Privacy Policy

Privacy Policy and Data Protection Framework – Groei Version 3.1 – Last updated: April 9, 2026 Article 1: Identification of the Data Controller This Privacy Policy defines the strict data processing protocols employed by Groei ("the Platform", "we", "us" or "our"), located at Claude Debussylaan 54, 1082 MD Amsterdam, Netherlands. We act as the data controller within the meaning of the General Data Protection Regulation (AVG/GDPR). Given the nature of our AI-driven services, we have appointed a Data Protection Officer (DPO), reachable via [email protected]. Article 2: Categories of Personal Data Processed To ensure an institutional degree of security and precision, we collect the following categories of data: Identity Data: Full legal name, date of birth, nationality, and official identification documents required for legal Know Your Customer (KYC) verification. Information: Verified email address, active mobile phone number, and officially registered residential address. Financial Telemetry: Information about the source of wealth, wallet addresses, transaction history, and risk profiles essential for our algorithms. Digital Footprint and AI Interaction: IP addresses, device specifications, geographical routing data, and detailed logs of your interactions with our AI-driven prediction models. Article 3: Legal Basis and Purposes of Processing In accordance with Article 6 of the GDPR, we process data based on: Contractual necessity: For managing your account and providing our core analytical services. Legal obligations: Compliance with the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft). Legitimate interest: For fraud prevention, network security, and the optimization of our AI models through anonymized datasets. Explicit consent: For sending personalized market reports and using non-essential analytical cookies. Article 4: Advanced Security and Encryption Groei employs enterprise-grade security standards in accordance with ISO/IEC 27001 norms: AES-256 Encryption: All data at rest is stored with military-grade encryption. TLS 1.3 Protocols: All data transfer between the user and our servers is fully encrypted. Sovereign Hosting: Data is stored exclusively on redundant, secure servers within the European Economic Area (EEA) with strict logical access controls. Article 5: Retention Periods and Archiving We do not retain your data longer than strictly necessary: Active Data: For the duration of the contractual relationship. Legal Archives: Personal data and financial records are retained for a period of seven (7) years after termination of the relationship, in accordance with Dutch tax and anti-money laundering legislation. Article 6: Your Rights under the GDPR The GDPR grants you full control over your information: right to access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, and right to object. You can exercise these rights via [email protected]. You also have the right to file a complaint with the Dutch Data Protection Authority (AP).

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