Synthvero Development Privacy Notice
MARKET INTELLIGENCE
DEVELOPMENT PRIVACY NOTICE
Version: dev-0.1
IMPORTANT DEVELOPMENT NOTICE
Market Intelligence is currently a development and pre-commercial product. This document is a development privacy notice used to design and test the platform's privacy controls. It is not represented as the final commercial privacy notice of an incorporated company.
1. CONTROLLER INFORMATION
Product: Market Intelligence Status: Development / pre-commercial Controller designation: Development/Test Controller Privacy contact: [email protected]
A registered company, registered office and company registration number have not yet been established. These details must be replaced before commercial launch where applicable.
2. PURPOSE OF THIS NOTICE
This notice describes the categories of personal data that Market Intelligence may process, why those data may be processed, how privacy choices are handled, and the technical governance model being prepared for the platform.
3. CATEGORIES OF DATA
Depending on the functions used, Market Intelligence may process:
- account and identity information;
- authentication and session information;
- portfolio and financial information entered by the user;
- watchlists, alerts and user preferences;
- real-estate, physical-gold, debt and other asset information;
- uploaded documents and information extracted from those documents;
- support communications;
- privacy choices and policy acknowledgements;
- security and audit information;
- technical and observability information;
- AI-related prompts, requests or history where an AI feature is used.
The exact production data inventory must be reviewed before commercial launch.
4. PURPOSES OF PROCESSING
Information may be processed to:
- create and operate user accounts;
- authenticate users and protect accounts;
- provide portfolio and market-intelligence functionality;
- process user-requested calculations and analytics;
- store user preferences and alerts;
- provide support;
- maintain security, reliability and auditability;
- maintain privacy evidence and user choices;
- provide AI functionality requested by a user;
- satisfy legal or regulatory obligations applicable to the final operator.
5. LEGAL BASIS
The production legal basis for each processing activity must be documented before commercial launch.
Depending on the processing activity and applicable law, a legal basis may include performance of a contract, compliance with a legal obligation, legitimate interests, or consent.
The existence of this development document does not itself establish that a particular legal basis applies.
6. FINANCIAL INFORMATION
Market Intelligence may contain information concerning investments, portfolios, transactions, property, physical assets, liabilities and related financial records entered or imported by users.
The platform privacy architecture treats financial portfolio information as a high-sensitivity data category requiring appropriate access controls and protection.
7. DOCUMENT UPLOADS
Where users upload statements, contracts or other documents, those documents may contain personal or financial information.
Production controls must address access restriction, storage, extraction, retention and deletion of uploaded documents.
8. AI FEATURES
Where a user invokes an AI-powered function, information necessary to perform that request may be processed by the applicable AI integration.
Before commercial launch, every external AI provider and relevant processing flow must be recorded in the processor and international-transfer inventory where required.
Optional AI processing must not be represented as consented to merely because a user created an account.
9. COOKIES AND SIMILAR TECHNOLOGIES
Strictly necessary technologies may be used where required for authentication, security, session management, privacy choices and essential operation.
Optional categories are designed to default to disabled unless an applicable lawful basis and user choice permits their use.
The development cookie categories are:
- Necessary
- Functional
- Analytics
- Marketing
See the Development Cookie Policy for additional information.
10. PRIVACY CHOICES
The platform is being designed to preserve evidence of policy acknowledgement, consent grants and withdrawals, and cookie preferences.
Optional consent must remain separate from mandatory account terms.
11. RETENTION
Market Intelligence contains a technical retention-policy framework.
Final retention periods have not yet been legally approved. Development retention entries marked draft or review-required must not be represented as final legal retention periods.
Before commercial launch, retention periods must be approved for each relevant data domain.
12. DATA LOCATION
The current development governance configuration identifies the primary storage region as EU and the storage country as Germany.
This statement describes the configured development architecture and must be revalidated against the actual production infrastructure and every relevant processor before commercial launch.
13. INTERNATIONAL TRANSFERS
No statement in this development notice should be interpreted as confirmation that a particular international transfer mechanism, adequacy decision, Standard Contractual Clauses, Data Processing Agreement or equivalent legal instrument is already in place.
Processors, subprocessors and transfers must be inventoried and legally reviewed before commercial launch.
14. INDIVIDUAL RIGHTS
Depending on applicable law and jurisdiction, individuals may have rights relating to access, correction, deletion, restriction, objection, portability, withdrawal of consent and other privacy protections.
The exact rights and response procedures applicable to the commercial service must be finalized before launch.
15. SECURITY
Market Intelligence is being designed with security and privacy controls that include authentication protections, authorization controls, privacy evidence, data-governance controls, auditability and protected handling of sensitive information.
No statement in this development notice constitutes a certification or guarantee of compliance with a particular security or privacy standard.
16. PROCESSORS
The definitive production processor and subprocessor list has not yet been approved.
No vendor should be represented as an approved production processor merely because its technology is being evaluated or integrated during development.
17. CHILDREN
The commercial age eligibility and any child-data controls must be formally established before launch.
The development platform is not intended to establish consent mechanisms for children through this document.
18. CHANGES
Development policy versions may be replaced as the architecture, legal entity, processors, jurisdictions and commercial service are finalized.
Published commercial versions should be versioned and preserved so that historical acceptance evidence can be associated with the exact policy content.
19. CONTACT
Development privacy contact:
This contact and the controller identity must be reviewed before commercial launch.