Privacy Policy
Last updated: May 2026 · GDPR compliant (EU & UK)
Notice: This policy reflects our current data practices and will be updated as we finalise our legal entity registration and data processing infrastructure. We operate with EU GDPR as our baseline standard globally.
Your privacy matters to us. This policy describes how VirtualSilvr handles your personal data and your rights as a data subject under GDPR and applicable privacy law.
1. Overview
VirtualSilvr Markets ("VirtualSilvr", "we", "us", "our") is committed to protecting your personal data. This Privacy Policy explains what data we collect, why we collect it, how it is used, and your rights under applicable data protection law — including the EU General Data Protection Regulation (GDPR) and the UK GDPR. This policy applies to all users of the VirtualSilvr platform, website, and related services.
2. Data We Collect
We may collect: (a) Account data — name, email address, organisation, and account preferences when you register; (b) Usage data — pages visited, features used, session duration, and interaction events (collected via analytics tools); (c) Technical data — IP address, browser type, device identifiers, and operating system; (d) Communication data — messages you send us via email or support channels; (e) Payment data — billing address and transaction references processed via PCI-compliant third-party payment providers. We do not store payment card numbers on our systems.
3. Legal Basis for Processing (GDPR)
We process personal data on the following legal bases: (a) Contract performance — to provide the service you have subscribed to; (b) Legitimate interests — to improve the platform, prevent fraud, and maintain security; (c) Legal obligation — to comply with applicable laws and regulatory requirements; (d) Consent — for marketing communications and non-essential cookies, which you can withdraw at any time. Where we rely on consent, you may withdraw it by contacting us or adjusting your cookie preferences.
4. How We Use Your Data
We use personal data to: operate and improve the Platform; process subscriptions and manage accounts; send transactional communications (account creation, password reset, billing notices); send product updates and market intelligence newsletters (where consented); analyse usage patterns to improve user experience; detect and prevent fraudulent or abusive use; comply with legal and regulatory obligations.
6. International Data Transfers
Some of our service providers may be located outside the European Economic Area (EEA). Where personal data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as EU Standard Contractual Clauses or adequacy decisions. As we establish our legal entity and data infrastructure, we will update this section with specific transfer mechanisms and processor locations.
7. Data Retention
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, and as required by applicable law. Account data is retained for the duration of your subscription and for up to 3 years after account closure (for legal and audit purposes). Analytics data is retained in aggregated, anonymised form after 24 months.
8. Your Rights
Under GDPR and applicable data protection law, you have the right to: access the personal data we hold about you; request correction of inaccurate data; request deletion ("right to be forgotten") in certain circumstances; object to or restrict processing; data portability (receive your data in a structured, machine-readable format); withdraw consent at any time where processing is consent-based; lodge a complaint with your national supervisory authority (e.g., the Dutch Autoriteit Persoonsgegevens or the UK ICO). To exercise your rights, contact: privacy@virtualsilvr.com
10. Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include encryption in transit (TLS), access controls, and regular security reviews. No transmission over the internet is completely secure; we cannot guarantee absolute security but commit to notifying affected users and relevant supervisory authorities within 72 hours of becoming aware of a data breach as required by GDPR.
11. Children's Privacy
The Platform is not intended for users under 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately and we will delete the information.
12. Policy Updates
We may update this Privacy Policy as our services evolve and regulatory requirements change. We will notify registered users of material changes via email and post the updated policy with a revised date. Continued use of the Platform after changes constitutes acceptance of the revised policy.
13. Contact
For privacy-related queries, data subject requests, or to contact our data protection function: privacy@virtualsilvr.com. We aim to respond within 30 days as required by GDPR.