Legal

Privacy Policy

This Privacy Policy explains which personal data purepofo processes, why that processing takes place, who may receive the data, and which rights you have under applicable data-protection law.

Last updated: March 29, 2026

Controller

Dr. Hazem Hamoudia Management Consulting, Munich, Germany

Regime

GDPR and applicable German data-protection law

Supervisory Authority

BayLDA, Ansbach, Germany

1. Who Is Responsible for Your Data

1.1 Controller

The controller responsible for personal data processed through purepofo is Dr. Hazem Hamoudia Management Consulting, Munich, Germany.

1.2 Contact

For privacy-related questions, please contact support@purepofo.com.

1.3 Scope

This Privacy Policy explains how we collect, use, store, and protect personal data when you visit the website, create an account, use the platform, or contact us.

2. Personal Data We Collect

2.1 Account data

This may include your name, email address, login credentials, account preferences, and related profile information that you provide when using the service.

2.2 Subscription and payment data

This may include billing details, subscription status, transaction references, and payment-related metadata. We do not store full payment-card details ourselves.

2.3 Usage and device data

We may process IP address, browser type, device information, log data, pages viewed, and platform usage data needed to operate, secure, and improve the service.

2.4 Communication data

If you contact us, we may process the information contained in your message, including support requests, feedback, and related correspondence.

2.5 Broker connection data

If you choose to connect a broker account, we may process account identifiers, holdings, transaction history, and related data that are needed to provide the requested integration features.

3. Why We Process Data and the Legal Bases We Rely On

3.1 Performance of a contract

We process data where this is necessary to create and manage accounts, provide subscriptions, operate platform features, and respond to service requests under Art. 6(1)(b) GDPR.

3.2 Consent

Where required, we rely on your consent, for example for optional marketing communications, optional cookies, or broker connectivity features that depend on your active authorization under Art. 6(1)(a) GDPR.

3.3 Legal obligations

We may process data to comply with accounting, tax, security, and other legal obligations under Art. 6(1)(c) GDPR.

3.4 Legitimate interests

We may process data under Art. 6(1)(f) GDPR where necessary to keep the platform secure, prevent misuse, improve product performance, analyze service stability, and protect our legal interests, always taking your rights and interests into account.

4. Sharing, Recipients, and International Transfers

4.1 Service providers

We may share personal data with carefully selected service providers that help us operate the service, such as hosting, authentication, analytics, payment-processing, email, and infrastructure providers.

4.2 Broker and integration partners

Where you choose to use broker connectivity or other integrations, relevant data may be exchanged with those providers to support the feature you requested.

4.3 Legal disclosures and business transfers

We may disclose data where required by law, legal process, or regulatory request, or in connection with a merger, sale, restructuring, or similar business transaction.

4.4 Transfers outside the EEA

If personal data is transferred outside the EEA, we use appropriate safeguards such as adequacy decisions or the European Commission’s Standard Contractual Clauses, where required.

5. Retention and Security

5.1 Retention periods

We retain personal data only as long as necessary for the purposes described here, for contractual and support needs, and for mandatory legal retention duties. Billing and accounting records may need to be kept for longer periods under German law.

5.2 Security measures

We use reasonable technical and organizational measures to protect personal data, including access controls, encryption where appropriate, secure infrastructure, and security monitoring.

6. Cookies and Similar Technologies

6.1 Functional and analytical use

We may use cookies or similar technologies to keep the service functional, understand usage patterns, and improve performance. Where consent is required for non-essential cookies or tracking technologies, we seek that consent through the relevant user interface.

6.2 Browser controls

You can also manage certain cookie settings through your browser or device settings, although doing so may affect some platform functionality.

7. Broker Account Connections

7.1 Authorization

When you choose to connect a broker account, you authorize us to access and process the data necessary to provide the relevant portfolio or trading-related feature that you have requested.

7.2 Authentication

Broker integrations may rely on secure authentication protocols such as OAuth2. We do not store your broker login credentials where the integration uses token-based authorization.

7.3 Revocation

You may disconnect a broker integration at any time. After revocation, we will stop further access to live broker data except where limited retention remains necessary for legal, accounting, or security reasons.

8. Your Rights

8.1 GDPR rights

Depending on the circumstances, you may have rights of access, rectification, erasure, restriction, objection, and data portability under the GDPR.

8.2 Withdrawal of consent

Where we rely on consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing that took place before withdrawal.

8.3 Complaint to a supervisory authority

You also have the right to lodge a complaint with a competent data-protection authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

9. Contact and Complaints

9.1 Contact us

If you have questions about this Privacy Policy or your personal data, please contact support@purepofo.com.

9.2 Bavarian supervisory authority

You may also lodge a complaint with the Bavarian Data Protection Authority (BayLDA), Promenade 18, 91522 Ansbach, Germany. Official contact information is available at lda.bayern.de.

10. Changes to This Policy

10.1 Updates

We may update this Privacy Policy from time to time. Material changes will be published on this page and, where appropriate, communicated through the service or by email.
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