Privacy Policy
This Privacy Policy explains how Nomad Vestbrook (“we”, “us”, or “our”) processes, collects, secures, and retains personal data when you interact with our website, software tools, customer support channels, or trading analytics platform. We are committed to upholding stringent standards of confidentiality in full alignment with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the Irish Data Protection Act 2018.
1. Identity of the Data Controller
For the purposes of European data protection legislation, Nomad Vestbrook operates as the primary Data Controller. If you have questions regarding this Privacy Policy or wish to exercise statutory data rights, our appointed Data Protection Liaison can be reached via email at [email protected].
2. Categories of Personal Data Collected
Depending on your relationship with our services, we may collect and process the following categories of information:
- Identification & Contact Data: Full name, verified email address, telephone number, country of residence, and communication history.
- Technical & Telemetry Data: IP addresses, browser fingerprint, operating system, network connection type, hardware specifications, and time-stamped access logs.
- Usage & Interaction Data: Navigation patterns, session durations, clickstream analytics, feature usage statistics, and interface configuration preferences.
- Authentication & Security Records: Two-factor authentication credentials, hashed passwords, session tokens, and encrypted API connection keys used to communicate with trading endpoints.
3. Legal Grounds and Purposes of Processing
We process your personal data strictly under established legal bases as defined under Article 6 of the GDPR:
- Performance of a Contract: To provision account functionality, authenticate authorized users, route analytical signals, deliver software features, and manage customer relations.
- Legitimate Interests: To enhance platform resilience, monitor cyber threats, prevent fraudulent transactions, optimize server load distribution, and conduct technical debugging.
- Legal & Regulatory Compliance: To satisfy tax, accounting, financial crime deterrence, and record-keeping mandates imposed by Irish and EU law.
- Consent: Where you have granted explicit opt-in consent for non-essential analytical cookies or direct marketing communications. Consent may be withdrawn at any time.
4. Cookies and Analytical Tracking
Our website utilizes cookies and similar local storage technologies. Essential cookies are strictly necessary to deliver page navigation, user session persistence, and cryptographic security tokens. Analytical and performance cookies help us analyze aggregate traffic volume and interface interaction patterns. You can modify your browser settings to decline or erase cookies, although certain functions of the platform may experience diminished usability as a result.
5. Disclosure of Data to Third Parties
Nomad Vestbrook will not sell, rent, or trade your personal data. We only share information with vetted service providers who act as Data Processors bound by strict data processing agreements, including:
- Secure cloud infrastructure and database hosting vendors located within the European Economic Area (EEA).
- Identity verification and anti-fraud monitoring partners.
- Customer support service platforms and communications tooling.
- Competent law enforcement or supervisory authorities where mandated by a lawful court subpoena, statutory warrant, or enforceable legal order.
6. International Data Transfers
Where personal data is transferred or accessed outside the European Economic Area, Nomad Vestbrook ensures an adequate level of data protection by utilizing Standard Contractual Clauses (SCCs) approved by the European Commission, verifying binding corporate rules, or relying on jurisdictions recognized as providing adequate safeguards. Appropriate technical and operational safety mechanisms, including end-to-end encryption, are applied to safeguard all international transmissions.
7. Data Retention Periods
We retain personal data only for as long as necessary to fulfill the operational purposes for which it was originally collected, or to comply with statutory statutory retention obligations under Irish commercial law. When data is no longer required, it is systematically deleted, erased, or irreversibly anonymized using secure data destruction protocols.
8. Your Statutory Rights Under the GDPR
Under applicable European data protection statutes, you possess comprehensive rights regarding your personal information, including:
- Right of Access: Request a copy of the personal information held concerning you.
- Right to Rectification: Request correction of inaccurate, incomplete, or out-of-date records.
- Right to Erasure (“Right to be Forgotten”): Request the permanent deletion of your personal data where retention is no longer justified.
- Right to Restriction: Request temporary suspension of data processing pending verification or legal dispute.
- Right to Data Portability: Receive your personal information in a structured, commonly used, machine-readable format.
- Right to Object: Object to processing carried out under the legal basis of legitimate interest or for direct marketing purposes.
- Right to Lodge a Complaint: You have the right to lodge a formal complaint with the Data Protection Commission (DPC) of Ireland, or your local supervisory authority within the EU.
9. Information Security
Nomad Vestbrook implements robust technical and organizational cybersecurity measures. These include transport layer encryption (TLS 1.3), AES-256 database storage encryption, role-based access control, periodic vulnerability assessments, and isolated network perimeters to protect personal data against accidental loss, unauthorized access, destruction, or compromise.
10. Updates to This Policy
We may revise this Privacy Policy periodically to reflect changes in regulatory standards or software operational features. Any revisions will be published directly on this page with an updated revision date. Continued usage of our services after such publication constitutes acknowledgment of the revised terms.