Privacy Policy

Effective Date: January 15, 2025
Last Updated: January 15, 2025

At Aptitudex Systems, we understand that your privacy matters deeply. This isn't just another legal document—it's our commitment to being transparent about how we handle your personal information when you use our investment application services.

We've written this policy in plain English because we believe you shouldn't need a law degree to understand how your data is used. If you have questions after reading this, please don't hesitate to reach out to our team.

Quick Contact: If you need immediate clarification about your privacy rights, email us at [email protected] or call +353564441447.
Information We Collect

We collect information in several ways, and we want you to know exactly what that means for your privacy.

Account Information

When you create an account, we collect your name, email address, phone number, and address. This helps us verify your identity and communicate with you about your investments.

Financial Data

For investment services, we need information about your financial situation, investment goals, and risk tolerance. This helps us provide appropriate recommendations.

Usage Information

We track how you use our application—which features you access, when you log in, and how you navigate through our platform.

Device Information

We collect information about the device you use to access our services, including IP address, browser type, and operating system.

Information from Third Parties

Sometimes we receive information about you from other sources, such as credit reporting agencies or financial institutions. This helps us verify your identity and assess your eligibility for certain investment products. We only work with reputable third parties who have their own privacy protections in place.

How We Use Your Information

Your information isn't just sitting in a database—we use it to provide better services and protect your interests.

  • Providing and improving our investment platform services
  • Processing your investment transactions and maintaining your account
  • Communicating with you about your investments and market updates
  • Complying with financial regulations and legal requirements
  • Protecting against fraud and unauthorized access to your account
  • Developing new features based on user needs and feedback
  • Providing customer support when you need assistance

Marketing Communications

We may send you information about new investment opportunities or platform features that we think you'll find valuable. You can opt out of these communications at any time—just click the unsubscribe link in any email or contact us directly.

Legal Basis for Processing

Under Irish and EU data protection laws, we process your personal data based on several legal grounds: your consent, contractual necessity, legal obligations, and legitimate interests in providing financial services.

Your Privacy Rights

Right to Access

You can request a copy of all personal data we hold about you. We'll provide this information within 30 days of your request, free of charge.

Right to Rectification

If any information we have about you is incorrect or incomplete, you can ask us to correct it. We'll update our records promptly.

Right to Erasure

You can request that we delete your personal data, though some information may need to be retained for legal or regulatory purposes.

Right to Data Portability

You can request your data in a structured, commonly used format to transfer to another service provider.

Right to Object

You can object to certain types of processing, including direct marketing. We'll respect your preferences and stop processing for those purposes.

Right to Restrict Processing

In certain circumstances, you can ask us to temporarily suspend processing of your personal data while we address your concerns.

To exercise any of these rights, simply email us at [email protected] with your request. We'll verify your identity and respond within the timeframes required by law.

Data Security and Protection

Protecting your financial information is our top priority. We've implemented multiple layers of security to keep your data safe.

Encryption

All data is encrypted both in transit and at rest using industry-standard AES-256 encryption.

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Access Controls

Only authorized personnel can access your data, and all access is logged and monitored.

Regular Audits

We conduct regular security audits and penetration testing to identify and fix vulnerabilities.

Secure Backups

Your data is backed up securely and regularly to prevent loss and ensure business continuity.

Data Breach Response

While we work hard to prevent security incidents, we have procedures in place to respond quickly if a breach occurs. We'll notify you and relevant authorities within 72 hours as required by GDPR, and we'll provide clear information about what happened and what steps you should take.

Employee Training

All our employees receive regular privacy and security training. They're required to sign confidentiality agreements and follow strict protocols when handling personal data.

Data Retention and Deletion

We don't keep your data forever. Here's how long we typically retain different types of information:

1

Active Account Data

While your account is active, we keep your profile information, transaction history, and communication records to provide ongoing service.

2

Closed Account Data

After you close your account, we retain essential records for 7 years to comply with financial regulations and tax requirements.

3

Marketing Data

If you opt out of marketing communications, we'll remove you from our marketing lists within 30 days but may keep a record of your opt-out preference.

4

Legal Hold Data

If your data is subject to a legal investigation or regulatory inquiry, we may need to retain it until the matter is resolved.

Automated Deletion

We've built automated systems that regularly review and delete data that's no longer needed. This helps ensure we're only keeping information that serves a legitimate purpose.

Sharing Your Information

We're selective about who we share your information with, and we never sell your personal data to third parties.

Service Providers

We work with trusted third-party companies to help us provide our services—things like payment processing, data storage, and customer support. These companies are contractually required to protect your information and can only use it for the specific services they provide to us.

Regulatory Bodies

As a financial services provider in Ireland, we're required to share certain information with regulatory bodies like the Central Bank of Ireland. This helps ensure we're operating within the law and protecting investors.

Legal Requirements

We may disclose your information if required by law, such as in response to a court order, subpoena, or government investigation. We'll always review such requests carefully and only share what's legally required.

Business Transfers

If Aptitudex Systems is acquired by or merged with another company, your personal information may be transferred as part of that transaction. We'll notify you before your information is transferred and becomes subject to a different privacy policy.

International Data Transfers

While we're based in Ireland, some of our service providers may process your data outside the European Economic Area (EEA). When this happens, we ensure your information receives the same level of protection.

Adequacy Decisions

We only transfer data to countries that the European Commission has deemed to have adequate data protection laws, or we use other appropriate safeguards like Standard Contractual Clauses.

Your Rights for International Transfers

If your data is transferred internationally, you still retain all your privacy rights under GDPR. You can contact us for more information about the safeguards we use for international transfers.

Cookies and Tracking Technologies

Like most websites, we use cookies and similar technologies to improve your experience on our platform.

Types of Cookies We Use

  • Essential Cookies: These are necessary for our website to function properly, such as keeping you logged in during your session.
  • Analytics Cookies: These help us understand how you use our platform so we can make improvements.
  • Preference Cookies: These remember your settings and preferences to personalize your experience.

Managing Cookies

You can control cookies through your browser settings, though disabling certain cookies may affect how our platform works for you. Most browsers allow you to refuse cookies or alert you when cookies are being sent.

Updates to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we'll notify you by email or through a prominent notice on our platform.

We encourage you to review this policy periodically to stay informed about how we're protecting your information. The "Last Updated" date at the top of this policy shows when the most recent changes were made.

Notification of Changes

If we make material changes that affect how we use your personal information, we'll provide at least 30 days' notice before the changes take effect. This gives you time to review the changes and decide if you want to continue using our services.

Contact Our Privacy Team

If you have questions about this privacy policy or want to exercise your privacy rights, we're here to help. Our privacy team is committed to addressing your concerns promptly and thoroughly.

Email: [email protected]

Phone: +353564441447

Address: Unit 7, Main St, Donaghcumper, Celbridge, Co. Kildare, Ireland

Response Time: We aim to respond to all privacy inquiries within 3 business days

You also have the right to lodge a complaint with the Data Protection Commission of Ireland if you believe we've mishandled your personal data.