Privacy policy

Who is responsible for your data

EFBS Trace is the controller of personal data collected through this website and in the course of providing legal services. You can reach us at support@trackfunds.ai or at the postal address in the footer.

TODO: name a data protection officer or contact, if one is required.

What we collect

When you use the contact form

• Your name, email address, and phone number if you give it.
• The category of matter, approximate timing, approximate value, and the description you write.
• Technical data collected as part of handling the request, including your IP address, which we use to limit automated abuse of the form.

When you become a client

• Identity and verification documents required by anti-money laundering and know-your-client rules.
• Case material you provide, which in these matters frequently includes financial records and communications, and may include special category data.
• Billing and payment records.

When you browse this site

We use Microsoft Clarity to understand how people move through this site — which pages they read, where they hesitate, and where they give up. It records anonymised sessions and builds aggregate heatmaps. We use it to make the site clearer, not to identify you.

Clarity collects:

• Pages viewed, time on each, and the order you visited them in.
• Mouse movement, scrolling, and clicks — recorded as a replay of the page, not a recording of your screen or camera.
• Device, browser, operating system, approximate location derived from your IP address, and the site you arrived from.
• Cookies set by Microsoft to recognise a returning browser across sessions.

What it does not collect. Clarity is configured with strict masking, so the contents of form fields are replaced before anything leaves your browser. Your name, email address, phone number, IBAN, wallet addresses, the amount you report losing, and any files you upload are not captured in session recordings. Those reach us only when you submit the form, and are handled as described above.

Microsoft acts as a processor for this data and may use it to improve its own services. Its practices are set out in the Microsoft Privacy Statement. Recordings are retained by Clarity for a limited period and then deleted.

Opting out. Browsers that send a “Do Not Track” or Global Privacy Control signal are respected by Clarity. You can also block it with any standard tracker-blocking extension, and nothing on this site will stop working. If you would rather we deleted the analytics data associated with your visits, email us and we will ask Microsoft to remove it.

We do not use analytics for advertising, we do not sell this data, and we do not combine it with the case information you send us.

Why we process it, and on what basis

• To respond to your enquiry — because you asked us to, and because we have a legitimate interest in answering people who contact us.
• To provide legal services — to perform our contract with you, and, for special category data, because processing is necessary for the establishment, exercise, or defence of legal claims.
• To meet our legal and regulatory obligations — client due diligence, conflict checks, and record-keeping required by our regulator.
• To protect this website — preventing spam and abuse of the contact form.
• To improve this website — anonymised analytics, on the basis of our legitimate interest in understanding whether people can find what they came for. See the analytics section above for what is collected and how to opt out.

Who we share it with

Only where necessary for your matter or our obligations: counsel and experts instructed on your case, courts and tribunals, regulators and law enforcement where we are required or permitted to disclose, our professional insurers and auditors, and the service providers who run our IT, email, and document systems under written terms.

We do not sell personal data, and we do not share it for third-party marketing.

AI-assisted processing

We use AI tooling to analyse case material — see our Technology & AI page for the detail. In summary: providers are engaged under terms that prevent client content being used to train their models; identifying detail is removed where it is not needed for the analysis; and no automated output is acted on without review by a qualified lawyer.

We do not make decisions about you by automated means alone that produce legal or similarly significant effects. You may ask us to handle your matter without AI-assisted processing.

International transfers

TODO: list the countries data may be transferred to and the safeguards relied on — adequacy decisions, standard contractual clauses, or equivalent. This section matters more than most firms treat it, particularly where AI providers are involved.

How long we keep it

• Enquiries that do not become matters: TODO — typically 12 months, then deleted.
• Client files: TODO — set by your regulator and your insurer, commonly 6–7 years after the matter closes.
• Anti-money laundering records: TODO — as required by the applicable regulations.

Your rights

Subject to the applicable regime, you may request access to your data, correction of it, erasure, restriction of processing, or portability, and you may object to processing based on legitimate interests. Some of these rights are limited where we are required to retain records or where legal professional privilege applies.

To exercise any of them, email support@trackfunds.ai. We will respond within the statutory period.

You also have the right to complain to a supervisory authority. TODO: name the relevant authority and link to it.

Security

We apply technical and organisational measures appropriate to material that is confidential and often privileged. Note that standard email and this website’s contact form are not secure channels — once you are a client we will give you a secure route for sending documents.

Changes

If we change this policy we will update the date below, and we will tell clients directly where a change is material.

Last updated: TODO — set a real date.