Last updated · 6 October 2026
Privacy Policy
Who handles your data, for what, for how long, and how to exercise your rights.
Who controls this data
21Core AI is run by its founder, Afonso Martins, in Madeira, Portugal, while the company is being registered. Until registration completes, Afonso Martins is the controller of the personal data described in this policy. The company then takes over as controller: we will update this policy and tell everyone with an open engagement. Data-protection questions and requests: afonso@21coreai.com.
What the enquiry form collects
The kind of organisation you work for, the package you are asking about, your timeframe, name, email and organisation, an optional role and your message. Your IP address may be used briefly for security and abuse prevention. The form does not ask for and will not accept deposits, wallet keys, credentials, API keys, account identifiers, trading records, suitability answers or financial details.
Engagement material
Under an engagement letter you may share decision logs, configurations or your own data. We keep it on our own workstation in the EU and use it only for that engagement. A Full review runs inside your environment, and only the verdict leaves it. If it includes other people’s personal data, the letter says how we handle it. Every copy is deleted when the work ends, including backups as they rotate out, and we confirm it in writing.
Purposes and legal bases
We use enquiry data to reply, judge whether a package fits and take the steps you ask for before a contract. For an engagement, we use what is needed to deliver the work, invoice, meet legal obligations and establish or defend legal claims. Abuse prevention rests on our legitimate interest in protecting the site. Site measurement runs only with consent.
Market data and wallet addresses
Our record is built from public venue data, the public Polygon chain and licensed vendor history, not from this site, its visitors or our clients. Its personal data, wallet addresses and their trades, comes from the public chain and the venues’ public data, not from the people concerned.
Legal basis: legitimate interests (GDPR Article 6(1)(f)).
- Interest: an independent record of how markets traded, for market integrity, research and evidence that regulators, courts and leagues can check.
- Necessity: on the chain, a trade is attributed only by its address.
- Balance: the data is pseudonymous and already public; we never enrich an address with off-chain identity; public pages show only labels, such as W01; we keep only what the record needs, for no longer than reproducibility requires, and keep it secure; and anyone can object, as set out below.
Processors and recipients
Vercel hosts the site and keeps security and technical logs. Resend delivers your enquiry to us by email. Vercel Analytics and Speed Insights measure use of the site, only after you consent. Calendly processes the details you enter in it if you book a call. In full, wallet addresses go only to a client whose engagement or licence needs them, such as the client who commissioned a Case File covering them or a data licensee, each an independent controller. A licence bars any attempt to identify the person behind an address. We do not sell contact data, and we never disclose one client’s material to another.
International transfers
Some of these providers, clients and licensees may be outside the European Economic Area. Personal data goes to them only under a GDPR safeguard, such as an adequacy decision or the European Commission’s standard contractual clauses. Ask us for a copy through the contact above.
Retention
Enquiries that lead to no work are kept for up to 12 months after the last contact, unless you ask us to erase them sooner or the law requires otherwise. Engagement letters and invoices are kept for the periods the law sets. The market record is kept for as long as the work built on it must stay reproducible.
Measurement and preferences
Your measurement choice is stored in your browser. Declining does not affect the enquiry form or any site content. You can change it at any time through . Technical logs strictly needed for security and delivery of the site do not depend on this choice.
Wallet holders: your right to object
You may object at any time. We cannot tell who is behind an address, so for this or any other request about one, first show us it is yours, for example by signing a message with it. We then stop using it in new deliveries, unless we need it to establish, exercise or defend legal claims, and pass your objection on to every licensee that received it.
Your rights
You may ask for access, rectification, erasure, restriction, portability or objection, and withdraw consent where it applies. Write to afonso@21coreai.com. You may also complain to the Comissão Nacional de Proteção de Dados.