Privacy Policy - Beta Preview

1. Introduction

The Treanova beta platform ("we," "us," or "our") is committed to protecting your privacy during our testing phase. This Privacy Policy explains how we handle information during the beta period. As we are in pre-launch validation, we collect only essential data needed to improve our platform and gather feedback.

This policy applies to all personal data we process, including data from:

• Visitors to our website
• Users of our Services
• Business contacts and partners
• Job applicants and employees

2. Beta Phase Data Handling

During our beta phase, the Treanova founding team handles all data with care, following privacy best practices even before formal incorporation. We are transparent about our pre-launch status.

3. Types of Data We Collect

3.1 Personal Identification Data

• Name and surname
• Email address
• Phone number
• Company name and position
• Business address
• User account credentials

3.2 Financial Data

• Bank account information (for service provision)
• Transaction history and patterns
• Financial reports and statements
• Payment information (for billing purposes)
• Cash flow and treasury data

3.3 Technical Data

• IP address and device information
• Browser type and version
• Operating system
• Access times and dates
• Pages viewed and actions taken
• Cookies and similar tracking technologies

3.4 Communication Data

• Email correspondence
• Support tickets and inquiries
• Feedback and survey responses
• Call recordings (with consent)

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under the General Data Protection Regulation (GDPR):

4.1 Contract Performance

Processing necessary to perform our contract with you or to take steps at your request before entering into a contract, including:

• Providing access to our Services
• Processing transactions and payments
• Customer support and service delivery
• Account management and administration

4.2 Legitimate Interests

Processing necessary for our legitimate interests or those of third parties, including:

• Improving and developing our Services
• Ensuring network and information security
• Fraud prevention and detection
• Direct marketing (with opt-out option)
• Business analytics and reporting

4.3 Legal Obligations

Processing necessary to comply with legal obligations, including:

• Anti-money laundering (AML) requirements
• Know Your Customer (KYC) procedures
• Tax reporting obligations
• Regulatory compliance and audits
• Court orders and legal proceedings

4.4 Consent

Processing based on your explicit consent for:

• Marketing communications
• Cookies and similar technologies
• Sharing data with certain third parties
• Processing sensitive personal data

5. How We Use Your Data

We use your personal data for the following purposes:

5.1 Service Provision

• Creating and managing your account
• Providing treasury management services
• Processing financial transactions
• Generating reports and analytics
• Facilitating bank connections and integrations

5.2 Communication

• Responding to inquiries and support requests
• Sending service-related notifications
• Providing product updates and announcements
• Marketing communications (with consent)

5.3 Improvement and Development

• Analyzing usage patterns and trends
• Developing new features and services
• Conducting research and surveys
• Testing and quality assurance

5.4 Security and Compliance

• Detecting and preventing fraud
• Ensuring platform security
• Complying with legal obligations
• Enforcing our terms and policies

6. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

6.1 Regulated Financial Partners

Licensed financial institutions and payment service providers who provide regulated services through our platform. These partners process your data as independent data controllers under their own privacy policies.

6.2 Service Providers

Third-party vendors who assist us in providing our Services, including:

• Cloud hosting providers (AWS, Google Cloud)
• Analytics and monitoring services
• Customer support tools
• Email service providers
• Payment processors

6.3 Professional Advisors

Lawyers, accountants, auditors, and other professional advisors bound by confidentiality obligations.

6.4 Legal and Regulatory Authorities

Government agencies, regulators, and law enforcement when required by law or to protect our rights and interests.

6.5 Business Transfers

In connection with any merger, acquisition, reorganization, or sale of assets, your data may be transferred to the acquiring entity.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place:

• EU-approved Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Binding Corporate Rules (where applicable)
• Your explicit consent for specific transfers

We regularly review and update our data transfer mechanisms to ensure compliance with applicable laws and regulations.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Our retention periods are:

After the retention period expires, we securely delete or anonymize your personal data.

9. Your Rights

Under the GDPR and applicable data protection laws, you have the following rights:

9.1 Right to Access

Request a copy of your personal data and information about how we process it.

9.2 Right to Rectification

Request correction of inaccurate or incomplete personal data.

9.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data in certain circumstances.

9.4 Right to Restrict Processing

Request limitation of processing in specific situations.

9.5 Right to Data Portability

Receive your data in a structured, machine-readable format and transfer it to another controller.

9.6 Right to Object

Object to processing based on legitimate interests or for direct marketing purposes.

9.7 Right to Withdraw Consent

Withdraw your consent at any time where processing is based on consent.

9.8 Right to Lodge a Complaint

File a complaint with your local data protection authority if you believe we have violated your rights.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against:

• Unauthorized access or disclosure
• Accidental or unlawful destruction
• Loss, alteration, or damage
• Unauthorized processing

Our Security Measures Include:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Access controls and role-based permissions
• Employee training on data protection
• Incident response and breach notification procedures
• Physical security of data centers
• Regular backups and disaster recovery plans

Despite our efforts, no security system is impenetrable. In the event of a data breach, we will notify affected individuals and relevant authorities as required by law.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and analyze usage of our Services. For detailed information, please refer to our Cookie Policy.

Types of cookies we use:

• Essential cookies: Required for the website to function properly
• Performance cookies: Help us understand how visitors use our website
• Functional cookies: Remember your preferences and settings
• Marketing cookies: Used to deliver relevant advertisements (with consent)

12. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child without parental consent, we will take steps to delete that information.

13. Third-Party Links

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending an email notification (for significant changes)
• Displaying a notice in our Services

We encourage you to review this policy periodically to stay informed about our data practices.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: