Privacy & Policy

Privacy Policy – Altroocorm Ltd
Effective date: 29 August 2025

This page explains how Altroocorm Ltd (“we”, “our”, “us”) collects, uses, stores, and protects personal data when you visit https://altroocorm.com or interact with any of our services (investment planning, portfolio management, newsletters, webinars, etc.).

Why it matters for you:
Understanding our privacy practices helps you feel confident that your personal and financial information is handled securely, lawfully, and transparently.

NOTE: This policy is written for general informational purposes only. For legal advice that applies to your specific situation, consult a qualified solicitor.

1. Who We Are

Company name: Altroocorm Ltd (registered in England & Wales – company number 12345678)
Registered address: 10 Bishopsgate, London, EC2N 4AJ, United Kingdom
Contact email: privacy@altroocorm.com
Data Protection Officer (DPO): Jane Hart – dpo@altroocorm.com

We are a fiduciary-registered wealth-management firm that offers cryptocurrency-focused investment planning and portfolio services. Because we handle sensitive financial data, we adhere to the UK General Data Protection Regulation (UK-GDPR), the Data Protection Act 2018, and relevant regulatory guidance.

2. What Personal Data We Collect

Identity data: Full name, date of birth, national ID/passport number (for KYC)
Contact data: Email address, phone number, mailing address
Financial data: Bank details, crypto wallet addresses, investment preferences
Technical data: IP address, device info, browser, usage data
Marketing data: Newsletter preferences, webinar activity
Communication data: Emails, chats, call recordings

We only collect data that is necessary for specific purposes (data minimization principle).

3. Lawful Basis for Processing

We process your data based on:

• Contract: Managing accounts and delivering services
• Legal obligation: KYC/AML and regulatory compliance
• Legitimate interests: Security, fraud prevention, analytics
• Consent: Marketing emails and non-essential cookies
• Vital interests: Emergency situations (rare)

You can withdraw consent at any time.

4. How We Use Your Data

• Account management: Setup profiles, verify identity
• Service delivery: Execute investments and generate reports
• Compliance: Meet FCA, HMRC, and AML requirements
• Communication: Respond to inquiries and send updates
• Marketing: Send newsletters (with consent)
• Analytics: Improve website and services
• Third-party services: Payments, hosting, CRM tools

We never sell your personal data.

5. International Data Transfers

Some providers are outside the UK (e.g., US, EEA).
We use safeguards such as:

• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules (BCRs)
• Explicit consent where required

6. Who We Share Your Data With

• Regulators (FCA, HMRC)
• KYC providers (e.g., Onfido, Trulioo)
• Custodians (e.g., Fireblocks, Coinbase Custody)
• Payment processors (Stripe, Worldpay)
• Marketing tools (Mailchimp, HubSpot)
• Analytics tools (Google Analytics, Hotjar)
• Advisors (legal, tax)
• Cloud providers (AWS, Azure)

All third parties are bound by strict data protection agreements.

7. Data Retention

• KYC records: Minimum 5 years
• Financial data: 7 years
• Communications: 3 years
• Marketing data: Until consent is withdrawn
• Analytics: 24 months
• Cookies: Up to 30 days

We regularly review and delete unnecessary data.

8. Security Measures

• TLS 1.3 encryption (data in transit)
• AES-256 encryption (data at rest)
• Role-based access control
• Multi-factor authentication (MFA)
• Security audits (ISO-27001, SOC 2)

In case of a breach, we notify authorities within 72 hours.

9. Your Rights

You have the right to:

• Access your data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Transfer your data
• Object to processing
• Avoid automated decision-making

To exercise rights, email: privacy@altroocorm.com

10. Cookies & Tracking

We use cookies for:

• Website functionality
• Preferences
• Analytics (Google Analytics)
• Marketing (ads, retargeting)

You can manage cookies via the banner or browser settings.

11. Third-Party Links

We are not responsible for external websites linked from our platform.

12. Children’s Privacy

Our services are for users aged 18+. We do not knowingly collect children’s data.

13. Policy Updates

We review this policy annually.
Changes will be posted here and emailed if necessary.

14. Contact Us

Data Protection Officer: Jane Hart
Email: support@altroocorm.com
Address: Altroocorm Ltd, 10 Bishopsgate, London, EC2N 4AJ, UK

General inquiries: info@altroocorm.com