Version 0.1 · 16 July 2026. This document is provisional and is under review by counsel.
Actum is the controller of the personal data described in this policy. The controller’s legal name, registered office, and registration number will be completed at incorporation. Until then, reach us at privacy@actum.capital.
Account data: your email address, display name, phone number if you add one, and password (stored only as a hash). Identity-verification data: when you originate a first listing, or where the law requires it, our verification provider collects identity documents and screening data on our behalf; we store the outcome, not your documents. Transaction records: deposits, purchases, bids, holdings, withdrawals, and receipts. Device data: if you use the mobile app, a push notification token and a device name. Support messages: what you write to us when you ask for help.
To run the service you signed up for — accounts, listings, purchases, transfers, notifications — we process your data to perform our contract with you. To meet legal obligations — anti-money-laundering rules, sanctions screening, tax reporting, and record-keeping — we process what those laws require. To keep the service secure and improve it — fraud prevention, error monitoring, audit logging — we rely on our legitimate interests. Where we ask for consent, such as optional emails, you can withdraw it at any time.
We use a small set of processors, each for one job: Stripe (payment processing); Sumsub (identity verification); Resend (transactional email); Vercel (application hosting); Neon (database hosting); Sentry (error monitoring); Expo (mobile push notifications). Each processor handles data under a contract with us. We do not sell your data, and we do not use third-party advertising or analytics services.
When you close your account, we erase and anonymize your personal data: your email, name, phone number, and sign-in credentials are removed, and your favorites, saved searches, and notification settings are deleted. Financial, identity-verification, and audit records are retained — detached from you as a person — for the period anti-money-laundering law requires. We keep those records because the law obliges us to, and we purge them when that period ends.
Access and portability: you can download everything we hold on you from your account page, as a machine-readable JSON file. Rectification: you can correct your profile details in your account settings, or ask us to. Erasure: closing your account erases your personal data, subject to the legal retention described above. Objection: you can object to processing based on our legitimate interests. Complaint: you can complain to your data-protection supervisory authority at any time.
Some of our processors operate outside your country. Where data leaves the European Economic Area, we rely on recognized transfer safeguards such as standard contractual clauses. The exact arrangements will be confirmed by counsel and detailed here before launch.
Questions about this policy or your data: privacy@actum.capital. See also our terms of service and cookie policy.