Privacy Policy

Last updated: 14 Sep 2025

We respect your privacy and are committed to protecting personal data processed through the Custos Advisory platform and related websites.

1. Data We Collect

We may process account identifiers, contact details, authentication data, usage logs, payment metadata (non‑sensitive), AML / KYC status flags, and product telemetry required for security and reliability.

2. Sources

Data originates from (a) you directly, (b) platform instrumentation, and (c) regulated third‑party providers (identity, sanction screening, blockchain analytics) under appropriate contracts.

3. Purpose & Legal Bases

• Contract performance – provide and maintain the service.
• Legitimate interests – secure, improve, and support the platform.
• Legal obligations – AML, taxation, accounting, sanction compliance.
• Consent – optional marketing communications (you can withdraw any time).

4. Retention

Operational data: live + rolling archives; compliance data: retained as required by applicable jurisdiction (typically 5–10 years); telemetry: aggregated or anonymised when no longer needed.

5. International Transfers

When data leaves the U.K. / EEA we implement adequacy decisions or Standard Contractual Clauses plus technical safeguards (encryption in transit and at rest, key management segregation).

6. Security

Encryption (TLS 1.2+ / AES‑256), RBAC with least privilege, MFA for staff, immutable audit logs, daily backups, vulnerability management, and independent penetration testing.

7. Your Rights

Subject to law: access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. Submit requests to privacy@custosadvisory.club.

8. Sub‑processors

A current list is available on request and includes hosting, email delivery, analytics, and identity verification providers. We contractually require data protection and confidentiality.

9. Children

Our services are not directed to individuals under 18. We act on any inadvertent collection notice promptly.

10. Updates

Material changes will be announced via dashboard notice or email. Continued use constitutes acceptance.

11. Contact

Data Protection Contact: privacy@custosadvisory.club