1. Who we are
This Privacy Policy explains how AllocClarity, Lda. ("AllocClarity", "we", "us") collects and uses personal data when you visit allocclarity.com or use our Services. We are the data controller for the personal data described here. Our registered office is at Lisbon, Portugal.
Our Services are built for businesses. Most of the data we handle is business contact information and on-chain data, which is public by nature.
2. Data we collect
Information you give us
- Contact and demo requests: name, work email, company, role and anything you write in your message.
- Account data: name, work email, company, login credentials and API keys, if you create an account.
- Portfolio data: wallet addresses, positions and mandate or risk-tolerance settings you add so we can analyse and report on your portfolio.
Information collected automatically
- Server logs: our hosting provider records IP address, browser type, pages requested and timestamps to deliver and secure the website.
- Usage data: if you use the platform or API, we log requests, features used and errors.
- Browser storage: the website stores your light/dark theme choice in your browser's local storage. It is not sent to us and is not used for tracking.
- Analytics: we use Google Analytics 4 to understand how the website is used. It sets cookies (
_ga,_ga_*) to tell returning visitors apart and reports pages viewed, approximate location, device and browser to Google, which acts as our processor. Google Analytics 4 does not store IP addresses. Separately, for our own monitoring we log page views and button clicks: the page path and your country, with no cookie and no identifier.
Public blockchain data
Wallet addresses and transactions are public on their blockchains. When you link a wallet to your account, that address becomes associated with you, and we treat it as personal data.
Cookie policy
The only cookies this website sets are Google Analytics cookies (_ga, _ga_*, kept for up to 2 years), and only after you click Accept in the cookie banner. If you decline, or do not answer, no analytics cookie is set and no data is sent to Google. Your answer, the time you gave it and the version of this policy are stored in your browser (ac-consent in local storage) so you are asked once; nothing about it is sent to us. You can change it at any time with Cookie settings in the footer of every page. Declining after an earlier acceptance removes the analytics cookies. If this policy changes materially, you will be asked again. The theme switch is also stored in your browser; it is not a cookie and is never sent to us.
3. How we use your data and why
- To provide the Services (account, portfolio analytics, reports, API): performance of our contract with you.
- To respond to enquiries and demo requests: our legitimate interest in answering business enquiries, or steps you ask us to take before entering a contract.
- To secure and improve the Services (fraud and abuse prevention, debugging, product analytics): our legitimate interests.
- To send product updates or research: your consent, or our legitimate interest for existing business contacts. You can unsubscribe at any time.
- To meet legal obligations (sanctions, responding to lawful requests): legal obligation.
We do not sell personal data, and we do not use it for advertising.
4. Who we share it with
We share personal data only with service providers that help us run the Services, under contracts that require them to protect it:
- Hosting: Vercel Inc. (website hosting and delivery).
- Cloud infrastructure: providers that host the platform and its databases, in EU regions.
- Analytics: Google (Google Analytics 4). Data may be processed in the United States under Google's EU-US Data Privacy Framework certification and standard contractual clauses.
- Internal notifications: Slack. Sign-up details (name, work email, company) and the page and click events above are posted to a private channel our team monitors. Passwords are never included.
- Forms: Tally (the form behind our demo, contact and API-access requests).
- Email: our business email provider, for correspondence with you.
- Blockchain data providers: used to read public on-chain data. A wallet address you link may be included in those queries.
We may also disclose data where required by law, to protect our rights, or as part of a merger or acquisition, in which case the recipient will be bound by this policy.
5. International transfers
Some of our providers process data outside the European Economic Area and the United Kingdom. Where they do, we rely on adequacy decisions or Standard Contractual Clauses to protect your data.
6. How long we keep it
- Enquiry and demo data: up to 24 months after our last contact, unless you become a customer.
- Account and portfolio data: for as long as your account is active, then deleted within 90 days of closure.
- Server logs: 30 days.
7. Security
We use technical and organisational measures to protect personal data, described on our Security page. No system is completely secure, and we will notify you and the relevant authority of a personal-data breach where the law requires.
8. Your rights
Depending on where you are, including under the EU and UK GDPR, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to receive it in a portable format, and to withdraw consent at any time. To exercise these rights, email team@allocclarity.com. We will respond within one month.
You also have the right to complain to your local data-protection authority. Our lead supervisory authority is the Portuguese data-protection authority, Comissão Nacional de Proteção de Dados (CNPD).
9. Children
The Services are for professional use and are not intended for anyone under 18. We do not knowingly collect data from children.
10. Changes to this policy
We may update this policy from time to time. We will post the new version here and update the "Last updated" date, and notify account holders of material changes.
11. Contact
Privacy questions or requests: team@allocclarity.com
AllocClarity, Lda., Lisbon, Portugal