Privacy Policy

This policy explains what InCyTrade collects from visitors to incytrade.com, why, and the rights you have over it. It covers this marketing website only - not the InCyTrade product itself, which is deployed directly into a customer's own environment under a separate, individually negotiated data processing agreement.

Who we are

InCyTrade is an early-stage venture based in Tel-Aviv, Israel, operated by its co-founders, Raphael Cohen and Yaron Golfand, who are jointly the controllers of the limited personal data described below. Registered company details will be published on this page once incorporation is complete. For any privacy question, or to exercise any right described below, contact support@incytrade.com.

What we collect

This site is static - it has no accounts, no forms, and no analytics or advertising scripts. In practice, two things reach us:

• Ordinary hosting logs. This site is hosted on GitHub Pages, a service of GitHub, Inc. (a Microsoft company, United States). Serving any website generates standard access logs - IP address, requested page, timestamp, browser user-agent. Those logs are generated and held by GitHub under its own privacy statement. We do not operate that infrastructure and do not receive, store, or analyse those logs ourselves.
• Whatever you choose to email us. The "Talk to us" links on this site are mailto: links - they open your own email client. We only receive what you decide to write and send. We don't collect your address any other way, and there's no contact form harvesting input on our servers.

We don't use tracking pixels, session replay, fingerprinting, or any third-party analytics or advertising service. The site sets exactly one cookie - recording that you've seen the cookie notice, nothing else - see the Cookie Policy for the full detail.

How we use it

Hosting logs are used only to operate and secure the site (diagnosing errors, spotting abuse). Anything you email us is used only to respond to you. We don't sell, rent, or share this information with third parties for their own marketing purposes, and we don't use it to build advertising profiles.

Legal basis for processing

Where GDPR applies, our legal basis for the limited processing above is legitimate interest (Art. 6(1)(f)) - operating and securing the site, and responding to messages you send us - which we consider proportionate given how little is collected and that none of it is used for profiling or marketing.

International transfers

InCyTrade's co-founders are based in Israel. Visitors reach this site from anywhere. Because the site is served by GitHub Pages, hosting logs are processed in the United States and potentially at other GitHub edge locations. GitHub offers Standard Contractual Clauses as the transfer mechanism in its data protection agreement, and the European Commission's adequacy decision covers transfers to Israel. Nothing beyond those hosting logs leaves your browser: no analytics, no third-party requests, no form submissions.

Retention

Hosting-log retention is set by GitHub and described in its privacy statement. We neither control nor extend it. Emails you send us are kept as long as reasonably needed to address your enquiry, or until you ask us to delete them.

Your rights

If you're in the EU/EEA or UK (GDPR / UK GDPR)

You have the right to access, correct, delete, or restrict our processing of your personal data, to receive a portable copy of it, to object to processing based on legitimate interest, and to lodge a complaint with your national supervisory authority.

If you're in Israel (Privacy Protection Law, as amended)

You have the right to access information held about you and to request correction of inaccurate information, and to file a complaint with the Israeli Privacy Protection Authority (PPA) if you believe your rights have been violated.

If you're in the United States

Depending on your state (e.g. California's CCPA/CPRA and comparable laws in other states), you may have the right to know what personal information we hold about you, to request deletion, and to opt out of the "sale" or "sharing" of personal information - a right that has no practical effect here, since we don't sell or share personal information with third parties in the first place.

To exercise any of the rights above, email support@incytrade.com. We'll respond within a reasonable time and in any case within the window the applicable law requires.

Children's privacy

This site is directed at security, compliance, legal, and investment professionals. It isn't directed at children, and we don't knowingly collect information from anyone under 16.

Security

We keep the amount of data this site touches deliberately small specifically to limit what there is to secure. Any hosting provider we use will be expected to maintain reasonable technical and organizational safeguards over the logs it generates.

Changes to this policy

If this policy changes, we'll update the date at the top of this page. Material changes will be flagged here for at least 30 days before taking effect.