purepofo.com
Privacy Policy
Last updated: September 26, 2025
We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, platform, and services (collectively the “Services”).
- 1. Introduction
- 1.1. Identity:
- This Privacy Policy apply to the use of the service purepofo, provided and operated by Dr. Hazem Hamoudia Management Consulting, based in Munich, Germany (‘we’, ‘our’, ‘us’).
- 1.2. Regulation:
- We comply with the General Data Protection Regulation (GDPR) and all other applicable data protection laws in Germany and the European Union.
- 1.3. Data Controller:
- The controller responsible for processing your personal data within the meaning of the GDPR is Dr. Hazem Hamoudia Management Consulting, Munich, Germany.
- 2. Personal Data We Collect
- 2.1. Account Data:
- Name, email address, password, and account preferences you provide when creating or managing your account.
- 2.2. Payment Data:
- Billing details, payment method, and transaction history (securely processed by third-party providers; purepofo does not store full card details).
- 2.3. Usage Data:
- Log files, IP address, device identifiers, browser type, operating system, and activity on our platform.
- 2.4. Communication Data:
- Any communication you send us, such as support inquiries, feedback, or messages.
- 3. Legal Bases for Processing
- 3.1. Contractual necessity:
- Processing is required to provide and manage your use of our Services (Art. 6(1)(b) GDPR).
- 3.2. Consent:
- Where you give explicit consent, e.g., for receiving newsletters or using cookies (Art. 6(1)(a) GDPR).
- 3.3. Legal obligations:
- Compliance with tax, accounting, and regulatory requirements (Art. 6(1)(c) GDPR).
- 3.4. Legitimate interests:
- Improving our Services, ensuring IT security, fraud prevention, and limited direct marketing (Art. 6(1)(f) GDPR).
- 4. How We Use Your Data
- 4.1. Service provision:
- To operate, maintain, and provide our Services, including account management and transactions.
- 4.2. Communication:
- To respond to your inquiries, notify you of service updates, and provide support.
- 4.3. Marketing:
- With your consent, we may send newsletters and promotional materials. You may opt-out anytime.
- 4.4. Security and compliance:
- To prevent fraud, misuse, and to comply with legal requirements.
- 5. Data Sharing and Disclosure
- 5.1. Service providers:
- We share data with trusted third-party providers for hosting, analytics, and payment processing, under strict confidentiality obligations.
- 5.2. Legal requirements:
- We may disclose your data when required by law, regulation, or court order.
- 5.3. Business transfers:
- In case of a merger, acquisition, or sale of assets, your data may be transferred as part of that process.
- 6. International Data Transfers
- 6.1. Safeguards:
- If your data is transferred outside the EEA, we ensure adequate safeguards such as EU Standard Contractual Clauses or adequacy decisions.
- 7. Data Retention
- 7.1. Retention periods:
- We retain account data as long as your account is active, billing data for up to 10 years (per German law), and communications for up to 3 years after resolution.
- 8. Your Rights under GDPR
- 8.1. Access and rectification:
- You may request a copy of your personal data and correct inaccuracies (Art. 15–16 GDPR).
- 8.2. Deletion and restriction:
- You may request deletion or restriction of your data under certain conditions (Art. 17–18 GDPR).
- 8.3. Data portability:
- You may request your data in a structured, machine-readable format (Art. 20 GDPR).
- 8.4. Objection:
- You may object to processing for marketing or based on legitimate interests (Art. 21 GDPR).
- 8.5. Withdrawal of consent:
- Where processing is based on consent, you may withdraw it anytime without affecting prior lawful processing (Art. 7(3) GDPR).
- 9. Broker Account Connections
- 9.1. Authorization:
- When you choose to connect your Broker account (e.g., Alpaca) with purepofo, you explicitly authorize us to access certain account data (such as portfolio holdings, transaction history, and account identifiers) and, where applicable, to transmit your trading instructions to your Broker at your direction.
- 9.2. Connection:
- The connection your Broker account is established using secure authentication protocols (OAuth2). We do not store your Broker login credentials. The access and processing of such data is based on your explicit consent (Art. 6(1)(a) GDPR) and for the performance of our Service features requested by you (Art. 6(1)(b) GDPR).
- 9.3. Revocation:
- You may revoke this authorization at any time by disconnecting your Broker account from purepofo. Upon revocation, we will no longer access or process data from your Broker account.
- 10. Data Security
- 10.1. Security measures:
- We use encryption, firewalls, secure servers, and access controls to protect your data.
- 11. Cookies and Tracking
- 11.1. Use of cookies:
- We use cookies to improve your browsing, analyze site traffic, and personalize content. You can manage cookies in your browser settings.
- 12. Children’s Privacy
- 12.1. Minors:
- Our Services are not directed to individuals under 18. We do not knowingly collect such data. If discovered, it will be deleted promptly.
- 13. Changes to this Policy
- 13.1. Updates:
- We may update this Privacy Policy. Significant changes will be communicated via email or service notifications.
- 14. Contact & Complaints
- 14.1. Contact:
- For questions, contact us at support@purepofo.com.
- 14.2. Supervisory authority:
- You may also lodge a complaint with the Bavarian Data Protection Authority (BayLDA), Promenade 27, 91522 Ansbach, Germany (https://www.lda.bayern.de).
