Privacy Policy – SmartFlow Trading

Effective date: 06.02.2026
Last updated: 06.02.2026

This Privacy Notice explains how SmartFlow Trading (“we”, “us”, “our”) collects, uses, stores, and shares personal data when you visit our website, create an account, contact us, subscribe to communications, or make a payment for our services (together, the “Services”).

This Privacy Notice should be read alongside our Cookie Notice, which explains how we use cookies and similar technologies and how you can manage your preferences.

Where we provide a specific service, additional product or service terms (including privacy disclosures) may apply.

1) Who we are 

SmartFlow Trading
Contact email: support@smartflow.trading

If you contact us or submit a request to exercise your rights, we may ask for enough information to verify your identity before we action certain requests. This is to protect your information and prevent unauthorised access.

2) What personal data we collect

We aim to collect and process personal data that is relevant and limited to what is necessary for the purposes described in this notice. The data we collect depends on how you interact with us.

A. Account and customer data (provided by you)

When you create an account or otherwise interact with the Services, we may process:

If you contact us, we also process:

B. Website usage and device data (collected automatically)

When you use our website, we may collect:

Details and controls are provided in our Cookie Notice (including how to grant, refuse, withdraw or change consent for non-essential cookies).

C. Payment-related data

Payments are processed entirely by Stripe. When you pay, your payment details (such as card number and card security code) are provided directly to Stripe and are not stored by us.

We may receive and store limited payment-related information needed to provide the Services and maintain proper records, such as:

D. Marketing subscription data

If you subscribe to marketing messages/newsletters, we process:

E. Data we receive from third parties (limited)

In normal operation, we primarily collect data directly from you or automatically via the website. However, we may receive limited information from:

 

3) Why we use your data and our legal bases 

We process personal data only where we have a lawful basis under GDPR. Depending on the context, we rely on one or more of the following legal bases: contract, legal obligation, legitimate interests, and consent.

A. To provide and manage accounts and Services

Purpose: create and manage your account; provide requested Services; respond to support messages; administer the relationship with you.
Personal data: name, email, communications content and metadata (where relevant).
Legal basis:

B. To process payments and manage billing records

Purpose: enable payment processing via Stripe; reconcile payments; handle receipts/refunds (where applicable); maintain financial records.
Personal data: name, email, limited payment status/reference information, transaction records.
Legal basis:

C. To keep the website secure and prevent misuse

Purpose: security monitoring; preventing and detecting abuse and unauthorised access; troubleshooting; maintaining availability; protecting our systems and users.
Personal data: device data, IP address, logs, cookie identifiers (where applicable), and account identifiers (where applicable).
Legal basis:

D. To understand website performance and improve the Services (analytics)

Purpose: measure and improve website performance and user experience; understand which pages/features are used; diagnose technical issues; improve content and usability.
Personal data: website usage/device data collected via cookies and similar technologies.
Legal basis:

If you do not consent to analytics cookies, we will not use them (but strictly necessary cookies may still be used for the website to function).

E. To send newsletters and marketing communications

Purpose: send marketing communications you request; manage subscriptions and opt-outs; measure campaign effectiveness (where enabled); maintain suppression lists to ensure we respect opt-outs.
Personal data: name (if provided), email, marketing preferences, campaign engagement data (where enabled).
Legal basis:

F. To comply with law and enforce rights

Purpose: comply with applicable laws and lawful requests; establish, exercise, or defend legal claims; investigate complaints; enforce terms and protect our rights.
Personal data: data relevant to the issue (may include account, communications, technical, and transaction data).
Legal basis:

 

4) Cookies and analytics

We use cookies and similar technologies to operate the website, remember preferences, secure the Services, and—if you allow—run analytics.

We use Google Analytics to help understand how visitors use our website. Google Analytics may use cookies or similar technologies to collect usage and device information. We use this information to improve site content, performance, and user experience.

