Privacy
Policy

BTC Breakout — Libertas Project Management – FZCO

Effective Date: 1 July 2026
Last Updated: 1 July 2026

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, country of residence, date of birth
• Date of Birth: Collected during registration to verify you meet the minimum age requirement (18 years) and to support identity verification and compliance with applicable financial regulations in your jurisdiction
• Gender: Optionally provided during registration. Used for demographic analysis and service personalisation. You may select “Prefer not to say” or leave this field blank
• Broker Credentials: MT4 account details (encrypted at rest and in transit using industry-standard encryption)
• Communication Data: Support requests, feedback, and correspondence
• Testimonial Data: Reviews and feedback you voluntarily provide for publication

1.2 Information Collected Automatically

• Usage Data: Pages visited, features used, time spent on the dashboard
• Device Data: Browser type, operating system, screen resolution
• Log Data: IP addresses, access timestamps, error logs
• Cookie Data: Session identifiers, preference settings, and affiliate tracking identifiers (see Section 9)

1.3 Information from Third Parties

• Payment Processor: Transaction confirmation, payment status, and fraud prevention data
• Cloud-Hosted Trade Execution Infrastructure Provider (Tradesync): Connection status, trade execution confirmations, account status events, cloud-hosted execution events, and trade data. Tradesync is operated by Ttech Solutions Limited, a company incorporated under the laws of Hong Kong with company number 2928825. Your MT4 credentials are transmitted to Tradesync via their API to establish and maintain your broker connection.
• Affiliate Tracking Provider: Affiliate attribution data, including referral tracking cookies set when you visit btcbreakout.com via an affiliate link

1.4 Information Collected Through Community Platforms

If you access BTC Breakout’s supplementary community features on Telegram or Discord (“Community Platforms”), we may collect:

• Platform Identifiers: Your Telegram user ID, Discord user ID, or username, for the purpose of linking your Community Platform identity to your BTC Breakout account and managing access
• Interaction Data: Messages sent to Company bots or within Company-managed channels, commands issued to bots, and bot responses, for the purpose of providing the community service and improving its functionality
• Moderation Data: Records of content moderation actions (warnings, mutes, bans) taken by Company moderators

Community Platforms are operated by independent third parties (Telegram FZ-LLC and Discord Inc.). When you use these platforms, the platform operator independently collects and processes data about you in accordance with its own privacy policy. The Company does not control and is not responsible for data processing by these third-party platform operators.

2. How We Use Your Information

We use your personal data to:

• Provide and maintain the Service
• Process payments and manage subscriptions
• Connect your broker account to our cloud-hosted trade execution infrastructure via the Tradesync API
• Communicate with you about your account, support requests, and service updates
• Send transactional emails (account confirmations, credential approvals, subscription reminders)
• Detect and prevent fraud, abuse, and unauthorised access
• Comply with legal obligations
• Verify that you meet the minimum age requirement for access to the Service
• Support identity verification and compliance with applicable financial regulations
• Personalise communications and improve user experience using demographic data you have chosen to provide
• Operate internal technical monitoring and reconciliation of account, trade, and connection-event data for service delivery, support investigation, service integrity, security, and abuse prevention
• Improve the Service through aggregated, anonymised analytics

We do not sell your personal data to third parties.

3. Legal Basis for Processing (GDPR)

For the purposes of GDPR and UK GDPR, the Company acts as Data Controller for personal data collected and processed through the Service, including account data, payment records, usage logs, affiliate attribution data, and consent records. Where the Company engages third-party service providers, those providers generally act as Data Processors on the Company’s behalf under appropriate contractual safeguards. Separately, if you give specific consent for us to share your name and email address with the affiliate partner who directly referred you, that affiliate receives the information as an independent controller for the limited onboarding-support purpose described in Section 4.

4. Information Sharing

We share your personal data only in the following circumstances:

• Third-Party Service Providers: We use third-party providers to operate the Service, including providers for payment processing, database and authentication services, application hosting, email delivery, affiliate tracking, and trade execution infrastructure. These providers process your data only as necessary to perform their services and are contractually bound to protect your data.
• Your direct referrer (affiliate partner): If you joined through a referral link and you give us your specific consent, we share your name and email address with the affiliate partner who directly referred you, so they can welcome you and support your onboarding. That affiliate acts as an independent controller of this information and is contractually required to use it only for that purpose, protect it, not sell it or disclose it onward, and delete it when required after withdrawal or erasure. This sharing is optional and is never a condition of your purchase, subscription, account, support, price, or trading access.
• Legal Requirements: We may disclose your data if required by law, court order, or government request, or to protect our rights, safety, or property.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction with equivalent protections.

5. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of sensitive data at rest and in transit (including broker credentials)
• Role-based access controls with audit logging
• Rate limiting and brute force protection
• Regular security assessments
• Restricted access to personal data on a need-to-know basis

No method of electronic storage or transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

6. Data Retention

7. Your Rights (GDPR & Applicable Law)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention requirements)
• Restriction: Request restriction of processing in certain circumstances
• Portability: Receive your data in a structured, commonly used format
• Objection: Object to processing based on legitimate interest
• Withdraw Consent: Where processing is based on consent, withdraw at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days (or as required by applicable law).

Processing of your date of birth for age verification is based on legal obligation and cannot be objected to. If you have provided gender data, you may request its deletion at any time without affecting your access to the Service.

8. International Data Transfers

Personal data may be transferred to and processed in countries outside the EEA/UK, including the United States, the United Arab Emirates, and Hong Kong (where our cloud-hosted trade execution infrastructure provider, Ttech Solutions Limited (company number 2928825), is incorporated), where our company and certain third-party service providers operate.

For all international transfers, we ensure appropriate safeguards are in place, including:

• EU Standard Contractual Clauses (SCCs) – Module 1 (Controller to Controller) for consent-based affiliate-recipient transfers
• EU Standard Contractual Clauses (SCCs) – Module 2 (Controller to Processor) for processor transfers
• UK International Data Transfer Agreement (IDTA) or Addendum, as applicable
• Adequacy decisions where applicable

Where your direct referrer receives your name and email address after your consent and is located outside the EEA or UK, that disclosure may involve an international controller-to-controller transfer. We use the EU Standard Contractual Clauses Module 1 (Controller to Controller), the UK International Data Transfer Addendum or International Data Transfer Agreement where applicable, and a transfer risk assessment where required.

Copies of relevant transfer mechanisms are available upon request.

9. Cookies and Tracking

We use cookies and similar technologies for:

• Essential Cookies: Required for the Service to function (authentication, session management, security)
• Analytics Cookies: To understand how users interact with our Service (usage patterns, page views)
• Preference Cookies: To remember your settings and preferences
• Affiliate Tracking Cookies: If you visit btcbreakout.com via an affiliate referral link, our affiliate tracking platform may set a cookie to attribute your registration or purchase to the referring affiliate. This cookie stores a referral identifier and attribution metadata. It does not, by itself, disclose your name or email address to affiliates. Separately, if you give specific consent after purchase or in your dashboard, we may share your name and email address with the affiliate partner who directly referred you. You can withdraw that sharing consent at any time.

You can manage cookie preferences through your browser settings. Blocking essential cookies may prevent the Service from functioning correctly.

For users located in the EEA or UK, we obtain your consent before setting non-essential cookies, including analytics cookies and affiliate tracking cookies where required. Cookie consent is separate from the optional referral-identity sharing consent described above. You may withdraw cookie consent or update your preferences at any time through the cookie mechanism or your browser settings.

10. Children’s Privacy

The Service is not intended for anyone under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or dashboard notification at least 14 days before they take effect. Your continued use of the Service after the effective date constitutes acceptance of the revised policy.

12. Contact and Data Protection

For questions about this Privacy Policy or to exercise your data rights:

Email: [email protected]
Company: Libertas Project Management – FZCO
Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, UAE

12.1 Data Protection Contact

Although the Company is not required to appoint a Data Protection Officer under Article 37 of the GDPR, we have designated a data protection contact point for all GDPR-related enquiries:

Email: [email protected]

If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority.