Privacy Policy

1 Who We Are

This Privacy Policy explains how Siberis LTD ("Company", "we", "us", "our") collects, uses, stores, and protects your personal data when you use the marketdrifter website and platform at marketdrifter.com (the "Services").

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Siberis LTD is the data controller responsible for your personal data.

2 Data We Collect

We may collect and process the following categories of personal data:

Information you provide to us:

• Name and email address when you create an account;
• Billing information and payment details (processed securely by our payment provider — we do not store full card numbers);
• Username and password;
• Any content, preferences, or settings you create within the platform;
• Communications you send to us (e.g. support enquiries).

Information collected automatically:

• IP address (truncated or hashed where possible);
• Browser type, version, and language;
• Operating system and device type;
• Pages visited, time spent on pages, and navigation paths;
• Referring URL and search terms used to find the Services;
• Date and time of access;
• Unique device identifiers.

3 How We Collect Data

We collect personal data through the following means:

• Directly from you — when you register, subscribe, update your account, or contact us;
• Automatically — through cookies and similar technologies when you browse the Services (see Section 6);
• From third parties — such as payment processors who confirm transactions, or analytics services that provide aggregated usage data.

4 Why We Process Your Data

We use your personal data for the following purposes:

• Providing the Services — to create and manage your account, process subscriptions, and deliver the platform's features;
• Improving the Services — to analyse usage patterns, diagnose technical issues, and develop new features;
• Communication — to respond to your enquiries, send service-related notifications (e.g. billing confirmations, security alerts), and provide customer support;
• Security — to detect, prevent, and address fraud, abuse, and technical issues;
• Legal compliance — to comply with applicable laws, regulations, and legal processes.

5 Legal Bases for Processing

Under the UK GDPR, we rely on the following legal bases to process your personal data:

Purpose	Legal Basis
Account creation & service delivery	Performance of a contract (Art. 6(1)(b))
Payment processing	Performance of a contract (Art. 6(1)(b))
Service improvement & analytics	Legitimate interests (Art. 6(1)(f))
Security & fraud prevention	Legitimate interests (Art. 6(1)(f))
Service-related communications	Legitimate interests (Art. 6(1)(f))
Legal compliance	Legal obligation (Art. 6(1)(c))

Where we rely on legitimate interests, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms.

6 Cookies & Tracking Technologies

We use cookies and similar technologies to ensure the Services function correctly and to understand how you use them. The cookies we use fall into the following categories:

Strictly necessary cookies

These are required for the Services to operate. They include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. You cannot opt out of these cookies.

Functional cookies

These remember your preferences and settings (e.g. language, display options) to provide a more personalised experience.

Analytics cookies

We use analytics tools to understand how visitors interact with the Services. These cookies collect information such as pages visited, session duration, and navigation paths. IP addresses are truncated or hashed before storage.

Managing cookies. Most browsers allow you to refuse or delete cookies through their settings. Please note that disabling strictly necessary cookies may prevent the Services from functioning properly.

7 Third-Party Services

We use the following third-party services that may process your personal data on our behalf:

• Google Analytics — for website usage analysis. Google may transfer data outside the UK; see Google's Privacy Policy. You can opt out using the Google Analytics Opt-out Browser Add-on;
• Microsoft Clarity — for session replays, heatmaps, and interaction analysis to improve user experience. IP addresses are truncated or hashed before storage. See Microsoft's Privacy Statement;
• Payment processor — to securely handle subscription payments. We do not store your full card details; these are handled directly by our PCI-DSS compliant payment provider.

All third-party processors are bound by data processing agreements and are required to process your data only in accordance with our instructions and applicable data protection law.

8 Data Sharing & Disclosure

We do not sell, rent, or trade your personal data. We may share your data only in the following circumstances:

• Service providers — third-party processors who assist in delivering the Services (see Section 7), under appropriate data processing agreements;
• Legal requirements — when required by law, regulation, legal process, or governmental request;
• Protection of rights — to enforce our Terms and Conditions, protect the security of the Services, or protect the rights, property, or safety of Siberis LTD, our users, or the public;
• Business transfers — in connection with a merger, acquisition, or sale of assets, in which case your data would remain subject to this Privacy Policy.

9 International Data Transfers

The Services are hosted in the United Kingdom. Some of our third-party processors (e.g. Google, Microsoft) may transfer personal data to countries outside the UK.

Where such transfers occur, we ensure appropriate safeguards are in place, including:

• The recipient country has been granted an adequacy decision by the UK Secretary of State;
• Standard contractual clauses (UK International Data Transfer Agreement or Addendum) are in place;
• Other lawful transfer mechanisms as permitted under the UK GDPR.

10 Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Specifically:

• Account data — retained for the duration of your account, plus up to 30 days after deletion to allow for recovery;
• Billing records — retained for up to 7 years to comply with UK tax and accounting obligations;
• Analytics data — retained in aggregated or anonymised form; identifiable data is deleted or anonymised within 26 months;
• Support correspondence — retained for up to 2 years after resolution.

When personal data is no longer required, it is securely deleted or anonymised.

11 Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

• Right of access — to request a copy of the personal data we hold about you;
• Right to rectification — to request correction of inaccurate or incomplete data;
• Right to erasure — to request deletion of your data ("right to be forgotten"), subject to legal retention obligations;
• Right to restrict processing — to request that we limit how we use your data in certain circumstances;
• Right to data portability — to receive your data in a structured, commonly used, machine-readable format;
• Right to object — to object to processing based on legitimate interests, including profiling;
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at hello@marketdrifter.com. We will respond to your request within one calendar month, as required by the UK GDPR. There is no fee for exercising your rights, unless requests are manifestly unfounded or excessive.

12 Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest;
• Access controls limiting data access to authorised personnel only;
• Regular security assessments and monitoring;
• Secure password hashing.

While we take reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but will notify you and the relevant supervisory authority of any data breach in accordance with our legal obligations.

13 Automated Decision-Making & Profiling

marketdrifter uses artificial intelligence and machine learning to generate audience insights, market analysis, and campaign recommendations. We want to be transparent about how this works in relation to your rights under Article 22 of the UK GDPR.

Specifically:

• AI-generated insights and audience recommendations are outputs for you to act upon — you remain in full control of any decisions made;
• We do not use automated processing to evaluate, score, or make binding decisions about individual users that produce legal or similarly significant effects on them;
• We do not build individual behavioural profiles for the purpose of targeted advertising.

If our use of automated processing changes in a way that triggers Article 22, we will update this policy, implement appropriate safeguards, and provide you with the right to: (a) obtain human review of any automated decision; (b) express your point of view; and (c) contest the decision.

14 Children's Privacy

The Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected data from a person under 18, we will take steps to delete that information promptly.

If you believe a child under 18 has provided us with personal data, please contact us at hello@marketdrifter.com.

15 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Services. When we make material changes, we will:

• Update the "Last updated" date at the top of this page;
• Where practicable, notify you by email or through a prominent notice on the Services.

We encourage you to review this page periodically. Your continued use of the Services after any changes constitutes acceptance of the updated policy.

16 Contact Us & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection: