BTC Breakout — Libertas Project Management – FZCO
Effective Date: [DATE]
Last Updated: [DATE]
1. Information We Collect
1.1 Information You Provide
- Account Information: Name, email address, country of residence, date of birth
- Date of Birth: Collected during registration to verify you meet the minimum age requirement (18 years) and to support identity verification and compliance with applicable financial regulations in your jurisdiction
- Gender: Optionally provided during registration. Used for demographic analysis and service personalisation. You may select “Prefer not to say” or leave this field blank
- Broker Credentials: MT4 account details (encrypted at rest and in transit using industry-standard encryption)
- Communication Data: Support requests, feedback, and correspondence
- Testimonial Data: Reviews and feedback you voluntarily provide for publication
1.2 Information Collected Automatically
- Usage Data: Pages visited, features used, time spent on the dashboard
- Device Data: Browser type, operating system, screen resolution
- Log Data: IP addresses, access timestamps, error logs
- Cookie Data: Session identifiers, preference settings, and affiliate tracking identifiers (see Section 9)
1.3 Information from Third Parties
- Payment Processor: Transaction confirmation, payment status, and fraud prevention data
- Trade Copying Infrastructure Provider (Tradesync): Connection status, trade execution confirmations, account status events, copier events, and trade data. Tradesync is operated by Ttech Solutions Limited, a company incorporated under the laws of Hong Kong with company number 2928825 (see Section 4.1 for details). Your MT4 credentials are transmitted to Tradesync via their API to establish and maintain your broker connection.
- Affiliate Tracking Provider: Affiliate attribution data, including referral tracking cookies set when you visit btcbreakout.com via an affiliate link
- Performance Verification Provider: Trading performance data for third-party verification (anonymised — see Section 4.2)
1.4 Information Collected Through Community Platforms
If you access BTC Breakout’s supplementary community features on Telegram or Discord (“Community Platforms”), we may collect:
- Platform Identifiers: Your Telegram user ID, Discord user ID, or username, for the purpose of linking your Community Platform identity to your BTC Breakout account and managing access
- Interaction Data: Messages sent to Company bots or within Company-managed channels, commands issued to bots, and bot responses, for the purpose of providing the community service and improving its functionality
- Moderation Data: Records of content moderation actions (warnings, mutes, bans) taken by Company moderators
Community Platforms are operated by independent third parties (Telegram FZ-LLC and Discord Inc.). When you use these platforms, the platform operator independently collects and processes data about you in accordance with its own privacy policy. The Company does not control and is not responsible for data processing by these third-party platform operators.
2. How We Use Your Information
We use your personal data to:
- Provide and maintain the Service
- Process payments and manage subscriptions
- Connect your broker account to our trade copying infrastructure via the Tradesync API
- Communicate with you about your account, support requests, and service updates
- Send transactional emails (account confirmations, credential approvals, subscription reminders)
- Detect and prevent fraud, abuse, and unauthorised access
- Comply with legal obligations
- Verify that you meet the minimum age requirement for access to the Service
- Support identity verification and compliance with applicable financial regulations
- Personalise communications and improve user experience using demographic data you have chosen to provide
- Improve the Service through aggregated, anonymised analytics
We do not sell your personal data to third parties.
3. Legal Basis for Processing (GDPR)
For the purposes of GDPR, the Company acts as Data Controller for all personal data collected and processed through the Service, including account data, payment records, usage logs, and affiliate data. The Company determines the purposes and means of processing. Where the Company engages third-party service providers, those providers act as Data Processors on the Company’s behalf under appropriate contractual safeguards.
| Purpose | Legal Basis |
|---|---|
| Account creation and service delivery | Performance of contract |
| Payment processing | Performance of contract |
| Transactional emails | Performance of contract |
| Security and fraud prevention | Legitimate interest |
| Analytics and service improvement | Legitimate interest |
| Marketing communications (if applicable) | Consent |
| Legal compliance | Legal obligation |
4. Information Sharing
We share your personal data only in the following circumstances:
- Third-Party Service Providers: We use third-party providers to operate the Service, including providers for payment processing, database and authentication services, application hosting, email delivery, affiliate tracking, and signal delivery. These providers process your data only as necessary to perform their services and are contractually bound to protect your data.
- Legal Requirements: We may disclose your data if required by law, court order, or government request, or to protect our rights, safety, or property.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction with equivalent protections.
