Privacy Policy

Last Updated: February 2, 2026

lorviatero ("Company," "we," "us," or "our") is dedicated to protecting and respecting your personal privacy. This Privacy Policy details the types of personal data we collect, how it is handled, stored, and protected, and sets out your statutory rights under the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

1. Data Controller

For the purposes of applicable data protection legislation, the data controller is lorviatero, with administrative premises located at High Holborn 66, EC3M 4AJ Edinburgh, United Kingdom. You can address any data protection queries directly to our appointed Data Protection Lead at [email protected].

2. Categories of Information We Collect

We process information necessary to maintain platform operational integrity, provide services, and protect against malicious cyber activity:

• Identity and Contact Data: Includes your name, email address, telephone number, and communication preferences when you correspond with us.
• Technical Data: Includes internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and hardware identifiers.
• Platform Usage Data: Details of your interactions with our algorithmic interfaces, feature navigation, simulation runs, calculation queries, and telemetry diagnostics.
• Market Telemetry: Anonymized trade simulation logs and execution preferences configured on user dashboards.

3. Legal Bases for Processing

Under UK GDPR, we rely on the following lawful bases to process your information:

• Performance of a Contract: Necessary for delivering the software features, platform operations, and support requested by you.
• Legitimate Interests: Necessary for maintaining platform security, detecting fraud, improving algorithmic infrastructure, and preventing unauthorized network intrusions.
• Legal Obligations: Compliance with applicable statutory requirements, anti-money laundering regulations, or law enforcement requests.
• Consent: Where you have granted explicit consent for specific informational or non-essential analytical communications.

4. How We Use and Share Information

lorviatero strictly refrains from selling, leasing, or monetizing personal data. We disclose your data only to verified entities under rigorous confidentiality obligations, including:

• Trusted cloud infrastructure providers, cybersecurity monitors, and managed server hosting services.
• Professional legal, financial, and compliance auditors assisting our governance.
• Competent judicial authorities or regulatory agencies when required by statutory mandates or court orders.

5. International Data Transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area, we implement robust safeguard mechanisms. These include the UK International Data Transfer Agreement (IDTA), standard contractual clauses approved by the Information Commissioner’s Office (ICO), and supplementary technical encryption to guarantee equivalent standards of protection.

6. Data Security and Retention

We implement end-to-end cryptographic protocols, zero-trust network architectures, and routine vulnerability audits to shield your records against unauthorized access, loss, or disclosure. Personal information is retained only for the duration necessary to satisfy operational, regulatory, or tax reporting requirements, after which it is securely erased or irreversibly anonymized.

7. Your Statutory Rights

Under United Kingdom data protection laws, you possess substantial statutory rights:

• Right of Access: Request confirmation and copies of personal data held regarding you.
• Right to Rectification: Request correction of inaccurate or incomplete personal records.
• Right to Erasure ("Right to be Forgotten"): Request deletion of personal data where retention lacks a continuing lawful basis.
• Right to Restrict Processing: Request suspension of data processing pending verification or legal dispute.
• Right to Data Portability: Obtain your digital records in a structured, machine-readable format.
• Right to Object: Object at any time to processing predicated on our legitimate business interests.

You also maintain the right to lodge a complaint with the UK supervisory body, the Information Commissioner's Office (ICO), via ico.org.uk.

8. Changes to This Privacy Policy

We may update this policy periodically to reflect operational refinements or legislative amendments. Any revisions will be published immediately on this page with an updated revision date. Continued engagement with the Platform constitutes your ongoing acknowledgment of these terms.