Zásady ochrany osobních údajů
Last updated: 23 October 2026. Version 3.2.
1. Who we are
This Privacy Policy is issued by ZunBit Technologies Ltd. (CRO #765234), a company registered in Ireland with its registered office at 24 Baggot Street Lower, Dublin D02 X064 (“ZunBit AI”, “we”, “our”, “us”). ZunBit AI operates the website zunbitai.com and the ZunBit AI trading-intelligence platform. For the purposes of the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018, Canadian PIPEDA, and comparable data-protection laws, ZunBit AI acts as the Data Controller of the personal data described below.
Our Data Protection Officer (DPO) can be reached at [email protected].
2. What this policy covers
This policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it, what rights you have, and how we protect it. It applies to everyone who visits our website, registers for an account, uses the ZunBit AI platform, contacts our support team, or applies for a job with us.
3. Personal data we collect
3.1 Data you give us directly
- Account data: first name, last name, email address, country of residence, password hash, chosen capital bracket.
- Verification data: where legally required (anti-money-laundering), copies of government-issued ID, proof of address, selfie for liveness check.
- Communication data: any emails, chats or phone calls you exchange with our support team.
- Payment data: processed by Stripe and never stored on our servers in plaintext. We only retain the last four digits and expiry month of your card.
3.2 Data we collect automatically
- Device & browser data: IP address, user agent, screen size, time zone, operating system.
- Usage data: pages viewed, buttons clicked, signal interactions, approximate session duration.
- Cookies & local storage: see our Zásady používání cookies for the full list.
3.3 Data we collect from third parties
- Broker API data: position, balance and trade history from the broker you connect, with your explicit OAuth consent.
- KYC data: verification results from certified identity providers (Sumsub, Jumio).
- Public enrichment: sanctions-list, PEP-list and open-source professional data from Refinitiv World-Check for AML.
4. Why we process your data (lawful bases)
| Purpose | Lawful basis |
|---|---|
| Delivering the platform and performing our contract with you | Contract (Art. 6(1)(b) GDPR) |
| Verifying your identity under AML law | Legal obligation (Art. 6(1)(c)) |
| Monitoring risk thresholds and executing pause logic | Contract & legitimate interest |
| Fraud prevention and platform-abuse detection | Legitimate interest (Art. 6(1)(f)) |
| Sending transactional emails (password reset, pause alerts, invoices) | Contract |
| Sending marketing emails about ZunBit features | Consent (Art. 6(1)(a)), withdrawable at any time |
| Responding to your support requests | Contract & legitimate interest |
| Complying with Court orders or regulatory requests | Legal obligation |
5. Who we share your data with
We never sell personal data. Full stop. We share it only with the following categories of recipient, strictly on a need-to-know basis:
- Infrastructure providers: AWS (EU-Frankfurt), Cloudflare (edge delivery), Postmark (transactional email).
- Partner brokers you choose to connect: only the data strictly required to route your trades.
- Identity verification providers: Sumsub, Jumio for KYC and AML.
- Analytics: privacy-preserving analytics (Plausible, EU-hosted). No Google Analytics. No Facebook Pixel. No session recorders.
- Payment processor: Stripe (Ireland) for subscription and fee processing.
- Regulators and law-enforcement: only when legally compelled.
- Professional advisors: auditors, lawyers and insurers bound by confidentiality.
6. International transfers
Our primary infrastructure is in the EU (Frankfurt). Where a service provider processes data outside the EEA (for example, a US-based email vendor), we rely on EU Standard Contractual Clauses (SCCs) and additional technical safeguards (encryption at rest and in transit) to protect your rights.
7. How long we keep your data
| Data category | Retention period |
|---|---|
| Account profile | Life of account + 7 years (AML) |
| Trade and signal history | 7 years (financial record-keeping) |
| Support emails | 3 years |
| Marketing opt-ins | Until withdrawn |
| Website analytics | 14 months aggregated |
| Server logs | 30 days |
8. Your rights
Under GDPR and comparable laws you have the right to:
- Access the personal data we hold about you (Article 15).
- Rectify inaccurate data (Article 16).
- Erase your data where legally possible (Article 17 — “right to be forgotten”).
- Restrict processing (Article 18).
- Port your data to another provider (Article 20).
- Object to processing based on legitimate interest (Article 21).
- Withdraw consent at any time, without affecting lawfulness of past processing.
- Lodge a complaint with your local supervisory authority (in Ireland: the Data Protection Commission).
To exercise any of these rights, email [email protected]. We respond within 30 days, free of charge, except for manifestly unfounded or excessive requests.
9. Security measures
- All data encrypted in transit (TLS 1.3) and at rest (AES-256).
- Password hashing with argon2id and per-user salts.
- Mandatory 2FA for all internal staff accounts.
- Quarterly external penetration tests.
- SOC-2 Type II audit scheduled Q4 2026.
- Role-based access with full audit trail.
- 72-hour breach-notification process to the Data Protection Commission and affected users.
10. Children
ZunBit AI is not intended for anyone under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data on a minor, contact us and we will delete it immediately.
11. Automated decision-making
Our risk-engine pause logic is automated but strictly rule-based, not profiling. It does not produce legal effects or significantly affect you in the sense of Article 22 GDPR — a pause simply halts further trading until you review and reactivate.
12. Changes to this policy
We review this policy at least annually. Material changes are announced by email at least 14 days before they take effect. The current version is always available at zunbitai.com/privacy-policy.
13. Contact
Email: [email protected]
Post: Data Protection Officer, ZunBit Technologies Ltd., 24 Baggot Street Lower, Dublin D02 X064, Ireland.