Privacy Policy

1. Data Controller

Smart-HODL (“we”, “us”, or “our”) acts as the data controller for limited personal data processed through this website and related services. We process personal data in accordance with the General Data Protection Regulation (GDPR).

2. Scope of This Policy

This Privacy Policy applies to the Smart-HODL web platform and related account services. It does not apply to software components executed on infrastructure fully controlled by the user, including user-managed virtual private servers (VPS).

3. Information We Collect

• Account Data: Email address and encrypted password used solely for authentication and account management.
• Service Metadata: Non-sensitive technical information required to operate the web platform (e.g. timestamps, plan status, configuration identifiers).
• Communication Data: Information you voluntarily provide when contacting support.

We do not collect, store, transmit, or process exchange API keys.

4. API Keys & Trading Execution

Smart-HODL provides software tools and configuration logic that users deploy and execute on their own infrastructure (e.g. a personal VPS). Exchange API keys are entered and stored exclusively within the user’s own execution environment.

At no point does Smart-HODL:

• Receive or store API keys
• Have access to exchange credentials
• Have technical ability to place trades on behalf of users
• Have withdrawal permissions or custody over funds

5. How We Use Personal Data

Personal data is processed solely for the following purposes:
– User authentication and account administration
– Operation and improvement of the Smart-HODL web platform
– Delivery of service-related communications and security notices

6. Legal Basis for Processing

We process personal data based on:
– Performance of a contract (Article 6(1)(b) GDPR)
– Compliance with legal obligations (Article 6(1)(c) GDPR)
– Legitimate interests related to platform security and stability

7. Data Retention

We retain personal data only for as long as necessary to provide the service or comply with legal obligations. Users may request deletion of their account and associated personal data at any time.

8. Data Sharing

We do not sell, rent, or share personal data with third parties, except where required by law or necessary to operate essential infrastructure services (e.g. hosting providers under GDPR-compliant agreements).

9. User Rights

Under GDPR, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, as well as the right to data portability.

10. Contact

For privacy-related inquiries or requests, please contact us via the details provided on the Smart-HODL website.