Privacy Policy

Art. 13Data controller and data protection referent

Ad Viternam, SAS, 60 rue François 1er, 75008 Paris (SIREN 990 909 996), acts as data controller within the meaning of Article 4(7) GDPR. The data protection referent is Valentin Soulages, reachable at [email protected] or by post at the registered office.

Users' data is never sold, exchanged or transferred to third parties for commercial purposes.

Art. 14Data collected, purposes and retention periods

14.1 Identification and account data

Mandatory data: email address (AES-256-GCM encrypted in the database), country of residence.

Optional data: socio-professional status, estimated annual income, estimated wealth, year of birth, language, preferred currency.

Purpose: account creation and management, personalisation of the experience.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) for mandatory data; consent (Art. 6(1)(a) GDPR) for optional data.

Retention: duration of the account. An account inactive for 3 years (no sign-in or use of the Platform) is deleted; the User is notified by email one week beforehand and may keep it by signing in before that date. An ongoing paid subscription suspends this rule.

Sign in with Apple or Google: Ad Viternam receives the technical identifier of the Apple or Google account and the associated email address (for Apple, where applicable, a private relay address). The name provided at first sign-in is not kept. Legal basis: performance of the contract (Art. 6(1)(b) GDPR). Retention: duration of the account.

14.2 Connection logs

Data: IP address, connection timestamp, session identifier.

Purpose: security, fraud and unauthorised access detection.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

Retention: 90 days, then automatic purge.

14.3 Portfolio and budget data

Data: financial positions (equities, bonds, ETFs, crypto-assets, real estate, currencies), liabilities, debts, financial goals, ratios, budgets and expense categories.

Purpose: provision of the wealth and budget tracking service.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Retention: duration of the account. Full purge within 72 hours of closure.

14.4 Banking and brokerage data (Enable Banking / SnapTrade)

Data: account information, balances, transaction history, categorisations, brokerage positions. Partial account identifier: last 8 digits of the IBAN, retained for display and identification by the User.

Exclusions: no full IBAN, login credential, access code or contract number is stored by or known to Ad Viternam.

Purpose: provision of the aggregation service and improvement of categorisation through machine learning.

Legal basis: explicit consent (Art. 6(1)(a) GDPR), collected granularly, renewed every 180 days (PSD2). A separate consent is collected for the use of transactions to improve automatic categorisation (machine learning), revocable at any time.

Retention: duration of the account. The history of transactions already imported is kept as long as the account exists, for wealth and budget tracking; withdrawing consent immediately stops any further synchronisation. Full purge within 72 hours of closure.

14.5 Aggregated and anonymised data

Nature: irreversibly anonymised data, outside the scope of the GDPR.

Use: economic statistics, consumption indices, behavioural trends.

This data can in no way re-identify an individual User.

14.6 Enterprise requests (website contact form)

Data: name, business email address, company, role, company size, description of the need.

Purpose: responding to the request and presenting the Enterprise offer.

Legal basis: pre-contractual steps taken at the person's request (Art. 6(1)(b) GDPR).

Retention: 3 years from the last exchange.

Recipients: the request is sent by email, via Resend, to Ad Viternam's mailbox; it is not stored in the Platform's database.

The former early-access lists are closed; the data collected through them is deleted no later than 24 months after the last interaction.

14.7 Account deletion

Upon the User's account deletion request, or at the end of the inactivity period set out in Article 14.1, all of their personal data is destroyed within 72 hours, except data whose retention is required by a legal obligation. An anonymised record of the account's existence is kept for internal statistical purposes.

Backups: the database is backed up every night and encrypted before any transfer. Deleted data remains only in these encrypted backups, which are not accessible to day-to-day operations, until they are automatically erased no later than 100 days after the backup. They are used solely to restore the service after an incident.

14.8 AEGIS Module queries

Data processed: the identifier submitted by the User to the relevant commands (name for OFAC, telephone number for PHONE, username or email address for GITHUB).

Purpose: one-off verification of an identifier's exposure or status in open sources.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR), based on the User verifying their own exposure or performing a due-diligence obligation of their own. The balancing test is recorded in the processing register.

Retention: none. Submitted identifiers are processed in memory for the duration of the query and are not recorded, logged or retained in any form whatsoever.

Search history: for searches on non-nominative entities only (companies, organisations, domain names, wallet addresses, vessels, aircraft), a history limited to a summary (counters and flags, never the raw result) is kept for 30 days in the User's space. No search on a natural person, an email address or a telephone number is ever recorded there.

Watchlist: the entities the User chooses to add to it, including a natural person, are kept until the User removes them or deletes their account, in order to alert the User of a change in sanctions status.

Recipients: none for the OFAC and PHONE commands (processing exclusively local on Ad Viternam's infrastructure); GitHub, Inc. for the GITHUB command only (see Articles 16 and 17).

