- Marketing cookies: Track engagement for targeted promotions (if consented)
b. Cookie Control
You can disable cookies through your browser settings.
However, some features of the Platform may not function properly if cookies are disabled.
9. Data Security
We employ industry-standard measures to safeguard your data, including:
- AES-256 encryption for stored data
- HTTPS and TLS encryption for data transmission
- Multi-factor authentication
- Strict access controls and audit trails
Despite these measures, no system is entirely secure. You acknowledge and accept the inherent risks of online data transmission.
10. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access and obtain a copy of your data
- Request correction or deletion of inaccurate data
- Object to or restrict data processing
- Withdraw consent (where applicable)
- Data portability
To exercise these rights, contact us at
[email protected].
We may require identity verification before processing your request.
11. Third-Party Links
Our Platform may contain links to third-party websites or tools.
We are not responsible for the privacy practices or content of such external sites.
Please review their policies before sharing personal information.
12. Children's Privacy
Pocketfolio is not intended for minors under 18 years of age.
We do not knowingly collect personal data from individuals under the age of 18.
If you believe a minor has provided us with their data, please contact [email protected] to request its removal.
13. Updates to This Policy
Pocketfolio reserves the right to update this Privacy Policy periodically.
We will notify users of material changes via email or platform notice.
The revised version becomes effective upon posting.
14. Contact Information
For privacy-related questions, contact:
Pocketfolio (CORPORATE ID: 3-102-938342)
Corporate ID: 3-102-938342
(3-102-938342 SOCIEDAD DE RESPONSABILIDAD LIMITADA)
Registered Address: SAN JOSÉ MONTES DE OCA SAN PEDRO, PROVINCE ONE SAN JOSÉ, COUNTY FIFTEEN MONTES DE OCA, DISTRICT ONE OF SAN PEDRO, LOS YOSES, AVENUES EIGHT AND TEN, STREET THIRTY NINE, LY CENTER, San José, Costa Rica
