Privacy Policy

This policy says what personal data OmniOS OÜ holds about you, why we are allowed to hold it, who else sees it, how long we keep it, and how to make us stop. It describes what the system actually does, not what a template says it might.

In force from
Version
2.9
Issued by
OmniOS OÜ

Clarifies service records, aggregate request counts and optional analytics, with one saved choice and no automatic prompts.

1Who is responsible for your data

OmniOS OÜ (registry code 17591703) is the controller of the personal data described here, within the meaning of Regulation (EU) 2016/679 (GDPR).

Controller
OmniOS OÜ
Registry code
17591703
Address
Padriku tee 3/3, 11912 Tallinn, Estonia
Privacy contact
[email protected]
Data protection officer
We are not required to appoint one: we do not carry out large-scale monitoring of individuals or process special-category data as a core activity. Privacy questions go to the address above and are handled by the management board.
EU representative
Not required — we are established in the EU.

This policy covers vultax.com, the app at app.vultax.com, the API, and alerts we send you. It does not cover exchanges, wallets or other sites you reach from ours; they have their own policies.

2The short version

  • We do not sell, rent or trade personal data, and we never have.
  • Optional analytics needs your choice on both sites. There is no automatic popup. Use Analytics choices in the website footer or Settings → Privacy & data in the app. Essential service records and aggregate request counts continue independently. See the cookie policy.
  • We do not train models on your data. Your Vi AI conversations are not used to train anyone's model, ours or our provider's.
  • Your data is hosted in the European Union, in Frankfurt, Germany.
  • We collect what the Service needs to work, keep it for a stated period, and delete it after.

3What we collect, why, and on what legal basis

Each row states a purpose, the data used for it, the Article 6 GDPR basis, and how long we keep it. Where the basis is legitimate interests, the interest is named so you can weigh it.

PurposeDataLegal basisRetention
Run your account and give you the Service you paid forEmail address, display name, password hash, plan and entitlements, settings, watchlists, alert rulesArt. 6(1)(b) — performance of the contractLife of the account, then 30 days
Sign you in with Google, if you choose toGoogle account identifier, email address, display name, avatar URLArt. 6(1)(b) — you asked to sign in this wayLife of the account, then 30 days
Take payment and manage the subscriptionBilling email, country, plan, subscription status, Stripe customer and payment identifiers, invoice history. We never receive your full card number.Art. 6(1)(b) contract; Art. 6(1)(c) legal obligation for the accounting recordAccounting records 7 years (Estonian Accounting Act § 12); other billing data, life of the account
Answer support requests and complaintsYour messages, attachments, and the account they concernArt. 6(1)(b) contract; Art. 6(1)(f) legitimate interest in keeping a record of what was agreed3 years from last contact
Hold an alert configuration you have set upTelegram chat identifier and alert rules, where you linked them, and a delivery log entry for each alert sent: the channel, the destination chat identifier, the delivery status and any error, the alert's title and category, and the time it was sent.Art. 6(1)(b) — performance of the contractAlert rules and the Telegram link: until you remove them; deleted with the account
Answer your questions in Vi AIYour prompts, the assistant's replies, timestamps, token counts, the model usedArt. 6(1)(b) — performance of the contractConversation history until you delete it, or 12 months after the account closes
Let you practise on the paper deskYour simulated positions, virtual balance and order history. Nothing here is money and no order reaches a market, but the ledger belongs to your account and is held by us, not by your browser.Art. 6(1)(b) — performance of the contractLife of the account, then 30 days
Keep the Service up, secure and free of abuseIP address, user agent, request URL and status, timestamps, rate-limit counters, authentication eventsArt. 6(1)(f) — legitimate interest in defending the Service against attack, credential stuffing and scrapingAccess logs are rotated daily and normally kept for 14 days; records needed for a legal claim follow the legal-claims retention below
Understand how the app is used, so we know what to fixWith permission, Google Analytics measures pages, navigation, signups and checkout starts. Our own analytics measure public-page use, active time, scrolling and interaction counts, using a pseudonymous browser identifier and broad device, country and source categories. Typed content, account identifiers, email addresses, wallet addresses, payment details and session recordings are excluded. Advertising features are disabled.Art. 6(1)(a) — consent, withdrawable in Settings → Privacy & data. Accepting the Terms is not analytics consentOur detailed analytics: 90 days. Google event data: up to 14 months. Browser identifiers: up to 180 days
Understand how the public website is usedOur first-party page-use and interaction measurement on vultax.com, only after your explicit choice. Google Analytics is currently enabled in the app rather than on the public website. No optional analytics event is sent before permission. The saved choice applies on both sites.Art. 6(1)(a) — consent, withdrawable at any time through Analytics choices in the site footerOur detailed analytics: 90 days; browser identifier: up to 180 days
Count service requests without visitor profilesAggregate daily requests, public routes, broad sources and device categories, status codes and delivery performance derived from existing server requests. No visitor identifier, IP address or account is retained in these counts; no browser beacon is required.Art. 6(1)(f) — legitimate interest in operating and improving the service with limited aggregate measurementAggregate counts: up to two years. They include automated requests and do not establish a number of people
Run the referral programmeThe referral code of the member who sent you, the time your account was created, and — for the referring member — the payments received on accounts they referred and the balance owed to them. Not the referred account's email address, and not what they looked at.Art. 6(1)(b) — performance of the contract with the referring member and with you, and Art. 6(1)(c) for the payment recordAccounting records 7 years; the attribution cookie 30 days
Tell which of our advertisements bring people hereOne event, sent from our server when you subscribe to the research newsletter: a one-way hash of the address you just gave us — never the address itself — with the IP address and browser user-agent of that request and the page it came from. No ad-click reference or browser advertising identifier is included in that event.Art. 6(1)(f) — legitimate interest in knowing whether our advertising works, weighed against a single event tied to an action you took deliberately. Object at [email protected] and we will exclude youWe keep no record of the event. OpenAI publishes no retention period for what it receives, so we do not state one for it.
Send service email you cannot opt out ofEmail address (billing receipts, security notices, changes to these documents)Art. 6(1)(b) contract; Art. 6(1)(c) legal obligation for change noticesLife of the account
Send product news, if you ask for itEmail address, and whether you opened itArt. 6(1)(a) — consent, withdrawable in one click in every messageUntil you withdraw consent, then a suppression record so we do not email you again
Establish, exercise or defend legal claimsWhatever is relevant to the claimArt. 6(1)(f) — legitimate interest in defending ourselves; Art. 9(2)(f) where applicableUntil the claim and any appeal period ends

