Privacy Policy

Last updated: April 3, 2025 · Effective: April 3, 2025 · legal@neverhodl.com

1. Who We Are

NeverHodl ("NeverHodl™", "we", "us", "our") is a market cycle intelligence platform operating under trademark registration OEPM España M4370276 (Classes 36 and 42). Website: neverhodl.com. Contact: legal@neverhodl.com

2. Data We Collect

2.1 Information you provide

• Email address — when you subscribe to the weekly NHCI signal newsletter via the form on neverhodl.com. This is the only personal data we actively collect.

2.2 Information collected automatically

• Usage analytics — if you consent, we collect anonymised page view data, session duration, and referral source via Google Analytics 4 (GA4). No personal identifiers are stored.
• Technical data — server logs may temporarily record IP addresses and browser type for security and error monitoring. These are not linked to personal profiles and are deleted after 30 days.
• Cookies — we use strictly necessary cookies for site functionality and, with your consent, analytics cookies. See Section 5.

2.3 What we do NOT collect

• Financial data, payment information, or credit card numbers
• Government IDs or identity documents
• Location data beyond country-level (from IP)
• Phone numbers or physical addresses
• Social media profiles or third-party account data

3. How We Use Your Data

• Email address: exclusively to send the weekly NHCI signal newsletter and important service updates. We do not send unsolicited commercial communications.
• Analytics data: to understand how users navigate the site and improve the product. Never linked to individual identities.
• Technical logs: for security monitoring, debugging, and preventing abuse.

4. Legal Basis (GDPR Art. 6)

• Consent (Art. 6.1.a) — for email newsletter subscription and analytics cookies. You may withdraw consent at any time.
• Legitimate interest (Art. 6.1.f) — for security logging and fraud prevention.

5. Cookies

We use three categories of cookies:

• Strictly necessary: Required for site functionality (language preference, theme setting, cookie consent state). Cannot be disabled.
• Analytics (optional): Google Analytics 4 with IP anonymisation enabled. Only placed with your explicit consent via the cookie banner. You can withdraw consent at any time by clicking "Cookie Settings" in the footer.
• No advertising or tracking cookies of any kind are used.

6. Data Sharing

We use the following sub-processors who may process data on our behalf:

• Formspree (form submission handler) — processes email addresses for newsletter sign-ups. Privacy policy: formspree.io/legal/privacy-policy
• Vercel (hosting) — hosts the website infrastructure. Privacy policy: vercel.com/legal/privacy-policy
• Google Analytics 4 (analytics, consent-gated) — anonymised usage analytics. Privacy policy: policies.google.com/privacy

7. Data Retention

• Newsletter email: retained until you unsubscribe. Deleted within 30 days of unsubscribe request.
• Server logs: deleted after 30 days.
• Analytics data: retained for 14 months in GA4 (Google default), then automatically deleted.

8. Your Rights (GDPR / LOPDGDD)

Under GDPR (EU Regulation 2016/679) and LOPDGDD (Spain, Ley Orgánica 3/2018), you have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Correct inaccurate or incomplete data.
• Erasure ("right to be forgotten"): Request deletion of your data.
• Portability: Receive your data in a structured, machine-readable format.
• Restriction: Request that we limit processing of your data.
• Objection: Object to processing based on legitimate interests.
• Withdraw consent: Unsubscribe from the newsletter at any time via the link in any email, or contact us directly.

To exercise any of these rights, email legal@neverhodl.com. We will respond within 30 days as required by law. You also have the right to lodge a complaint with the AEPD (Agencia Española de Protección de Datos) at aepd.es.

9. Security

We implement industry-standard security measures including HTTPS encryption, Content Security Policy (CSP) headers, rate limiting on all form endpoints, and regular security audits. No system is 100% secure; in the event of a data breach affecting your personal data, we will notify you as required by GDPR Art. 34.

10. International Transfers

Your data may be processed in the United States by Formspree and Google. These transfers are covered by Standard Contractual Clauses (SCCs) as required by GDPR Chapter V and the EU-US Data Privacy Framework.

11. Children

NeverHodl is not directed at children under 16. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child, contact us immediately at legal@neverhodl.com.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated via a notice on the website and, where appropriate, by email. The "Last updated" date at the top of this page indicates when the policy was last revised.

13. Disclaimer

NeverHodl is a market data and educational intelligence platform. Nothing on this website constitutes financial advice, investment advice, or a recommendation to buy or sell any asset. All investment decisions are the sole responsibility of the user. Crypto assets are highly volatile and can lose all their value. DYOR.