Privacy Policy
1. Who we are
1.1 SOUSEKI LIMITED (“we”, “us”), Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus, registered in Cyprus under number HE442002, makes Pippodrome. We are the controller of the personal data this policy describes.
1.2 Write to us about your personal data at [email protected]. We have not appointed a data protection officer, because the law does not require us to.
2. What this policy covers
2.1 This policy covers our website pippodrome.com, requests for a free trial, The Clubhouse at clubhouse.pippodrome.com, our billing, our email to customers, and support.
2.2 It does not cover the personal data inside the trading platforms we host for brokers. For that data the broker is the controller and we are its processor. If you are a client of a broker that uses Pippodrome, the broker’s privacy notice applies to you; please contact the broker.
3. What we collect, why, and for how long
Visiting pippodrome.com
The website sets no cookies and runs no analytics. Our hosting provider processes your IP address and the details of your requests to deliver the pages and protect them from attack. We do this in our legitimate interest in running a secure website (GDPR Article 6(1)(f)).
Requesting a free trial
The trial request form is a Google Form. Google stores the answers you give — such as your name, company, email address and what you tell us about your business — for us. We use them to answer you and to set up a trial, as steps you ask us to take before a contract (Article 6(1)(b)). We keep them for as long as we need them to follow up on your request, and, if you become our customer, as long as the data of your Clubhouse account below.
Your Clubhouse account
We keep your email address, your company’s name, your password (as a hash only), the Platforms you subscribe to with their subscription status and monthly account counts, the version of our Terms you accepted, and the sign-in links and sessions we issue. The Clubhouse sets one cookie, which keeps you signed in; it is strictly necessary, so it needs no consent. We record the IP addresses that use The Clubhouse to limit abuse and keep it secure. We process this data to perform our contract with you (Article 6(1)(b)), and the security data in our legitimate interest in keeping the service secure (Article 6(1)(f)). We keep account data while your account exists, and security records only as long as we need them to keep the service secure.
Billing
When you pay at our checkout, Stripe processes the payment. For that purchase, the Stripe company named on your receipt (“Sold through Link”) is the seller of record, and it processes your payment details under its own privacy policy. We receive your company’s name, email, billing address, tax number and the status of your payments, but never your full card number. When we invoice you directly, we process the same details ourselves. We do this to perform our contract (Article 6(1)(b)) and to meet our tax and accounting obligations (Article 6(1)(c)). We keep billing records for as long as Cyprus tax and company law requires.
Email and support
We send sign-in links, billing notices and notices about the Service by email, through our email service provider. When you write to us, we keep the correspondence for as long as you are our customer and afterwards as long as we may need it to establish or defend legal claims, to perform our contract and in our legitimate interest in those claims (Article 6(1)(b) and (f)).
Monitoring
Our monitoring collects technical measurements of our servers and services. It does not collect the personal data inside the Platforms.
4. Who receives your data
4.1 We share your data only with the service providers that process it for us — for hosting, network services and email (such as Hetzner, DigitalOcean and Cloudflare), for payments (Stripe) and for the trial form (Google) — and with authorities and professional advisers where the law requires or allows it. We do not sell your data.
4.2 Some of these providers may process data outside the European Economic Area, including in the United States. They do so only under a safeguard the GDPR recognises, such as the EU-U.S. Data Privacy Framework or the European Commission’s standard contractual clauses.
5. Your rights
5.1 You may ask us for access to your personal data, to correct it, to erase it, to restrict its processing, to receive it in a portable form, and you may object to processing based on our legitimate interests. Write to [email protected]. We answer within one month.
5.2 You may also complain to a supervisory authority: in Cyprus, the Office of the Commissioner for Personal Data Protection (dataprotection.gov.cy), or the authority where you live or work.
5.3 We make no decisions about you by automated means alone, and we do not profile you.
6. Changes
6.1 We publish every change on this page with its date. We tell our customers of significant changes by email before they take effect.