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Privacy Policy

Effective Date: 1 January 2026 • Last Revised: 14 February 2026

This Privacy Policy explains how Walgrave ("we", "us", or "our") collects, holds, uses, and discloses your personal data when you interact with our website, infrastructure, trading simulation interfaces, and autonomous intelligence systems. We are committed to safeguarding personal information in alignment with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

1. Data Controller Information

The data controller responsible for the processing of your personal information is Walgrave, having its operational registered address at King William Street 60, BS1 5LJ Bristol, United Kingdom. You can contact our designated Data Protection Officer via email at [email protected].

2. Categories of Information We Collect

Depending on your relationship with Walgrave, we may collect and process the following categories of personal data:

  • Identification & Contact Data: Full name, email address, telephone number, residential address, country of residence, and government-issued identification details where required for identity verification.
  • Technical & Telemetry Data: IP addresses, browser version, operating system, device identifiers, time-zone settings, diagnostic crash logs, and interaction data gathered during system usage.
  • Financial & Transactional Records: Wallet public keys, simulated or active trade configuration logs, settlement references, and payment verification records. We never store raw cryptographic private keys.
  • Communications Data: Inquiries, customer support tickets, survey responses, and feedback provided during customer assistance interactions.

3. Legal Bases and Purposes of Processing

We process personal information strictly in accordance with lawful grounds under UK data protection law:

  • Performance of a Contract: To activate user accounts, configure trading parameters, provide automated execution tools, and maintain user dashboards.
  • Legal and Regulatory Compliance: To verify identities, detect financial misconduct, maintain audit records, and comply with binding court orders or statutory notices.
  • Legitimate Interests: To optimize algorithmic performance, enhance cybersecurity defences, detect fraudulent activity, and upgrade platform efficiency, provided such interests do not override your fundamental rights.
  • Consent: Where explicitly provided, such as for specific marketing updates or elective analytical cookie tracking. You may withdraw consent at any time.

4. Data Sharing and Third-Party Disclosures

We do not sell, rent, or trade your personal data. We may share information only under strict confidentiality and security terms with:

  • Hosting providers, cloud infrastructure vendors, and cybersecurity monitoring services;
  • Identity verification and anti-fraud software providers;
  • Independent legal counsel, statutory auditors, and professional advisors;
  • Regulatory bodies, law enforcement agencies, or public authorities when legally compelled.

5. Cross-Border Data Transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area, Walgrave ensures that equivalent data protection standards are enforced. Transfers rely on approved International Data Transfer Agreements (IDTAs), standard contractual clauses, or adequacy regulations recognized by the UK Information Commissioner's Office (ICO).

6. Security and Data Retention

Walgrave implements advanced administrative, logical, and physical security measures, including end-to-end data encryption (AES-256), TLS cryptographic transmission protocols, role-based access governance, and continuous vulnerability monitoring. Personal data is retained only for as long as required to fulfil the purposes for which it was collected or to satisfy statutory record-keeping and legal limitation requirements.

7. Your Statutory Rights

Subject to applicable data protection legislation, you possess specific rights regarding your personal information:

  • Right of Access: Request a copy of the personal information we hold about you.
  • Right to Rectification: Request correction of inaccurate or incomplete personal data.
  • Right to Erasure: Request the deletion of your personal data under certain conditions.
  • Right to Restriction: Request the suspension of data processing under certain circumstances.
  • Right to Data Portability: Obtain your personal information in a structured, machine-readable format.
  • Right to Object: Object to processing carried out based on legitimate interests or direct marketing.

To exercise any of these rights, please submit your request to [email protected]. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you consider that our processing violates your privacy rights.

8. Updates to this Policy

We review and update this Privacy Policy on a regular basis to reflect evolving statutory duties and algorithmic technological practices. Revisions will be published on this page with an updated effective date. We encourage periodic review of this statement.