You do not have to give us any of this. But without an email address and a payment method we cannot give you an account or a paid plan, and without the security logging we cannot safely run the Service at all.

4Blockchain and market data

This section matters, and most policies in our sector skip it.

The Service analyses public blockchain transactions and public exchange order flow. That data is about wallet addresses and trades, not about our customers. But a wallet address can sometimes be linked to a living person, and where it can, it is personal data under the GDPR. We treat it as personal data whenever that link is reasonably possible.

What we process
Publicly recorded blockchain addresses, transaction values, timestamps, counterparties, and derived flow and clustering metrics. Public exchange trade and order-book data. On prediction-market surfaces: public trades, positions and realised profit per participant, together with the public profile name the participant chose on the venue and an abbreviated form of their address.
Where it comes from
Public blockchains (including Polygon), public exchange APIs, and prediction-market operators' public data APIs (currently Polymarket). We do not buy identity data, and we do not attempt to attach a name, email or real-world identity to an address or a venue profile name.
Legal basis
Art. 6(1)(f) — our legitimate interest, and our customers' and the public's legitimate interest, in transparency about market integrity. We have carried out and documented the balancing test required by Art. 6(1)(f).
Why we think it is balanced
The data is already public and published by design; we analyse conduct on a market rather than a private life; we use only the name a participant chose to publish and abbreviate addresses; we do not deanonymise, profile individuals, or make automated decisions with legal effects; we offer no way to copy a participant's trades; and we publish our method so any figure can be challenged. Ranking participants by profit is the most intrusive thing we do with this data, and our documented balancing test treats it as such.
Your rights over it
If you can show an address is yours, you may object under Art. 21 and ask for restriction or erasure of our derived records. We cannot erase anything from a public blockchain, because nobody can. Write to [email protected].

A detection signal is not an accusation. Scores describe how closely observed behaviour resembles patterns associated with wash trading or spoofing. They are not a finding that anyone broke the law. If you are named and believe we are wrong, § 13 of the Terms sets out the right of reply.

5Who we share it with

We use a small number of processors to run the Service. Each is bound by a written contract under Art. 28 GDPR to act only on our instructions. One entry below is not one of them: OpenAI's published Ad Tools terms state that each side acts as an independent controller of ad-measurement data, which is why OpenAI appears twice with different footing. That measurement is now a single server-to-server event; nothing of OpenAI's runs in your browser. The current list, with what each one gets and where it sits, is on the sub-processors page — the authoritative version, kept current.

WhoWhat they doWhere
OVH SASHosting, compute, storage and recoveryEuropean Economic Area
CloudflareWebsite delivery and network securityGlobal edge; US parent
Stripe Payments Europe, Ltd.Card payments, subscriptions, invoicesIreland — EU
Google Ireland LimitedSign in with Google if chosenIreland, with processing within the Google group under the applicable Google service terms and data processing terms
OpenAIThe language model behind Vi AI and news summariesUnited States
OpenAI, ChatGPT AdsMeasures whether an advertisement worked, from one server-side event per newsletter subscription. OpenAI's published Ad Tools terms state that each side acts as an independent controller of this data, so it is not our processor here.Outside the EEA
TelegramAlert delivery, if you connect itOutside the EEA

Beyond processors, we disclose personal data only where the law requires it — a valid order from a court or competent authority — or to establish or defend a legal claim. We check that any such demand is lawful and properly served before responding, and we tell you unless we are legally barred from doing so.

