Privacy Policy

Responsible handling of your personal data is of the highest importance to Promenade Earnd. We process information transparently, for defined purposes and in accordance with applicable law – in particular the GDPR. This policy explains which data we collect, why we use it, how long we retain it and how we protect it.

1. Data controller

The data controller for your personal data under the GDPR is the operator of the Promenade Earnd website and platform. Relevant contact details and further information can be found in the legal notice on this site. For privacy questions you can contact our Data Protection Officer.

2. Data collected

We collect and process only the data necessary to provide our services, fulfil legal obligations and ensure secure operation of the platform. These include in particular:

Identity data: first and last name, date of birth (for age and identity verification).
Contact details: email address, telephone number (optional), country of residence and address if applicable.
Account and transaction information: payment details, deposits and withdrawals, transaction history.
Technical and usage data: IP address, browser type, device information, access times, log data.
Verification documents: identity documents, proof of address or other documents for KYC/AML checks (only when legally required).

Special categories of personal data (e.g. health data or religious beliefs) are generally not collected unless legally required or provided with your explicit consent.

3. Collection methods

Your data is collected via various secure channels:

Directly from you: for example when registering, updating your profile, submitting verification documents or using the contact form.
Automatically: e.g. via cookies, server logs, analytics tools and device information during platform use.
From third parties: such as payment providers (for deposits and withdrawals), identity verification services (KYC/AML) or – with your consent – social login services.

4. Purposes of processing

We process your personal data only for clear and legitimate purposes:

Setting up, managing and providing your user account and platform features.
Processing and securing payment transactions (deposits and withdrawals).
Personal customer support and handling your enquiries.
Fulfilling legal and regulatory obligations (e.g. KYC, AML and tax requirements).
Ensuring IT security and protection against fraud, abuse and attacks.
Optimising the user experience and developing the platform further.
Marketing and informational purposes – only based on your explicit consent.

5. Legal bases for processing

Performance of a contract or pre‑contractual measures (Art. 6(1)(b) GDPR).
Compliance with legal obligations (Art. 6(1)(c) GDPR), e.g. related to anti‑money laundering.
Protection of legitimate interests (Art. 6(1)(f) GDPR), e.g. to ensure platform stability and security.
Your explicit consent (Art. 6(1)(a) GDPR), for example for marketing or optional additional features.

6. Data sharing

Your data is shared only when necessary and exclusively with carefully selected partners:

Payment service providers and banks to process deposits and withdrawals.
Specialised providers to perform KYC/AML checks.
IT and cloud providers with whom we have data processing agreements.
Analytics and security tools that – where possible – work with anonymised or pseudonymised data.
External advisors (e.g. lawyers, tax advisors) within the scope of legal obligations.
Authorities or courts when there is a legal obligation or rights must be enforced.

Your personal data is not transferred or sold to third parties for commercial purposes.

7. International data transfers

In some cases we use providers (e.g. cloud or analytics services) outside the European Economic Area. In such cases we take adequate safeguards, such as EU standard contractual clauses, binding corporate rules or adequacy decisions by the European Commission, to ensure an appropriate level of data protection.

8. Data security

To protect your data we implement extensive technical and organisational measures:

Encrypted data transmission using current protocols (e.g. TLS 1.3+).
Strong encryption of sensitive data at rest (e.g. AES‑256).
Regular security audits, penetration tests and reviews by independent experts.
Continuous monitoring of systems for suspicious activity and attack attempts.
Strict access controls and role‑based permissions within the team.
Holding client funds in segregated accounts with regulated partner institutions.

Absolute protection against all risks cannot be technically guaranteed, but we reduce such risks to a very low level with our measures.

9. Storage period

We retain your data only as long as required for the stated purposes or as legally required:

For the duration of the active use of your account and the contractual relationship.
After account closure for the legally required retention period (e.g. 5–10 years for tax and regulatory purposes).
For consent‑based processing (e.g. marketing) until you withdraw your consent.

When data is no longer needed we delete it securely or anonymise it.

10. Your rights as a data subject

You have extensive rights regarding your personal data. In particular you can:

Request information about which data we hold about you.
Request correction of inaccurate or completion of incomplete data.
Request deletion of your data, provided no legal retention obligations apply.
Request restriction of processing in certain circumstances.
Receive your data in a structured, commonly used and machine‑readable format (data portability).
Withdraw any given consents at any time with effect for the future.
Lodge a complaint with a competent data protection supervisory authority.

11. Cookies and similar technologies

We use cookies and similar technologies to ensure platform functionality, analyse usage and optimise the experience. Essential cookies are always active, while analytical and marketing cookies require your prior consent. Further details can be found in our Cookie Policy.

12. Changes to this Privacy Policy

We may update this policy from time to time – for example due to legal changes, regulatory requirements or new features. The updated version is always available on the website. We will inform you of relevant changes by email or directly on the platform.

13. Contact for data protection matters

If you have questions about data protection, this policy or exercising your rights, contact us by email at [email protected] or via the site's contact form. Our Data Protection Officer will review your request and respond promptly.

By using Promenade Earnd you confirm that you have read this Privacy Policy and accept its contents.

Thank you for your trust. Protecting your data and privacy remains a central priority for us.