Privacy Policy

Introduction

UrbanPulse IO SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website urbanpulseio.world or use our financial services. Please read this privacy policy carefully to understand our policies and practices regarding your information and how we will treat it.

Data Controller Information

The data controller for your personal information is UrbanPulse IO SARL, a company incorporated in Luxembourg with registration number RCSB468264. Our registered office is located at Rue du Fossé 117, 4814 Differdange, Luxembourg. You can contact us regarding any privacy matters at privacy@urbanpulseio.world or by phone at +352 28985632.

Data Collection

We collect several types of information from and about users of our website and services. The data we collect includes personal information that can identify you, either directly or indirectly. Specifically, we collect the following categories of personal data:

• Contact Information: Including your name, email address, phone number, and postal address
• Financial Information: Including income details, investment goals, risk tolerance, and current financial situation
• Technical Information: Including IP address, browser type, device information, and website usage data
• Communication Records: Including correspondence, consultation notes, and service-related communications
• Identity Verification Data: Including documents required for compliance with anti-money laundering regulations

How We Use Your Information

We use the personal information we collect for various purposes, depending on the legal basis for processing. Here's how we use your data and the legal grounds for each use:

• Service Provision: To provide financial advice, wealth modelling, and related services (Legal basis: Contract performance)
• Communication: To respond to your enquiries and provide customer support (Legal basis: Legitimate interests)
• Legal Compliance: To comply with regulatory requirements and legal obligations (Legal basis: Legal obligation)
• Marketing: To send you information about our services, with your consent (Legal basis: Consent)
• Website Improvement: To analyse website usage and improve our services (Legal basis: Legitimate interests)

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please refer to our Cookie Policy.

Data Sharing and Disclosure

We may share your personal information in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our business
• Legal Requirements: When required by law, regulation, or court order
• Professional Advisors: With lawyers, accountants, and other professional advisors as needed
• Regulatory Authorities: With financial regulators and compliance authorities as required

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Specifically, we retain client data for a minimum of 10 years after the end of our business relationship, as required by Luxembourg financial regulations. Marketing data is retained until you withdraw consent. Website analytics data is typically retained for 26 months. After the retention period expires, we securely delete or anonymise your personal data.

Your Rights

Under the General Data Protection Regulation (GDPR) and Luxembourg data protection law, you have several rights regarding your personal data:

• Right of Access: You can request a copy of the personal data we hold about you
• Right to Rectification: You can request correction of inaccurate or incomplete data
• Right to Erasure: You can request deletion of your personal data in certain circumstances
• Right to Restrict Processing: You can request that we limit how we use your data
• Right to Data Portability: You can request a copy of your data in a structured format
• Right to Object: You can object to certain types of processing, including direct marketing
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time

International Data Transfers

We primarily process your data within the European Union. If we transfer your personal data outside the EU, we ensure appropriate safeguards are in place, such as adequacy decisions by the European Commission or standard contractual clauses. We will inform you of any international transfers and the safeguards we have implemented.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include encryption, access controls, regular security assessments, and staff training. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of any material changes by posting the new Privacy Policy on our website and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following information:

Supervisory Authority

You have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (Commission Nationale pour la Protection des Données - CNPD) if you believe we have not complied with applicable data protection laws. You can contact the CNPD at 15, boulevard du Jazz, L-4370 Belvaux, Luxembourg, or visit their website at cnpd.public.lu.