4.1 Third-Party Performance Verification
If you participate in our beta programme, your trading performance may be linked to a third-party verification platform for independent performance tracking. Only trading performance data is shared — no personal identification data. Your profile on the verification platform will display an anonymised account identifier only.
5. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of sensitive data at rest and in transit (including broker credentials)
- Role-based access controls with audit logging
- Rate limiting and brute force protection
- Regular security assessments
- Restricted access to personal data on a need-to-know basis
No method of electronic storage or transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
6. Data Retention
| Data Type | Retention Period |
|---|---|
| Account Data | Duration of your account plus 2 years for legal compliance. If your account is terminated via refund within the 7-day window, basic account records (email, transaction ID, date of birth) are retained for 2 years for dispute resolution; extended profile data is deleted within 30 days. |
| Date of Birth | Duration of your account plus 2 years to support financial compliance obligations |
| Gender | Duration of your account only. Deleted upon account termination. |
| Broker Credentials | Deleted within 30 days of account termination or broker disconnection |
| Trading Data | Duration of subscription plus 1 year |
| Payment Records | 7 years (legal/accounting requirements) |
| Usage Logs | 12 months |
| Support Correspondence | Duration of account plus 2 years |
| Performance Verification Data (beta) | Duration of subscription plus 1 year, consistent with trading data retention |
| Community Platform Data (Telegram/Discord) | Duration of your account plus 6 months. Platform identifiers and moderation records retained for the duration of your account. Interaction data (messages to bots, commands) retained for 12 months for service improvement and moderation purposes, then deleted. Data held by third-party platform operators (Telegram FZ-LLC, Discord Inc.) is subject to their own retention policies. |
7. Your Rights (GDPR & Applicable Law)
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data (subject to legal retention requirements)
- Restriction: Request restriction of processing in certain circumstances
- Portability: Receive your data in a structured, commonly used format
- Objection: Object to processing based on legitimate interest
- Withdraw Consent: Where processing is based on consent, withdraw at any time
To exercise any of these rights, contact us at support@btcbreakout.com. We will respond within 30 days (or as required by applicable law).
Processing of your date of birth for age verification is based on legal obligation and cannot be objected to. If you have provided gender data, you may request its deletion at any time without affecting your access to the Service.
8. International Data Transfers
Personal data may be transferred to and processed in countries outside the EEA/UK, including the United States, the United Arab Emirates, and Hong Kong (where our trade copying infrastructure provider, Ttech Solutions Limited (company number 2928825), is incorporated), where our company and certain third-party service providers operate.
For all international transfers, we ensure appropriate safeguards are in place, including:
- EU Standard Contractual Clauses (SCCs) — Module 2 (Controller to Processor)
- UK International Data Transfer Agreement (IDTA) or Addendum, as applicable
- Adequacy decisions where applicable
Copies of relevant transfer mechanisms are available upon request.
9. Cookies and Tracking
We use cookies and similar technologies for:
- Essential Cookies: Required for the Service to function (authentication, session management, security)
- Analytics Cookies: To understand how users interact with our Service (usage patterns, page views)
- Preference Cookies: To remember your settings and preferences
- Affiliate Tracking Cookies: If you visit btcbreakout.com via an affiliate referral link, our affiliate tracking platform sets a cookie to attribute your registration to the referring affiliate. This cookie has a 90-day expiration. The cookie stores a referral identifier only — no personal data. You may decline this cookie, but doing so may prevent proper attribution of any referral benefits.
You can manage cookie preferences through your browser settings. Blocking essential cookies may prevent the Service from functioning correctly.
For users located in the EEA or UK, we obtain your consent before setting non-essential cookies (analytics and affiliate tracking cookies) via a cookie consent mechanism displayed on first visit. You may withdraw consent or update your preferences at any time through this mechanism or your browser settings.
10. Children’s Privacy
The Service is not intended for anyone under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or dashboard notification at least 14 days before they take effect. Your continued use of the Service after the effective date constitutes acceptance of the revised policy.
12. Contact and Data Protection
For questions about this Privacy Policy or to exercise your data rights:
Email: support@btcbreakout.com
Company: Libertas Project Management – FZCO
Address: Dubai, UAE
12.1 Data Protection Contact
Although the Company is not required to appoint a Data Protection Officer under Article 37 of the GDPR, we have designated a data protection contact point for all GDPR-related enquiries:
Email: privacy@btcbreakout.com
If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority.