Latvian FTS Privacy Policy

Introduction

Verveni Technologies is a technology and quantitative software company established in Bulawayo, Zimbabwe:

• Entity Name: Verveni Technologies (operating Latvian FTS)
• Headquarters / Operating Office: Bulawayo, Zimbabwe
• Official Inquiries & Privacy Contact: latvianfts@gmail.com / joydmoyo@verveni.com

This Privacy Policy applies to:

• Our web platform and marketplace at https://latvianfts.verveni.com (the "Platform" or "Store")
• Our proprietary algorithmic trading software products, indicators, and Expert Advisors (the "Product")
• Our trading academy video curriculums, masterclasses, and student portals
• All related services, licensing systems, and support channels (collectively, the "Services")

By accessing the Platform, purchasing or accessing courses, activating EA software licenses, or using our Services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you must discontinue use of the Platform and Services immediately.

1. Data Controller and Scope

1.1 Data Controller

Verveni Technologies is the sole and exclusive data controller (within the meaning of the Cyber and Data Protection Act [Chapter 12:07] of Zimbabwe, the EU General Data Protection Regulation (GDPR), and other applicable data protection frameworks) for all personal data collected, processed, or stored in connection with the Platform, Product, Services, and member accounts.

As data controller, Verveni Technologies determines:

• What personal data is collected
• How personal data is utilized, analyzed, and processed
• Retention schedules for personal data
• With whom personal data may be shared under strict data processing agreements
• Technical and organizational measures for safeguarding information

1.2 No Joint Controllers

No third party (including cloud infrastructure providers, Google LLC for OAuth 2.0 authentication, database hosts, IT consultants, analytics providers, or payment gateways) acts as a joint controller of your personal data. Any data processing performed by service providers is conducted strictly on behalf of Verveni Technologies as data processors under documented instructions and data processing agreements.

1.3 User Relationship and Rights

Your data protection rights under applicable law are exercisable solely against Verveni Technologies as the data controller. You have no direct data protection relationship with, and may not assert data subject claims directly against, any third-party infrastructure provider or processor engaged by Verveni Technologies. All data subject access requests, complaints, or inquiries must be directed to Verveni Technologies at latvianfts@gmail.com.

1.4 Scope of This Policy

This policy applies strictly to data collected by Verveni Technologies through Latvian FTS websites, applications, and customer support. It does NOT apply to third-party brokerage firms, MetaTrader servers, or external trading platforms you independently connect to.

2. Personal Data We Collect

2.1.1 Account & Google Authentication Data

To deliver a streamlined Udemy-grade onboarding experience, Latvian FTS authenticates users via Google Sign-In (OAuth 2.0). When creating an account or logging in, we collect:

• Full name (given name and family name)
• Verified Google email address
• Profile avatar photo URL (from your Google account)
• Unique Google Account Subject ID
• Marketing consent preference (opt-in checkbox)
• Account role and permission timestamps

2.1.2 Order & Licensing Information

When you enroll in courses or acquire an Expert Advisor (EA) license, we record:

• Course enrollment status and video progress tracking
• Generated algorithmic license keys (e.g. LFTS-ALPH-XXXX-XXXX)
• Transaction identifiers and timestamps
• Zero Card Storage: We do NOT collect, process, or store full credit card numbers, CVVs, or bank secrets. Payment transactions are handled directly through compliant, certified payment gateways.

2.1.3 Technical & Platform Usage Data

When you navigate the platform, we automatically receive technical telemetry: IP address, device type, browser specifications, session cookies, crash logs, and page load performance.

2.2 Special Categories of Data

We do not collect sensitive data such as biometric identifiers, political affiliations, religious beliefs, medical history, or trade union membership.

2.3 Age Restriction (18+)

Our platform, algorithmic trading education, and software tools are designed exclusively for individuals aged 18 years and older. We do not knowingly collect personal data from minors.

3. How We Use Your Personal Data

We process personal data based on the following legal bases:

• Performance of a Contract: Creating and managing your member account, granting video curriculum access, issuing unique EA license keys, and providing customer support.
• Legitimate Interests: Protecting platform security, detecting fraud, verifying license integrity, and improving user interface performance.
• Consent: Delivering quantitative strategy briefs, product announcements, and market research newsletters when opted in. You may opt out at any time.
• Legal Compliance: Satisfying tax, accounting, and anti-fraud regulations.

4. How We Share Your Personal Data

We never sell, rent, or trade your personal data to third parties. Data is shared solely with vetted infrastructure partners necessary to operate the platform:

• Google Identity Services (Google LLC): For secure OAuth 2.0 authentication and profile verification.
• Cloudflare R2 Storage: For secure streaming of educational masterclasses and downloadable EA assets.
• Database & Infrastructure Providers: Highly secured, encrypted cloud databases and Google Cloud servers for hosting application services.
• Legal Authorities: Only when strictly required by a binding court order, subpoena, or lawful regulatory directive.

5. International Data Transfers

Verveni Technologies is based in Zimbabwe. In delivering global digital trading education, your data may be processed on secure cloud infrastructure situated internationally (including the United States and the European Union). All transfers are conducted under industry-standard contractual clauses, strong cryptographic safeguards, and strict confidentiality agreements.

6. Data Retention

7. Data Security

Verveni Technologies implements enterprise-grade security protocols, including 256-bit TLS/SSL encryption in transit, strict session isolation, hashed credentials, and multi-region database replication. While we employ rigorous defenses, no digital infrastructure can guarantee 100% invulnerability. Members are responsible for protecting their personal Google authentication devices and accounts.

8. Cookies and Session Storage

Latvian FTS utilizes essential cookies strictly necessary for platform operation: maintaining your authenticated login session (connect.sid), preserving course navigation state, and remembering your interface preferences. We do not use intrusive advertising tracking networks.

9. Your Legal Privacy Rights

Regardless of your jurisdiction, Verveni Technologies honors the core principles of data privacy:

• Right of Access: Request a copy of the personal information we hold regarding your account.
• Right to Rectification: Request correction of inaccurate profile data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your account and associated personal data, subject to lawful retention requirements.
• Right to Restriction & Objection: Object to processing of personal data for direct marketing or quantitative updates.
• Right to Data Portability: Obtain your course completion and license data in an organized digital format.

To exercise any of these rights, email us at latvianfts@gmail.com with the subject line "Data Subject Request". We will respond within 30 days.

10. Broker & Trading Platform Disclaimer

Latvian FTS provides educational courses and algorithmic Expert Advisor software. Verveni Technologies is not a financial broker or custodian of customer trading balances. When you install our Expert Advisors onto third-party trading terminals (such as MetaTrader 4/5), your financial deposits, live trade execution, and brokerage personal data are governed exclusively by your chosen broker's privacy policy.

11. Changes to This Policy

We may update this Privacy Policy periodically to reflect technological enhancements, operational changes, or statutory regulations. Any revisions will be published on this page with an updated "Last Updated" date. Continued use of our Platform following posted revisions indicates your acknowledgment and acceptance.

12. Contact & Regulatory Information

13. Governing Law & Jurisdiction

This Privacy Policy and any disputes arising under it shall be governed by and construed in accordance with the laws of Zimbabwe, with full regard to applicable international data protection standards for our global student body.