Google user data — "Sign in with Google"

This section explains, for the "Sign in with Google" feature, how Ad Viternam accesses, uses, stores and shares data from your Google account.

Data we receive

Only the basic identity information you consent to on Google's screen (openid, email and profile permissions): the technical identifier of your Google account and the associated email address. The name provided at first sign-in is not kept. Ad Viternam does not access any other data in your Google account: no emails, files, contacts or calendar.

How we use it

This data is used exclusively to create your account, authenticate you and confirm your identity before a sensitive action (account deletion, email address change, disabling two-factor authentication, leaving read-only mode). It is not used for advertising, profiling or training any machine-learning model.

Sharing

It is never sold, rented or transferred to third parties. Only the technical processors listed in Article 16, including the hosting provider, process it on Ad Viternam's behalf.

Retention, security and deletion

It is kept for the duration of the account, under the security measures described in Article 15, and destroyed within 72 hours of account deletion, subject to the encrypted backups described in Article 14.7. You can revoke Ad Viternam's access to your Google account at any time at myaccount.google.com/connections.

Ad Viternam's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Apple data — "Sign in with Apple"

This section explains, for the "Sign in with Apple" feature, what data Ad Viternam receives from Apple and how it is used, stored and shared.

Data we receive

The technical identifier of your Apple account and the associated email address. If you choose to hide your address, Ad Viternam only receives a relay address created by Apple, which forwards our messages to you. Apple also provides your name at first sign-in: it is not kept. Ad Viternam does not access any other data in your Apple account.

How we use it

This data is used exclusively to create your account, authenticate you and confirm your identity before a sensitive action (account deletion, email address change, disabling two-factor authentication, leaving read-only mode). It is not used for advertising, profiling or training any machine-learning model.

Sharing

It is never sold, rented or transferred to third parties. Only the technical processors listed in Article 16, including the hosting provider, process it on Ad Viternam's behalf.

Notifications from Apple

Apple informs Ad Viternam of certain changes to your Apple account, through a signed message that Ad Viternam verifies before acting:

• if you permanently delete your Apple account, the deletion of your Ad Viternam account is scheduled within 72 hours;
• if you stop using "Sign in with Apple" for Ad Viternam, your Apple account is unlinked and all your sessions are closed; your Ad Viternam account remains accessible with a password if it has one;
• if you disable or re-enable forwarding from your relay address, the event is only logged. While forwarding is disabled, our emails (security, alerts) no longer reach you.

Retention, security and deletion

It is kept for the duration of the account, under the security measures described in Article 15, and destroyed within 72 hours of account deletion, subject to the encrypted backups described in Article 14.7. You can stop using "Sign in with Apple" for Ad Viternam at any time from your Apple account settings, under "Sign in with Apple".

Art. 15Data security

Encryption in transit: TLS 1.3 via Cloudflare on all communications, then an encrypted tunnel between Cloudflare and Ad Viternam's servers.

Encryption at rest: AES-256-GCM with random initialisation vector for sensitive data.

Authentication: JWT (JSON Web Token) on all API endpoints.

Data isolation: Logical isolation per user in the database.

Logging: Full traceability of access and security events, 90-day retention then automatic purge. Express exclusion: identifiers submitted to AEGIS Module commands are never logged or retained, including in technical security logs (see Article 14.8). Connection logging (Article 14.2) covers the User's session, not the content of their queries.

Off-server backups and logs: the database is backed up every night and technical logs every 15 minutes, encrypted before transfer to storage located in the European Union and protected against deletion; backups are kept for at most 100 days, logs for at most 35 days.

Anti-intrusion protection: Detection and blocking of repeated login attempts, SSH key-only access, Cloudflare Web Application Firewall (WAF), immediate alerting on any administrative login and integrity monitoring of server files.

Hosting: Infomaniak Network SA servers, Geneva, Switzerland — ISO 27001 certified infrastructure.

In the event of a personal data breach, Ad Viternam will notify the French supervisory authority (CNIL) within 72 hours in accordance with Article 33 GDPR, and affected Users without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

Art. 16Processors

In accordance with Article 28 GDPR, Ad Viternam has entered into or undertakes to enter into a data processing agreement (DPA) with each of the following processors:

Infomaniak Network SA — Hosting & data storage — Geneva, Switzerland 🇨🇭 — DPA signed

Stripe, Inc. — Web/desktop payment processing — United States 🇺🇸 — DPA available at stripe.com/legal/dpa

Apple Inc. — In-App Purchase (iOS), "Sign in with Apple", push notifications (APNs), email (Apple Mail) — United States 🇺🇸 — DPA available at apple.com/legal/privacy

Google LLC — In-App Purchase (Android), "Sign in with Google", push notifications (FCM) — United States 🇺🇸 — DPA available at cloud.google.com/terms/data-processing-addendum

Microsoft Corporation — Email (Outlook) — United States 🇺🇸 — DPA available at microsoft.com/licensing/docs

Cloudflare, Inc. — CDN, WAF, TLS, aggregated audience analytics, object storage (R2) of technical logs and backups, encrypted before upload and located in the European Union — United States 🇺🇸 — DPA available at cloudflare.com/gdpr/introduction

Resend, Inc. — Transactional email delivery (account confirmation, security, alerts) — United States 🇺🇸 — DPA available at resend.com/legal/dpa

RevenueCat, Inc. — Technical management of in-app subscriptions — United States 🇺🇸 — DPA available at revenuecat.com/dpa

650 Industries, Inc. (Expo) — Delivery of push notifications to the mobile apps and distribution of app updates — United States 🇺🇸 — Legal information available at expo.dev

Enable Banking — Bank aggregation (AISP, PSD2) — European Union 🇪🇺 — Legal information available at enablebanking.com

SnapTrade — Brokerage connections (read-only) — Legal information available at snaptrade.com

GitHub, Inc. — Recipient of the AEGIS Module GITHUB command (public API lookup) — United States 🇺🇸 — EU-US Data Privacy Framework certified

Meta Platforms Ireland Limited — Advertising-audience measurement via the Conversions API (CAPI) on the marketing website, ONLY subject to the visitor's consent — Ireland 🇮🇪 (US transfers covered) — EU-US Data Privacy Framework certified — joint controller for this measurement

GitHub, Inc. does not act as a processor within the meaning of Article 28 GDPR but as a mere recipient: Ad Viternam does not entrust any processing to GitHub on its behalf; it consults a public API service. The other AEGIS Module sources (DNS resolvers, RDAP registries, certificate transparency logs, BGP routing data, CVE registries, OUI registry) receive only technical data relating to no identified person.

Users' personal data is not sold, exchanged or transferred to third parties.

Art. 17International data transfers

Several of Ad Viternam's processors are established in the United States. Transfers to these entities are governed by the European Commission's Standard Contractual Clauses (Decision 2021/914), the EU-US Data Privacy Framework (DPF) for certified entities, and a transfer impact assessment (TIA) for each processor concerned.

The transmission of identifiers to GitHub, Inc. under the AEGIS Module GITHUB command falls under the same framework: GitHub, Inc. is certified under the EU-US Data Privacy Framework, and no additional transfer instrument is required.

Data is hosted in Switzerland with Infomaniak. Switzerland benefits from a European Commission adequacy decision. The Swiss Federal Act on Data Protection (nFADP), in force since 1 September 2023, is aligned with the GDPR. Backups and technical logs, encrypted before transfer, are stored in the European Union.

For users residing outside the European Union, the United Kingdom, Switzerland and North America, use of the Platform is at their sole responsibility. Such users must ensure compliance with their applicable local law.

Art. 18Cookies and trackers

The Platform does not use tracking cookies. Audience analytics are performed through Cloudflare Analytics, a server-side aggregated analytics tool that uses no cookies, does not track individual users and does not fingerprint devices; this audience measurement requires no consent. Advertising-effectiveness measurement via Meta's Conversions API (Meta Platforms Ireland Limited), however, is subject to your prior consent, collected via a dedicated banner on the marketing website, and may be refused or withdrawn at any time (see Article 16 and the legal notice).

The web app sets a single strictly necessary cookie, inaccessible to scripts (httpOnly), which keeps the signed-in User's session. It requires no consent and is removed on sign-out.

Art. 19Rights of data subjects

Right of access (Art. 15): Obtain a copy of their processed personal data.

Right to rectification (Art. 16): Have inaccurate or incomplete data corrected.

Right to erasure (Art. 17): Obtain deletion of their data (purge within 72 hours — Article 14.7).

Right to restriction (Art. 18): Obtain restriction of processing in the cases provided for.

Right to portability (Art. 20): Receive their data in a structured, machine-readable format.

Right to object (Art. 21): Object to processing based on legitimate interest.

Right to withdraw consent: Withdraw consent at any time, including for bank connections and the use of transactions for machine-learning purposes.

Right to post-mortem directives: In accordance with the French Data Protection Act.

Profile data rectification, consent withdrawal and account deletion are performed directly from the User's personal space. The rights of access and portability, as well as the other rights, are exercised by email to [email protected]; a copy of the data is then sent in a structured, machine-readable format. Ad Viternam undertakes to respond within one month. If unsatisfied, the User may lodge a complaint with the CNIL (www.cnil.fr) or the competent authority in their country of residence.

PART III — COMMON PROVISIONS