If the business is ever sold or merged, data may transfer with it. We will tell you before that happens and before any different policy applies to you.

6Transfers outside the EEA

Core service data is hosted in the European Economic Area. Some providers process limited data outside the EEA, as described in the processor inventory and below:

  • Cloudflare — as our CDN and security layer it processes request metadata, including your IP address, at edge locations worldwide. Covered by Cloudflare's data processing addendum incorporating the European Commission's Standard Contractual Clauses.
  • OpenAI — Vi AI prompts and news text are sent to its API for processing. Covered by its data processing addendum incorporating the Standard Contractual Clauses. Under its API terms, content sent through the API is not used to train its models. Advertising measurement is a separate arrangement: OpenAI publishes a distinct set of Ad Tools terms for it rather than that addendum, § 3c of the sub-processors page sets out what it receives and on what footing, and it is now one server-side event with nothing running in your browser.
  • Telegram — only if you connect it, and only the chat identifier and the alert text you asked for. This transfer happens because you asked us to send you messages on a platform of your choosing (Art. 49(1)(b) GDPR).

We minimise what leaves the EEA: no billing data, no password material and no full account record goes to any of them. A copy of the relevant clauses is available on request at [email protected].

7Cookies and what is stored on your device

Essential cookies support sign-in and security. Optional analytics identifiers are written only after permission on either site. One saved browser choice applies to the website and app. A referral link can also set a functional referral cookie. There is no OpenAI browser pixel. See the cookie policy for purposes and lifetimes.

Every cookie and browser-storage entry, with its exact lifetime and how to remove it, is listed in the cookie policy. Analytics can be turned off in Settings → Privacy & data in the app and through Analytics choices in the vultax.com footer.

8Automated decisions and profiling

We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you, within the meaning of Art. 22 GDPR.

Two automated processes touch you, and neither reaches that threshold: rate limiting and abuse detection may temporarily throttle a request pattern, and Stripe applies its own fraud screening to card payments. In both cases you can reach a human at [email protected] and have the outcome reviewed.

Vi IQ scores, detection signals and wallet analytics score markets and addresses, not our customers. They are not used to make decisions about you.

9How we protect it

  • TLS 1.2 or better for everything in transit, with HSTS and a preload entry.
  • Passwords stored only as salted hashes with a modern key-derivation function. We cannot read your password.
  • Session cookies are signed, HTTP-only and same-site; OAuth uses PKCE with a single-use state nonce.
  • A restrictive content security policy, and no third-party script we have not chosen deliberately.
  • Encrypted, tested backups, with restore drills rather than assumed recoverability.
  • Access to production data limited to those who need it, over authenticated channels, with an append-only audit log.
  • Dependency and vulnerability scanning, with security fixes prioritised over feature work.

No system is perfectly secure. If a breach is likely to risk your rights and freedoms, we will notify the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate) within 72 hours of becoming aware of it, and tell you without undue delay where the risk to you is high, as Arts. 33 and 34 GDPR require. Our vulnerability reporting process is in the security policy.

10Your rights, and how to use them

Under the GDPR you can ask us to do each of the following. Exercising them is free, and we do not treat you differently for it.

Access (Art. 15)
Get a copy of the personal data we hold about you, and be told what we do with it.
Rectification (Art. 16)
Have inaccurate data corrected and incomplete data completed.
Erasure (Art. 17)
Have data deleted where we no longer need it, subject to records we must keep by law — principally the 7-year accounting record.
Restriction (Art. 18)
Have us hold data without using it while a dispute about it is resolved.
Portability (Art. 20)
Receive the data you gave us in a structured, machine-readable format, or have it sent to another provider.
Objection (Art. 21)
Object to processing based on legitimate interests, including our analysis of a blockchain address you can show is yours. Objection to direct marketing is absolute — we stop, no balancing.
Withdraw consent (Art. 7(3))
Withdraw consent at any time, without affecting what we did lawfully before you withdrew it.
Complain (Art. 77)
Complain to a supervisory authority — see § 11.

Write to [email protected] from the address on your account. We respond within one month. If a request is unusually complex we may extend by two further months, and we will tell you why within the first month. We may ask you to confirm your identity, but only where we have real doubt, and we will not use the request as a reason to collect more data about you.

11Complaining to a regulator

Please raise it with us first — we would rather fix it. But you have the right to go straight to a supervisory authority. Ours is:

Authority
Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Address
Tatari 39, 10134 Tallinn, Estonia
Phone
+372 627 4135

If you live or work in another EEA country, you may also complain to your own national authority.

12Children

The Service is for adults. We do not knowingly collect data from anyone under 18, and we do not direct any part of the Service at children. If you believe a child has given us data, write to [email protected] and we will delete it.

13Changes to this policy

When we change how we use personal data we update this page, change the version and date at the top, and record it in the changelog. We notify affected users of material changes as required. Where a change requires your consent, we ask for it rather than assuming it from your continued use.