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Legal

Privacy Policy

Effective Date: 17 June 2026 · Last Updated: 17 June 2026

1. General

Aladinum LLC, a Wyoming limited liability company doing business as "Aladinum" (we, us, our), is committed to protecting the privacy of personal information collected through our website and in the course of our business. This Privacy Policy describes the information we collect, how we use and share it, and the choices available to you. It applies to www.aladinum.com and to the advisory, sales representation, and build-and-run services we provide to business clients. Aladinum provides services to institutional and business clients only. We do not operate a consumer service, and we do not provide a service that you log into, consume as a data feed, or access through an API. This policy does not apply to third-party websites linked from our site. Please review their own policies before using them.

2. International Transfers

Aladinum is established in the United States. Personal data we handle is processed in the United States and in the European Economic Area, and in the other locations where our service providers operate. Personal data is also disclosed to the market data vendor we represent, which has entities in the United States and in Ireland. If you are located in the European Economic Area, the United Kingdom, or Switzerland, personal data relating to you may be transferred to and processed in the United States and in those other locations, and we comply with the GDPR, the UK GDPR, and the Swiss Federal Act on Data Protection respectively in connection with that processing. For transfers of personal data originating from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we put in place appropriate safeguards, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, and the Swiss-amended Standard Contractual Clauses, as applicable. We do not rely on the EU-US Data Privacy Framework.

3. Information We Collect

3.1 Personal Information

We collect information you submit through our website or in correspondence with us. This includes your name, business or personal email address, employer where given, job title, country, and the content of any message you send. When you submit a form, we also automatically record your IP address and the approximate geographic location, such as city, region, and country, time zone, and network or Internet service provider derived from it, to help us understand and respond to your enquiry and to detect abuse. This derived location is approximate and may be inaccurate.

3.2 Usage Information

When you visit our website, we automatically collect technical information about your session, including IP address, browser and operating system information, language, referring URL, pages and resources accessed, request and response timestamps, and error events. We use this information to operate, secure, and improve the website. We use Cloudflare Web Analytics to understand aggregate website usage. This analytics is cookieless and does not collect personal data or set identifiers. We also use the Leadfeeder service, provided by Dealfront, to identify the organisation associated with a visit, for business development. This company identification is cookieless and runs for all visitors on the basis of our legitimate interests. Leadfeeder can also set a first-party cookie to recognise returning visits. We set that cookie only with your consent if you are in the European Economic Area, the United Kingdom, or Switzerland, or if your region cannot be determined. In the United States and other regions where consent is not required for this purpose, the cookie may be set unless you opt out. You can manage your choice at any time through the "Cookie settings" link in the website footer.

3.3 Information from Other Sources

We may receive personal data from a business client during an engagement. A client may provide personal data, for example about its staff or its own contacts, so that we can process it on the client's behalf for that engagement. We process such data only on the client's documented instructions. We do not receive personal data about you from other third-party sources for our own purposes.

4. How Information Is Used

Information is used only for the following purposes:

  • Responding to your enquiries and taking steps at your request before entering into a contract.
  • Providing demonstrations, advisory and consulting services, and build-and-run engagements for business clients.
  • Processing personal data that a business client provides, only on the client's documented instructions, when we act as a processor during an engagement.
  • Sharing prospect and client contact details and deal information with the market data vendor we represent, for contract execution and service provision by that vendor.
  • Sending marketing communications about Aladinum services to business contacts who have opted in.
  • Operating cookieless aggregate website analytics, as described in section 3.2.
  • Operating cookieless company identification for business development, and the returning-visitor cookie where permitted, as described in section 3.2.
  • Making disclosures required by law, including to public authorities or courts in response to a lawful and binding request.

We do not sell personal data.

We share personal data only with the recipients needed for the purposes above. These are: service providers that host, operate, or support our website and email under written contracts containing data-protection obligations; the market data vendor we represent, for the purpose described above; professional advisers under duties of confidentiality; and public authorities or courts where disclosure is required by a lawful and binding request.

Lawful bases: we rely on the performance of, or steps taken at your request prior to, a contract for responding to enquiries and providing services to a client; on our legitimate interests for website security and for cookieless company identification; on your consent for marketing emails and for the returning-visitor cookie where consent is required; and on compliance with a legal obligation for disclosures required by law. Where we process personal data as a processor for a business client, the client is responsible for establishing the lawful basis.

4.1 Choice

We respect your choices about how your information is used. We provide an unsubscribe option in every marketing communication. You can manage cookie consent through the "Cookie settings" link in the website footer. If your information is held by us because a business client provided it for us to process, please contact that client to opt out or to manage your preferences, and we will support the client in responding to your request.

5. Safeguards

We protect personal data using technical and organizational measures. These include encryption of data in transit and at rest, role-based access control with least-privilege defaults, audit logging of administrative actions, periodic vulnerability scanning, and documented due diligence on service providers before they are engaged. We are working towards alignment with the ISO/IEC 27001 information-security framework. We do not currently hold a certification.

6. Accessing, Updating, and Removing Personal Information

Subject to applicable law, you have the following rights in relation to personal data we hold about you:

  • Access: view the personal information we hold about you.
  • Rectification: correct inaccurate or incomplete information.
  • Erasure: request deletion in the circumstances permitted by law.
  • Restriction: limit how we process your data in defined situations.
  • Objection: object to processing based on our legitimate interests, including direct marketing.
  • Portability: receive certain data in a structured, commonly used, machine-readable format.
  • Withdrawal of consent: withdraw any consent you have given, without affecting the lawfulness of processing carried out before withdrawal.
  • Complaint: lodge a complaint with the data-protection supervisory authority in your country of residence, place of work, or place of the alleged infringement.

Where Aladinum acts as a processor for a business client, requests should be directed to that client, and we will support the client in responding. Otherwise, contact us at dataprivacy@aladinum.com with enough information to identify you and the right you wish to exercise. We may need to verify your identity before acting on the request. We respond within one month of receipt, as required by Article 12(3) of the GDPR, and may extend that period by up to two further months where the request is complex or where we have received a number of requests from you.

7. Retention

We keep personal data for as long as is needed for the purpose for which it was collected, plus any period required by law or by a contractual obligation. The following periods apply:

  • Operational and security logs (technical): 13 months from the date of the log entry.
  • Billing, tax and statutory accounting records: 10 years from the end of the financial year to which they relate.
  • Marketing contacts: 24 months from your last interaction with us, or until you opt out, whichever is earlier.
  • Support correspondence and ticket data: 24 months from case closure.
  • Cookie consent and preference records: 24 months from the date consent was given or last refreshed.
  • Personal data processed for a business client as a processor: for the duration of the engagement, after which it is deleted or returned in accordance with the client's instructions and our agreement with the client.

When we no longer need personal data, we delete it or anonymise it.

8. Other Agreements

Where Aladinum acts as a processor for a business client, we and the client may have entered into a separate data-processing agreement governing the handling of personal data. That agreement applies in addition to this Privacy Policy and prevails to the extent of any conflict in relation to the personal data processed under it.

9. Questions

For any question about this Privacy Policy, please contact us at dataprivacy@aladinum.com.

10. Right to Change This Privacy Statement

We may update this Privacy Policy from time to time. Where a change is material, we will provide reasonable notice before it takes effect, for example by a banner on the website or, where we have your contact details, by email. Non-material changes take effect when we update the "Last Updated" date at the top of this page.