Privacy policy
Our beginning
We – referred to as «We» or «Our» – are committed to protecting your personal data and your privacy.
This privacy policy is designed to explain how we collect, store, process and use the information you provide in connection with the website Vortex Momentum (hereinafter «the Website»).
We are committed to following these principles:
Transparency in the collection and processing of your personal data:
We ensure you are always well informed so you can make conscious choices about how your data is used on the website or when you interact with third-party platforms. We use various methods to give you precise and timely information about the processing of your data.
If we need to provide you with specific information, we make sure it is delivered at the right time and place.
We are also available to answer questions or provide clarifications, within the scope of applicable law. You can reach us by email: [email protected]
Processing of personal data only for the purposes stated in this policy:
We may process your information to make the website available, connect you to third-party trading platforms («Services»), improve user experience, develop the platform, protect our rights, carry out administrative processes and fulfil legal requirements.
We also process information to better understand your needs and preferences.
Resources to uphold your rights:
We allocate significant resources to ensure you can exercise your rights as a data subject. You can request access, rectification, erasure or restriction of your information, or request portability at any time. We will respond in accordance with applicable legislation.
Protection of your personal data:
Although we cannot guarantee absolute security, we use modern security methods and measures to protect your information and will continue to improve them.
Our full privacy policy
1. Scope
This policy describes the types of data we collect, how we process them, share them with third parties, and the security measures we apply.
«Personal data» means any information that can be linked to an identified or identifiable person. «Processing» means any operation such as collection, storage, use, sharing, adjustment or deletion.
Our services are intended for the general public and are not directed at persons under 18 years of age. We do not knowingly collect information from minors. If we discover such information has been recorded, we will delete it immediately.
2. When do we collect information?
We collect data when you use our services, visit the website or interact with our channels. Some information you provide yourself, other data is collected automatically through analysis of your activity or via third-party partners.
3. No obligation to provide data – but consequences
You are not required to give us information. However, without certain data we may not be able to offer you all our services or give you full access to the website.
4. What types of information do we collect?
This may include activity logs, IP addresses, timestamps, language, browser type, device information and error logs. Some of this may not directly identify you and is therefore not considered personal data.
Information you provide directly: name, phone number, email address when you contact us or use the platform.
5. Purposes of processing and legal basis
Vortex Momentum processes information only when we have a lawful basis, for example to deliver services, improve experience, protect your data, or fulfil legal obligations.
- You have given consent to the processing of your personal data for specific purposes. This applies when you consciously share information via the website so we can forward it to a third-party trading platform.
- Processing is necessary to pursue legitimate interests pursued by Vortex Momentum or a third party. For example, this may include improving our services or handling legal claims.
- Processing is necessary to comply with a legal obligation to which Vortex Momentum is subject.
If you would like a more detailed explanation of how the processing of your personal data serves legitimate interests for Vortex Momentum or a third party, you can contact us by email at any time.
Below is an overview of why we may process your information, along with the legal bases:
| Purpose | Legal basis | |
| 1 |
To forward your information to a third party upon request to participate in digital or trading activities. We may collect information to forward it if you expressly request this. |
Consent from you to processing for one or more specified purposes. |
| 2 |
To respond to your enquiries and requests Processing of information is necessary to handle any questions you may have about our services. |
Necessary to pursue legitimate interests of the company or third party. |
| 3 |
To comply with legal obligations or orders from authorities We process data to ensure compliance with statutory requirements. |
Necessary to comply with a legal obligation. |
| 4 |
To improve our services This may include analysis of error logs or other reports to optimise the platform. |
Necessary for legitimate interests of the company or third party. |
| 5 |
To prevent fraud and misuse of the services |
Necessary for legitimate interests of the company or third party. |
| 6 |
To perform and maintain operational activities that support the delivery of services This may include back-office functions, business development, strategic planning and internal control. |
Necessary for legitimate interests of the company or third party. |
| 7 |
To perform analyses and statistical assessments We use statistical methods and analyses to make better decisions and improve the platform. |
Necessary for legitimate interests of the company or third party. |
| 8 |
To protect our and third parties’ interests, rights and assets, including legal claims We may process information to defend rights and interests in accordance with applicable law, agreements and terms. |
Necessary for legitimate interests of the company or third party. |
6. Transfer of personal data to third parties
Vortex Momentum may share your information with third-party providers that assist with storage, hosting, IP information, user experience analysis, research and other technical or diagnostic services.
If you request it yourself, we may also transfer certain information to third-party trading platforms. In such cases they will process the information in accordance with their own privacy policies. We may share information with multiple trading platforms.
Vortex Momentum may also share information with affiliated companies and business partners that contribute to improving the quality of our services.
We may disclose information to public authorities if this is necessary to protect our or third parties’ interests, rights or assets, including in connection with legal proceedings.
Information may also be shared with potential buyers, investors or lenders in connection with merger, acquisition, reorganisation or bankruptcy proceedings.
7. Cookies and third-party services
We use certain third-party services, for example analytics and advertising providers. These may use cookies or similar technologies, governed by their own policies.
A cookie is a small text file stored on your device when you visit the website. It can collect information about usage patterns, preferences and technical data, and is used to improve your experience, remember settings and deliver more relevant content.
We may use both session cookies (deleted when the browser is closed) and persistent cookies (that remain on your device until they expire or are manually deleted).
Types of cookies:
| Type | Purpose | Additional information |
| Necessary cookies | These are essential for navigating and using the website’s functions, as well as downloading or streaming content without interruption. | They may contain login status and are deleted automatically when you close the browser (session cookies). |
| Functional cookies | Help the website remember choices and preferences when you return. | Remain on the device until they expire or are manually deleted. |
| Performance and analytics cookies | Used to collect statistics and measure performance so we can improve user experience and test new features. | Collect only anonymised data. Some are deleted at the end of the session, others may remain longer. |
Blocking and deleting cookies
You can change your browser settings to block or delete cookies. Here are links to instructions for the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some website functions may stop working if you block cookies.
NOTE ON ONLINE TRACKING
This service does not currently support «Do Not Track» signals.
8. Storage of personal data
Vortex Momentum will store your information for as long as necessary for the purposes described in this policy, or as required by law, regulation or authority.
If you have given consent, we may share information with third-party trading platforms for up to 12 months, with the possibility of extension after new consent.
We regularly review stored information to ensure it is not kept longer than necessary.
9. Transfer of personal data to third countries or international organisations
Your personal data may be transferred to a third country (outside the EEA) or to international organisations. In such cases Vortex Momentum will implement appropriate safeguards to ensure the information is protected and that you retain your rights and effective legal remedies.
If you are resident in the EEA (European Economic Area), such protective measures will apply if one of the following criteria is met:
- The transfer is to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for personal data, cf. GDPR Article 45(3).
- The transfer is carried out on the basis of a legally binding and enforceable agreement between public authorities or bodies, cf. GDPR Article 46(2)(a).
- The transfer is based on standard data protection clauses adopted by the European Commission, cf. GDPR Article 46(2)(c). You can find these clauses on the European Commission’s websites.
If you would like more information about the safeguards we use when transferring personal data, you can contact us by email: [email protected]
10. Protection of personal data
We use technical and organisational security measures to protect personal data against unauthorised access, alteration, loss or destruction. These measures are adapted to the risk of the processing.
We cannot guarantee absolute security for data transmission over the internet. Vortex Momentum disclaims responsibility for indirect or unintended damage that may arise as a result of data loss or unauthorised access outside our reasonable control.
In some cases we may be legally obliged to share information with public authorities. In that case our control over the protection of the information may be limited.
11. Links to third-party websites
The website may contain links to external websites or applications operated by third parties. Vortex Momentum has no control over these and is not responsible for their processing of personal data. We recommend that you always read their privacy policies before providing information.
12. Your rights regarding personal data
You have the right to request access to the information we process about you, demand rectification of errors, request deletion of data that is no longer necessary, and restrict or withdraw consent to specific processing.
Right of access
You have the right to confirmation of whether Vortex Momentum processes personal data about you. If we do, you have the right to access the information and information about: purposes, types of data, recipients (including in third countries), storage period, rights, right to complain and what safeguards are in place for transfers.
You may receive a copy of the information being processed. If you request additional copies, we may charge a reasonable fee. If the request is sent electronically, you will normally receive the data in a common electronic format.
The right of access must not infringe the rights and freedoms of others. If this occurs, we may limit the access or refuse the request.
Right to rectification
You may request that Vortex Momentum correct inaccurate or incomplete information about you. Where necessary you may supplement with an explanatory statement.
Right to erasure («right to be forgotten»)
You have the right to request deletion of your information when it is no longer necessary to process it, when you withdraw consent, or if the processing is unlawful. We will respond in accordance with applicable law.
Right to erasure («right to be forgotten»)
This right applies if: (a) the personal data are no longer necessary for the purpose for which they were collected; (b) you withdraw consent and there is no other legal basis; (c) you object to processing based on our or third parties’ legitimate interests and there are no overriding legitimate grounds; (d) you object to processing for direct marketing; (e) the data have been processed unlawfully; or (f) the data must be erased to comply with a legal obligation under EU or UK law.
The right does not apply if the processing is necessary (a) to comply with a legal obligation, or (b) to establish, exercise or defend legal claims.
Right to restriction of processing
You may request that we restrict the processing of your information if: (a) you contest the accuracy, for a period that allows us to verify; (b) the processing is unlawful but you want restriction instead of erasure; (c) we no longer need the information but you need it for legal claims; (d) you have objected to the processing, pending assessment of our legitimate interests; (e) the information is processed for direct marketing, including profiling.
If processing is restricted, the information may only be used with your consent, for legal claims, to protect the rights of others or for important public interests.
Right to data portability
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You may also request that the information be transferred directly to another controller if technically possible, and if the processing is based on consent or contract and carried out automatically.
Right to withdraw consent
You may withdraw consent to processing at any time without affecting the lawfulness of processing based on consent before it was withdrawn.
Right to object
You may object to the processing of your information when the processing is based on legitimate interests. This also applies to profiling. We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests and rights, or if the processing is necessary for legal claims.
You may also object at any time to the processing of information for direct marketing, including profiling related to such marketing.
Right to lodge a complaint with a supervisory authority
You may lodge a complaint with the Information Commissioner’s Office or another supervisory authority in the UK if you believe that the processing of your personal data violates GDPR.
We will respond to requests to exercise rights within one month of receipt. If necessary the deadline may be extended by up to two months, depending on the complexity of the case and the number of requests. You will then be informed of the reason for the delay.
Information related to the exercise of rights is provided free of charge, unless the request is manifestly unfounded or excessive. In such cases we may charge a reasonable fee or refuse the request.
Vortex Momentum may request additional information to confirm your identity if we have reasonable grounds to doubt it.
13. Updates to this policy
We reserve the right to update this privacy policy. Changes will be published on the website, and material updates will be communicated clearly. Unless otherwise stated, the changes take effect when the updated policy is published.