Privacy Policy

1. Introduction

The Black Vault Funding, Inc. ("Company," "we," "us," or "our") is committed to protecting the privacy of individuals who interact with our platform, website, and evaluation programs. This Privacy Policy describes how we collect, use, store, disclose, and protect personal information in connection with our services. This Policy is governed by applicable Minnesota state law, including the Minnesota Government Data Practices Act (Minn. Stat. Chapter 13) principles as they apply to private entities, and federal privacy law where applicable.

By using our platform, you consent to the practices described in this Privacy Policy. If you do not agree with this Policy, please do not use our platform or services.

2. Information We Collect

Information You Provide Directly:

• Account registration information: name, email address, country of residence, date of birth (for age verification)
• Payment information: processed through third-party payment processors; we do not store full payment card numbers
• Identity verification documents: government-issued ID, as required for payout eligibility review
• Communications: emails, support requests, and feedback submitted to us

Information Collected Automatically:

• Log data: IP address, browser type, operating system, referring URLs, pages viewed, and timestamps
• Device identifiers: unique device identifiers used to detect multi-accounting or policy violations
• Trading activity data: all simulated trade data, account metrics, and session activity within the platform
• Cookies and similar tracking technologies (see Section 6)

3. How We Use Your Information

We use the information we collect for the following purposes:

• To create and manage your account and provide access to evaluation programs
• To process payments and administer program fees through third-party payment processors
• To evaluate your simulated trading performance and administer evaluation outcomes
• To verify your identity for payout eligibility review as required by our Payout Policy
• To communicate with you about your account, program updates, and policy changes
• To detect, investigate, and prevent fraud, policy violations, and prohibited conduct
• To improve our platform, products, and services
• To comply with legal obligations and enforce our Terms of Service
• To send promotional communications where you have opted in (you may opt out at any time)

4. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

• Service Providers: Third-party vendors who assist us in operating the platform, processing payments, sending communications, or providing customer support, subject to confidentiality obligations
• Platform and Technology Partners: Providers of the trading simulation platform or data infrastructure necessary to deliver our services, who are contractually prohibited from using your data for their own purposes
• Legal Compliance: When required by applicable law, court order, regulatory authority, or to protect the rights, property, or safety of the Company, its users, or the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with appropriate notice and subject to the same privacy protections
• With Your Consent: For any other purpose with your explicit consent

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including maintaining your account, complying with legal obligations, resolving disputes, and enforcing our agreements. Evaluation program data, including simulated trade history and account records, may be retained for a minimum of three (3) years for audit, compliance, and dispute resolution purposes. Identity verification documents are retained only as long as required for payout processing and then securely deleted.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate the platform, authenticate users, maintain session security, remember preferences, and analyze usage patterns. You may configure your browser to reject cookies, but doing so may impair the functionality of the platform. We do not use third-party advertising cookies or behavioral advertising networks. Analytics cookies, if used, are configured to anonymize IP addresses and are subject to data processing agreements with our analytics providers.

7. Your Rights and Choices

Subject to applicable law, you have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete personal information
• Deletion: Request deletion of your personal information, subject to retention obligations
• Opt-Out of Marketing: Unsubscribe from promotional communications at any time via the unsubscribe link in any email or by contacting us directly
• Data Portability: Request your data in a structured, commonly used format where technically feasible

To exercise any of these rights, contact us at [email protected]. We will respond to verifiable requests within thirty (30) days. We may require identity verification before processing data requests.

8. Security

We implement commercially reasonable technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit (TLS), access controls, and regular security reviews. No system is completely secure, and we cannot guarantee the absolute security of your information. You are responsible for maintaining the security of your account credentials.

9. International Users

Our platform is operated from the United States. If you access the platform from outside the United States, your personal information will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction. By using the platform, you consent to this transfer and processing.

10. Children's Privacy

The platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a person under 18, we will promptly delete it. If you believe a minor has provided us with personal information, contact us at [email protected].

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the platform before they take effect. Your continued use of the platform after any such changes constitutes your acceptance of the updated Policy.

12. Contact

For privacy-related inquiries, data subject requests, or questions about this Policy, contact: The Black Vault Funding, Inc., Attn: Privacy, [email protected]