Privacy Policy

Name: Enigma Fund Management Kft. Address: 2045 Törökbálint, Balassi Bálint utca 23. Building O. Ground floor, Door 2. Contact: support@metisone.app

The Data Controller processes personal data for the following purposes: • User account management and authentication • Providing the Service (portfolio tracking, market data display) • Processing subscription payments • Sending service-related notifications • Technical operation and security of the platform Legal basis for processing: • Performance of contract (Article 6(1)(b) GDPR) - for service delivery • Legal obligation (Article 6(1)(c) GDPR) - for tax and accounting records • Legitimate interest (Article 6(1)(f) GDPR) - for security and fraud prevention • Consent (Article 6(1)(a) GDPR) - for web analytics, only if you allow analytics cookies

The Data Controller uses the following partners (Data Processors) to provide the Service. The Data Controller guarantees that its partners comply with GDPR requirements. 3.1. Hosting and Infrastructure Partner: Google Cloud EMEA Limited Registered office: 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Task: Running the Software, storing databases (Cloud Firestore), authentication (Firebase Auth). Data transfer: Data is stored on servers within the EEA (e.g., Frankfurt, Belgium). In case of data transfer to a third country (USA), Google ensures protection under the EU-US Data Privacy Framework, or through Standard Contractual Clauses (SCC). 3.2. Payment Service Provider Partner: Stripe Payments Europe, Limited Registered office: The One Building, 1 Lower Grand Canal Street, Dublin 2, Ireland (or One Wilton Park, Dublin 2). Task: Processing card payments, managing recurring payments. Data transfer: Stripe processes data within the European Union; international transfers are governed by the "Stripe Data Transfer Agreement" and SCCs. 3.3. Web Analytics (only with consent) Partner: Google Ireland Limited Registered office: Gordon House, Barrow Street, Dublin 4, Ireland. Task: Measuring how the website and app are used (Google Analytics 4), only after the User allows analytics cookies. Advertising features are turned off. Data transfer: Data may be transferred to Google LLC (USA) under the EU-US Data Privacy Framework.

The website uses cookies and similar technologies. Strictly necessary ones (for example, to keep you signed in) are used without consent, as the law allows. Analytics cookies are used only with your consent, which you can give, refuse or withdraw at any time under "Cookie settings" at the bottom of every page. The cookies we use, what they are for and how long they are kept are listed in the Cookie Policy: metisone.app/cookies

Users are entitled to the following rights: Right of access: You may request information about your processed data. Right to rectification: You may request correction of inaccurate data. Right to erasure ("Right to be forgotten"): You may request deletion of your data, provided there is no legal impediment (e.g., Accounting Act). Right to restriction of processing: You may request that we restrict the processing of your data, for example while the accuracy of the data is checked. Right to object: You may object to processing based on legitimate interest. Right to data portability: You may request your data in a structured, machine-readable format. Right to withdraw consent: Where processing is based on consent (for example, analytics cookies), you may withdraw it at any time, without affecting the lawfulness of processing before the withdrawal. To exercise your rights, please send your request to: support@metisone.app We will respond to all legitimate requests within 30 days.

In case of complaints, the User may turn to the National Authority for Data Protection and Freedom of Information (NAIH): Address: 1055 Budapest, Falk Miksa utca 9-11. Mailing address: 1363 Budapest, P.O. Box 9. Website: www.naih.hu Users also have the right to seek judicial remedy before the competent court.