You can manage cookies (including analytics cookies) through our cookie banner and cookie settings, and you can also adjust browser settings to block cookies. For more detail, see our Cookie Notice.

 

5) Marketing communications

If you opt in to marketing:

Opting out: You can unsubscribe at any time using the unsubscribe link in our emails or by contacting support@smartflow.trading. If you unsubscribe, we may keep a record of your opt-out status (for example, on a suppression list) so we can respect your request.

Email tracking: Marketing emails may include tracking (e.g., opens/clicks) where enabled. You can reduce tracking by disabling automatic image loading in your email client and avoiding clicking tracked links.

6) Who we share personal data with

We do not sell your personal data. We share it only where necessary for the purposes described above and subject to appropriate safeguards.

A. Service providers (processors) and platform providers

We use suppliers that help us operate the Services, including:

Depending on the context, these providers may act as processors or as independent controllers. We rely on their documentation for how they process personal data in their role, and we use appropriate contractual and organisational protections where required (for example, data processing terms).

B. Legal and compliance disclosures

We may disclose personal data when required by law, court order, or binding request from a regulator/law enforcement body, or when necessary to protect rights, safety, and the integrity of our Services.

C. Professional advisers

Where necessary, we may share personal data with professional advisers (for example, legal, accounting, or auditors) subject to confidentiality obligations.

D. Business transfers

If we are involved in a merger, acquisition, restructuring, or sale of assets, personal data may be shared with relevant parties (e.g., advisers and the acquiring entity) subject to appropriate safeguards and confidentiality obligations.

 

7) How long we keep your data 

We keep personal data only for as long as necessary for the purposes described in this notice, and then we delete or anonymise it where appropriate. Retention depends on the type of data, the purpose, and legal requirements.

Account data (name, email): kept while your account remains active, and for a limited period afterwards where necessary for support, dispute resolution, enforcement of terms, or legal requirements.

Support communications: kept for as long as needed to address your request and to maintain records for legitimate business purposes, including handling complaints and improving customer support.

Marketing data: kept until you unsubscribe/withdraw consent. After that, we may retain limited information (such as your email address on a suppression list) to ensure we respect your opt-out.

Payment/transaction records: retained for the period required by applicable accounting/tax laws and for financial reconciliation.

Where possible, we delete or anonymise data when it is no longer needed.

8) Your rights

Depending on your circumstances and applicable law, you may have the right to:

How to exercise your rights

Email us at support@smartflow.trading. Please provide enough detail for us to understand and process your request.

Identification and access limits

Response time

We aim to respond within 30 days. This period may be extended where permitted by law (for example, if requests are complex or numerous). If an extension is required, we will inform you.

Right to complain

You may lodge a complaint with your local data protection authority. In Bulgaria, this is the Commission for Personal Data Protection.

9) Children’s data

Our Services are not intended for anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us personal data, contact us at support@smartflow.trading and we will take steps to delete it.

10) Special category (sensitive) data

We do not intentionally collect special category data (such as health data, biometric data, political opinions, religious beliefs, or sexual orientation).

11) Security

We use appropriate technical and organisational measures designed to protect personal data against accidental loss, unlawful destruction, alteration, unauthorised access, or disclosure. Access to personal data is limited to authorised personnel and suppliers who need it to perform their tasks.

If a personal data breach occurs, we will comply with applicable notification requirements.

12) Automated decision-making

We do not intend to make decisions about you that produce legal effects (or similarly significant effects) based solely on automated processing. If this changes, we will update this notice and, where required, provide information about the logic involved and your rights.

(We may use basic automated tools for security purposes—such as filtering obvious spam or abusive activity—but not for significant decisions about you.)

 

13) Changes to this Privacy Notice

We may update this notice from time to time. The “Last updated” date shows when it was most recently revised. If changes are material, we may provide additional notice via the website or other appropriate channels.

14) Contact

For privacy questions or requests, contact: support@smartflow.trading