Privacy Policy

1. Data Controller

The data controller for the purposes of this Privacy Policy is:

Vincitore group s.r.o.

Lichnerova 132/40, 903 01 Senec, Slovak Republic

Company ID: 55 805 906

Registered in the Commercial Register of the Municipal Court Bratislava III, Section: Sro, File No. 174171/B

Contact: hello@vincitore.group

2. Key Definitions

For the purposes of this Policy, terms such as "personal data," "processing," "controller," "processor," and "data subject" have the meanings given to them in Regulation (EU) 2016/679 (GDPR).

3. What Personal Data We Collect

We collect personal data in two situations only, and in both cases only to the extent needed for that specific situation:

• Website visitors and enquiries. When you use the contact form on this website, we collect the information you provide (name, email address, and the content of your message). We do not require registration or an account to browse this website.
• Trading counterparties. Vincitore group s.r.o. trades crypto-assets in its own name, on its own account and at its own risk, using its own capital, meeting counterparties on peer-to-peer platforms. Before settling a specific trade, and only where required by the applicable P2P platform's own rules or by our AML/CTF obligations under Slovak law, we (or our identity verification provider on our behalf) may collect identification data about the counterparty to that specific trade — such as full name, date of birth, a government-issued identification document, and, where the verification method requires it, a photograph or short video used to confirm the document belongs to the person presenting it. This data is tied to the individual trade being verified; it is not used to build an ongoing customer profile, because no ongoing customer relationship exists.

We do not operate client accounts, we do not hold funds or crypto-assets on behalf of third parties, and we do not collect personal data for the purpose of onboarding users to a service, because Vincitore group s.r.o. does not provide crypto-asset services or any other services to third parties.

4. Special Categories of Personal Data

We do not seek to collect special categories of personal data (e.g. data revealing racial or ethnic origin, health data, biometric data). Where our identity verification provider processes biometric data as part of a standard identity-verification check on a trading counterparty, this is carried out by that provider under its own privacy notice, and only to the extent required to meet our AML/CTF due diligence obligations.

5. Sources of Personal Data

We collect personal data directly from the individual concerned — either through the contact form, or, for trading counterparties, through the identity verification process carried out in connection with a specific trade.

6. Purposes and Legal Bases for Processing

We do not process personal data for marketing purposes, we do not use it to profile individuals beyond the specific trade being verified, and we do not sell personal data to third parties.

7. Cookies and Similar Technologies

This website uses only technical cookies necessary for it to function (for example, to remember your cookie consent choice or to support basic site navigation). We do not use advertising or cross-site tracking cookies, and we do not use cookies to build a marketing profile of visitors.

8. Data Sharing

Personal data about a trading counterparty flows through a small, fixed set of parties in connection with a specific trade: the counterparty provides identification data to our identity verification provider (or, where the P2P platform runs its own verification, to that platform); the verification provider confirms the outcome of the check to us; and we retain only what is necessary to demonstrate that our AML/CTF obligations were met for that trade. We do not share this data onward for any purpose beyond that.

More specifically, we may share personal data with:

• Our identity verification provider, engaged solely to carry out due diligence checks on trading counterparties where legally required;
• IT and hosting providers who support the operation of this website;
• Competent authorities (e.g. the Financial Intelligence Unit or the National Bank of Slovakia) where we are legally required to report or disclose information, including in response to a specific supervisory or banking enquiry.

We do not share personal data with any party for that party's own marketing purposes, and we do not share it with the P2P platforms themselves beyond what those platforms already collect directly as part of their own verification process.

9. Processors and Subprocessors

Personal data may be processed on our behalf by service providers acting as processors, under a data processing agreement. This currently includes KYCAID, engaged to carry out identity verification and sanctions/PEP screening of trading counterparties, and our website hosting provider, engaged to operate and maintain this website.

10. International Transfers

Where a processor is located outside the European Economic Area, we ensure an adequate level of protection through appropriate safeguards, such as the European Commission's Standard Contractual Clauses.

11. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected. Identification data collected for AML/CTF due diligence purposes is retained for the period required by Act No. 297/2008 Coll. Enquiries submitted via the contact form are retained only for as long as needed to address them, unless a longer period is required by law.

12. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure.

13. Your GDPR Rights

Subject to the conditions set out in the GDPR, you have the right to: access your personal data; request rectification or erasure; request restriction of processing; object to processing; request data portability; and withdraw consent at any time where processing is based on consent. To exercise these rights, contact us at hello@vincitore.group.

14. Complaints

If you believe your personal data has been processed unlawfully, you have the right to lodge a complaint with the Slovak Office for Personal Data Protection (Úrad na ochranu osobných údajov Slovenskej republiky).

15. Automated Decision-Making

We do not make decisions that produce legal or similarly significant effects based solely on automated processing.

16. Minors

This website is not directed at, and we do not knowingly collect personal data from, individuals under the age of 18.

17. Third-Party Platforms and Websites

This website may reference P2P platforms operated by third parties. Vincitore group s.r.o. is not responsible for the privacy practices of any third-party platform, and any activity conducted directly on such a platform is governed by that platform's own privacy policy.

18. No Customer Relationship

Visiting this website, or submitting an enquiry through it, does not create a client, customer, or service-provider relationship with Vincitore group s.r.o. Vincitore group s.r.o. trades crypto-assets in its own name, on its own account and at its own risk, using its own capital, meeting its counterparties as an equal party to each trade rather than as their service provider. It does not provide custody, exchange services, order execution, portfolio management, investment advice, or any other crypto-asset service to third parties. Where we collect a trading counterparty's identification data, this reflects only our own AML/CTF due diligence obligations as a trading business under Slovak law — it is not, and should not be read as, evidence of an onboarding, account-opening, or service-subscription process, because no such process exists. This Privacy Policy, like the rest of this website, describes the data handling of a proprietary trading company, not of a crypto-asset exchange or service provider.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page indicates when it was last revised.

20. Contact

For any questions about this Privacy Policy or our data processing practices, contact us at hello@vincitore.group or at our registered office: Lichnerova 132/40, 903 01 Senec, Slovak Republic.