GDPR

Last Updated: 1.1.2026

1. Identity of the Data Controller

The data controller responsible for your personal data is:

Enchions LLC Reg. No.: 2024-001480371 Registered office: 1309 Coffeen Avenue Ste 15526, Sheridan, Wyoming 82801, United States Email: info@putcallflow.cz (hereinafter referred to as “we”, “us” or the “Controller”).

2. What Data We Collect

To provide our automated trading services and server rental, we collect and process the following categories of data:

Identity Data: Information related to your identification as verified by Interactive Brokers (IBKR). We rely on the KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures performed by IBKR. We process data such as your full name and account ownership details to the extent accessible through the broker integration.
Contact Data: Email address, phone number.
Technical & Financial Data: IBKR account ID, trade logs, server access logs, IP address.
Payment Data: Payment history and billing details (we do not store full credit card numbers; payments are processed securely via Stripe).

3. Purpose of Processing

We process your data solely for the following purposes and legal bases:

Contract Performance: To configure the server, connect our algorithms to your IBKR account, and execute trades as per the "Agreement for the Provision of Trading Signals and Server Rental".
Billing: To calculate commissions based on your trading profits (High Water Mark calculation).
Communication: To send you trade alerts, invoices, system updates, and technical notifications.
Security & Compliance: To monitor the server for unauthorized access, technical failures, and to comply with legal obligations.

4. Automated Individual Decision-Making

Our service involves automated decision-making in the form of algorithmic trading execution (buying/selling financial instruments).

Nature of Processing: The algorithms analyze market data and technical indicators, not your personal behavioral traits or personality.
Legal Basis: This automated processing is necessary for entering into and performing the contract (the Service Agreement) between you and the Provider.
Client's Rights: By signing the Agreement, you explicitly request this automated service. You retain the right to intervene manually in your IBKR account at any time, although doing so releases the Provider from liability as per our Terms and Conditions.

5. Data Sharing

We do not sell your personal data. We may share necessary data with:

Service Providers: Hosting providers (for server rental), Stripe (for payment processing), and email delivery services. All providers are bound by confidentiality agreements.
Legal Authorities: If required by law or to protect our rights in case of a legal dispute.

6. International Data Transfers

Since the Controller is established in the United States, your personal data will be transferred to and processed in the U.S., a jurisdiction outside the European Economic Area (EEA). To ensure your data is protected in accordance with GDPR standards, we implement appropriate safeguards:

Standard Contractual Clauses (SCCs): We rely on the European Commission’s approved Standard Contractual Clauses for data transfers between EU and non-EU entities regarding our vendors.
Encryption: All sensitive data transmitted between your device, our servers, and Interactive Brokers is encrypted using industry-standard protocols (TLS/SSL). By using our services, you explicitly consent to this transfer of data to the United States necessary for the performance of the contract.

7. Data Retention

We retain your personal data for the duration of the Agreement and for a subsequent period required by tax and legal regulations (usually 5–10 years after contract termination) to defend against potential legal claims or audits.

8. Data Breach Notification

In the unlikely event of a data breach that is likely to result in a high risk to your rights and freedoms, the Provider undertakes to:

Notify the competent supervisory authority without undue delay (within 72 hours where feasible).
Notify the affected Clients directly without undue delay via email, providing advice on protective measures.

9. Your Rights (GDPR)

Under applicable data protection laws, you have the right to:

Access: Request a copy of the personal data we hold about you.
Rectification: Request correction of inaccurate or incomplete data.
Erasure (Right to be Forgotten): Request deletion of your data, provided that we do not need the data for legal, tax, or defense purposes.
Restriction of Processing: Request that we restrict the processing of your data under certain conditions.
Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise these rights, please contact us at info@putcallflow.cz.

10. Cookies

Our website uses cookies to analyze traffic and improve user experience.

Essential Cookies: Necessary for the website to function (e.g., login, cart). These do not require consent.
Analytical/Marketing Cookies: Used to track visitor behavior. We will only store these cookies on your device if you have given us your explicit consent via the Cookie Banner. You can manage your cookie preferences in your browser settings at any time.