Introduction

At Ottaviano Belcanto, we respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, process, and safeguard your information when you visit our website, engage with our investment communities, or use our financial education services.

We operate in compliance with Irish data protection laws, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. This policy applies to all personal data we process about you, regardless of how it was collected or stored.

Data Controller Information

Information We Collect

Personal Information

We collect various types of personal information when you interact with our services:

• Name, email address, phone number, and postal address
• Investment experience level and financial goals
• Educational background and professional information
• Communication preferences and marketing consents
• Website usage data, IP address, and device information
• Payment information for educational programs and services

How We Collect Information

We collect your personal data through various methods including direct interactions when you register for our programs, complete forms, subscribe to our newsletters, or contact us. We also collect data automatically through cookies and similar technologies when you use our website.

How We Use Your Information

We process your personal data for several legitimate purposes:

• Providing our investment education services and community access
• Processing applications for learning programs starting in autumn 2025
• Communicating about your account, programs, and relevant updates
• Personalizing your experience within our investment communities
• Improving our website functionality and user experience
• Complying with legal obligations and regulatory requirements
• Preventing fraud and ensuring platform security
• Conducting market research to enhance our educational offerings

We only use your data for marketing purposes where we have your explicit consent or where we have a legitimate interest to do so, and you have not objected to such use.

Legal Basis for Processing

Under GDPR, we must have a legal basis for processing your personal data. We rely on the following legal bases:

• Consent: Where you have given clear consent for specific processing activities
• Contract: Where processing is necessary for providing our educational services
• Legal Obligation: Where we must process data to comply with Irish and EU laws
• Legitimate Interests: Where processing is in our legitimate business interests and doesn't override your rights

Data Sharing and Disclosure

We may share your personal information with trusted third parties in specific circumstances:

Service Providers

We work with carefully selected service providers who help us deliver our educational programs and maintain our platform. These include hosting providers, payment processors, email marketing services, and educational technology partners. All service providers are bound by strict data protection agreements.

Legal Requirements

We may disclose your information if required by law, regulation, or legal process, or if necessary to protect our rights, property, or safety, or that of our users or the public.

Business Transfers

In the event of a merger, acquisition, or sale of business assets, personal data may be transferred as part of the transaction, subject to appropriate safeguards and notification requirements.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

Your Rights Under GDPR

As a data subject, you have several important rights regarding your personal data:

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within one month, though this may be extended in complex cases.

Data Security Measures

International Data Transfers

Your personal data is primarily processed within Ireland and the European Economic Area. When we transfer data outside the EEA, we ensure appropriate safeguards are in place:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses approved by the European Commission
• Certification schemes and codes of conduct
• Additional security measures to protect data in transit

We carefully vet all international service providers to ensure they meet European data protection standards.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and provide personalized content. We use:

• Essential Cookies: Required for basic website functionality
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements (with consent)

You can manage cookie preferences through your browser settings or our cookie consent tool. Disabling certain cookies may affect website functionality.

Changes to This Privacy Policy

We may update this privacy policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on our website with a new effective date
• Sending email notifications to registered users
• Displaying prominent notices on our platform
• For significant changes, seeking renewed consent where required

We encourage you to review this policy regularly to stay informed about how we protect your information.

Contact Information

If you have questions, concerns, or requests regarding this privacy policy or our data processing practices, please contact us:

You also have the right to lodge a complaint with the Data Protection Commission of Ireland if you believe we have not handled your personal data in accordance with data protection law.

Data Protection Commission:
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Phone: +353 57 868 4757
Email: [email protected]