Privacy Policy

Last updated: Sep 10, 2026

This policy explains how Berto Production processes your personal data on cadencesignals.com, under Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1. Data controller

Berto Production — Andrea Bertolotti
NIF Y-4514/312-R
Alicante, Spain
info@cadencesignals.com

We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR. Privacy questions go to the address above.

2. What we collect, why, and on what legal basis

Data	Purpose	Legal basis	Retention
Email address, password (hashed), name (optional), interface language	Creating and running your account; giving you access to the members' area	Performance of a contract — Art. 6(1)(b)	For as long as the account exists, then 30 days
Email address, language	Sending the newsletter and new-signal alerts	Consent — Art. 6(1)(a)	Until you withdraw consent, then deleted
Self-declared trading experience	Adapting the level of the content and the warnings we show you	Consent — Art. 6(1)(a)	For as long as the account exists
Record of consents: what you accepted, when, from which IP and user agent	Proving that consent was given, as GDPR requires	Legal obligation — Art. 6(1)(c) and Art. 7(1)	3 years after the account is closed
Registration IP, login timestamps, rate-limiting counters	Security, abuse prevention, protecting the site from automated attacks	Legitimate interest — Art. 6(1)(f)	12 months
Email delivery log (recipient, subject, status, date)	Diagnosing delivery problems and proving an email was sent	Legitimate interest — Art. 6(1)(f)	12 months
Server logs and technical cookies	Serving the site, keeping you logged in, remembering your language	Legitimate interest / strictly necessary — Art. 6(1)(f)	Up to 12 months
Anonymised analytics (if you consent)	Understanding which pages are used, in aggregate	Consent — Art. 6(1)(a)	14 months
Invoicing data (only if paid plans are introduced)	Billing and statutory accounting	Legal obligation — Art. 6(1)(c)	10 years (Spanish tax law)

We do not ask for and do not want: identity documents, your broker credentials, your account balance, your positions, payment card numbers, or any special category of data under Article 9 GDPR. Please never send them to us.

3. Providing your data

Giving us an email address and a password is necessary to have an account: without them we cannot create one. Everything else — your name, your experience level, the newsletter, the signal alerts, analytics cookies — is optional, and refusing has no consequence beyond not receiving that specific thing.

4. Who else sees your data

We do not sell your data, we do not rent it, and we do not share it with advertisers or data brokers. It is disclosed only to processors acting on our instructions under Article 28 GDPR:

Hosting provider — stores the site and the database, inside the European Union.
Email provider — sends the transactional emails, the alerts and the newsletter.
Analytics provider — only if you accept analytics cookies. See the Cookie Policy.

We may also disclose data where the law requires it, or to establish or defend a legal claim.

5. Transfers outside the EEA

Our hosting and email processing take place inside the European Union. If you accept analytics cookies, that provider may transfer data to the United States; such transfers rely on the EU-US Data Privacy Framework and on the European Commission's Standard Contractual Clauses. If you decline analytics cookies, no transfer of your data outside the EEA takes place.

6. Automated decisions

The trade ideas on this site are generated with the assistance of an AI system, but that system processes market data, never your personal data. We do not profile you and we take no automated decision that produces legal effects for you within the meaning of Article 22 GDPR.

7. Your rights

Under Articles 15 to 22 GDPR you may at any time:

Access your data, and get a copy of it;
Rectify anything inaccurate — you can edit your profile yourself;
Erase your data ("right to be forgotten") — the account page has a one-click delete button;
Port your data — the same page gives you an immediate JSON export;
Restrict or object to processing based on our legitimate interest;
Withdraw consent at any time, without affecting processing already carried out — every email we send carries a one-click unsubscribe link.

Write to info@cadencesignals.com to exercise any of these. We reply within one month (extendable by two further months for complex requests, in which case we will tell you). The service is free; we may charge a reasonable fee only for manifestly unfounded or repetitive requests.

8. Complaints

If you believe we are handling your data unlawfully, please tell us first — we would rather fix it. You also have the right to complain to a supervisory authority, in particular:

Spain — Agencia Española de Protección de Datos (AEPD)
Italy — Garante per la protezione dei dati personali
or the authority of your country of residence.

9. Security

The site is served over HTTPS only. Passwords are stored hashed with a per-installation secret and are never readable by us or recoverable in plain text. Access to the database is restricted, session cookies are HttpOnly and SameSite, and login and registration are rate-limited. No system is perfectly secure; if a breach ever affects your rights we will notify the AEPD within 72 hours and inform you where the law requires it.

10. Children

The Service is not intended for anyone under 18 and we do not knowingly collect data from minors. If you believe a minor has registered, write to us and we will delete the account.

11. Changes

If we change this policy we will update the date at the top and, for material changes, notify registered users by email before the change takes effect.

Contact

Berto Production — Andrea Bertolotti
NIF Y-4514/312-R
Alicante, Spain
info@cadencesignals.com