Privacy Policy

Introduction

alvora B.V. ("we", "us", or "our") 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 alvora.world and use our investment platform services. This policy applies to all personal data we collect and process.

Data Controller Information

alvora B.V. is the data controller responsible for your personal data. Our company is registered in the Netherlands with registration number 77419305 and VAT number NL845930218B01. Our registered address is Beukenlaan 123, 5063 UT Tilburg, North Brabant, Netherlands.

Data Collection

The data we collect depends on how you interact with our services. We may collect the following types of personal information:

• Contact information including name, email address, phone number, and postal address
• Financial information relevant to our investment services
• Technical information including IP address, browser type, and device information
• Usage data about how you interact with our website and services
• Communication records when you contact us
• Identity verification documents as required by financial regulations

How We Use Your Information

We use of your data is based on legitimate interests, contractual necessity, legal obligations, and your consent where required. Specifically, we use your information to:

• Provide investment platform services and legal advisory
• Process and manage your investment portfolios
• Communicate with you about our services and your account
• Comply with legal and regulatory obligations
• Improve our website and services through analytics
• Protect against fraud and ensure platform security
• Send marketing communications where you have consented

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds: performance of a contract with you, compliance with legal obligations, legitimate interests in operating our business, and your explicit consent for marketing communications and certain data processing activities.

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 see our Cookie Policy.

Data Sharing and Disclosure

We do not sell your personal data. We may share your information with trusted third parties including regulatory authorities when required by law, service providers who assist in operating our platform, professional advisers such as lawyers and accountants, and other parties with your explicit consent.

Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this policy, comply with legal and regulatory requirements, and resolve disputes. Financial records are typically retained for seven years in accordance with applicable regulations. Website usage data and cookies are retained for shorter periods as specified in our Cookie Policy.

Your Rights

Under GDPR and applicable data protection laws, your rights include:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure in certain circumstances
• Right to restrict processing
• Right to data portability
• Right to object to processing based on legitimate interests
• Right to withdraw consent where applicable
• Right to lodge a complaint with a supervisory authority

Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, secure servers, access controls, and regular security assessments.

International Data Transfers

Your personal data is primarily processed within the European Economic Area. If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Supervisory Authority

If you believe we have not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority.