Privacy Policy

Last Updated: January 15, 2026

1. Data Controller Identification

Bach Nganloc acts as the primary data controller for the personal details processed through our website, algorithms, and interface services. If you have questions concerning our data stewardship routines, contact our data protection officer via email at [email protected].

2. Categories of Information Collected

We process only such personal data as is necessary to supply our computational and trading orchestration services. Information categories include:

• Identity & Contact Details: Full name, verified email address, telephone contact numbers, and jurisdictional residency information submitted during platform onboarding.
• Technical & Telemetry Data: IP address, browser build, operating platform, device hardware profiles, routing timestamps, and network latency metrics collected automatically during user sessions.
• Trading Telemetry & System Usage: API interaction frequency, execution preference toggles, chosen algorithmic parameters, stop-loss ratios, and interface responsiveness logs.
• Communications Records: Written records of correspondence, support queries, bug notifications, and diagnostic logs shared with our help desk.

3. Legal Bases for Processing Under UK GDPR

In adherence to UK data privacy standards, we process your personal data exclusively under the following lawful bases:

• Contractual Performance (Article 6(1)(b)): To initialize software instances, allocate algorithmic resources, establish broker connectivity, and deliver platform services requested by you.
• Legitimate Interests (Article 6(1)(f)): To safeguard infrastructure integrity, prevent algorithmic abuse, detect denial-of-service attempts, and upgrade execution speed.
• Legal Compliance (Article 6(1)(c)): To satisfy statutory recordkeeping, financial audit standards, and mandatory requests from competent judicial or statutory bodies in the United Kingdom.
• Consent (Article 6(1)(a)): For non-essential tracking cookies and direct technical notifications where specific, voluntary authorization was requested.

4. Purpose of Data Processing

Your information is utilized strictly for the following operational workflows:

• Configuring secure user access to the Bach Nganloc computational dashboard.
• Facilitating API link handshakes between user accounts and third-party execution venues.
• Conducting risk monitoring to protect systems against coordinated latency attacks or malicious scrapers.
• Distributing mission-critical service advisories, software patches, and security alerts.
• Refining algorithmic efficiency and calculating analytical models based on anonymized performance data.

5. Cookie Policy & Tracking Technologies

We utilize essential and operational session cookies. Essential cookies are required to authenticate active user sessions, maintain cross-page state, and enforce security policies. We do not sell tracking profiles to external data brokers. You may adjust cookie preferences within your browser settings; disabling strictly essential cookies may impair platform operation.

6. Data Sharing & Third-Party Transfers

Bach Nganloc preserves strict confidentiality over user data. We do not monetize your private information. We share personal data only under bounded arrangements with:

• Cloud hosting providers and infrastructure hosts operating high-security servers located within the United Kingdom and the European Economic Area (EEA).
• Authorized execution brokerages and liquidity providers with whom you deliberately configure system integrations.
• Legal, compliance, and regulatory authorities where compelled by valid court summons or United Kingdom statutory enactments.

When data is transmitted outside the UK, we implement robust transfer safeguards, including UK International Data Transfer Agreements (IDTA) or standard contractual clauses guaranteeing equivalent protection standards.

7. Data Security & Retention Schedules

We deploy defensive measures, including end-to-end TLS 1.3 cryptographic transport protocols, AES-256 data-at-rest encryption, partitioned database structures, and role-based access governance. Telemetry and session records are purged regularly once their diagnostic utility terminates.

Account records are maintained throughout the active lifespan of your service registration and for up to six (6) years following account closure to comply with statutory accounting and dispute limitation periods in England and Wales.

8. Your Statutory Rights Under UK GDPR

As a data subject, you hold statutory rights enforceable without charge:

• Right of Access: Obtain confirmation of processing and request copies of your held personal data.
• Right to Rectification: Request correction of inaccurate, incomplete, or outmoded information.
• Right to Erasure: Request the deletion of personal data when retention is no longer justified by law.
• Right to Restriction: Request limitation of processing under specific contestation conditions.
• Right to Data Portability: Receive your provided data in a structured, commonly used, machine-readable format.
• Right to Object: Oppose processing grounded solely on legitimate corporate interests.

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk if you believe our data processing contravenes legal guidelines.

9. Policy Revisions & Direct Inquiries

We update this Privacy Policy periodically to match changes in algorithmic functionality or legislative developments. Direct your privacy requests to:

Bach Nganloc Privacy Office
High Holborn 145, LS1 5AT Leeds, United Kingdom
Email: [email protected]
Telephone: +44 20 7946 7049