Privacy Policy

1. Data controller

Immune Systems Brokering ("the Company", "we"), located in Dubai (United Arab Emirates) — registered address [registered address] — is the controller of personal data collected through the website hodlsystem.com and the HODL System brand and software.

For any privacy matter you can write to info@hodlsystem.com.

2. Data we collect

Data you provide: name, email, phone and any information you include when requesting information or contacting us.

Data collected automatically: IP address, device and browser type, pages visited and usage data, via cookies and similar technologies (see our Cookie Policy).

Where applicable, data required for the investment relationship, collected and processed under the relevant private contract.

3. Purposes and legal bases

We process your data to: respond to your requests and provide information (pre-contractual steps and our legitimate interest); manage the contractual relationship where it exists (performance of a contract); comply with applicable legal and regulatory obligations; and, with your consent, send you communications.

Where applicable, we rely on UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection and, for EEA/UK users, on the GDPR.

4. Retention

We keep data for as long as necessary for the purposes described and to meet legal obligations; afterwards it is deleted or anonymised.

5. Recipients and processors

We may share data with providers serving us (hosting, analytics, communications, brokers and entities necessary for operations), which process data on our behalf under contract.

We do not sell your personal data.

6. International transfers

Some providers may be located outside your country. In such cases we apply appropriate safeguards in accordance with applicable law.

7. Security

We apply reasonable technical and organisational measures to protect data. No system is completely secure, so we cannot guarantee absolute security.

8. Your rights

You may exercise the rights of access, rectification, erasure, objection, restriction and portability, and withdraw consent, by writing to info@hodlsystem.com. You may also complain to the competent supervisory authority.

9. Minors

The site and services are intended for adults. We do not knowingly collect data from minors.

10. Changes

We may update this policy. We will post the current version on the site with its update date.