Privacy Policy

Last Updated: January 1, 2026

Effective Date: January 1, 2026

Introduction

This Privacy Policy describes how Progressium LLC ("we," "our," or "us") collects, uses, and protects your personal information when you use our website and services. We are committed to protecting your privacy and ensuring the security of your personal data in compliance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

Data Controller Information

Progressium LLC is the data controller for the personal information we collect. Our contact details are:

Data Collection

We collect personal data when you interact with our website and services. The data we collect includes:

Information You Provide Directly

  • Name and contact information (email address, phone number, mailing address)
  • Financial information relevant to our services (income, expenses, financial goals)
  • Communication preferences and marketing consents
  • Messages and correspondence you send to us
  • Account information if you create an account with us

Information We Collect Automatically

  • Website usage data and analytics information
  • IP address, browser type, and device information
  • Cookies and similar tracking technologies (see our Cookie Policy)
  • Pages visited, time spent on our website, and referral sources

Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

  • Consent: When you provide explicit consent for marketing communications or cookies
  • Contract Performance: To provide our financial services and fulfill our obligations to you
  • Legitimate Interest: To improve our services, conduct analytics, and ensure website security
  • Legal Obligation: To comply with applicable laws and regulations

How We Use Your Information

We use the personal data we collect for the following purposes:

  • Providing financial planning services and consultations
  • Communicating with you about our services and responding to inquiries
  • Sending marketing communications (with your consent)
  • Improving our website and services through analytics
  • Ensuring the security and proper functioning of our website
  • Complying with legal and regulatory requirements
  • Processing payments and managing client accounts

How we use your information depends on how you interact with our services and the consents you provide. We will only use your data for the purposes stated in this policy or as otherwise communicated to you.

Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your information in the following circumstances:

  • Service Providers: With trusted third-party service providers who assist us in operating our website and providing services
  • Legal Requirements: When required by law, regulation, or legal process
  • Business Transfers: In connection with a merger, acquisition, or sale of business assets
  • Consent: When you provide explicit consent for specific sharing purposes

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws. Generally, we retain client data for seven years after the end of our business relationship for legal and regulatory compliance purposes. Website analytics data is typically retained for 26 months. You can request deletion of your data at any time, subject to legal obligations that may require us to retain certain information.

Your Rights

Under GDPR and applicable privacy laws, you have the following rights regarding your personal data:

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data in certain circumstances
  • Right to Restrict Processing: Request limitation of how we use your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent where processing is based on consent

To exercise any of these rights, please contact us at privacy@progressium.top. We will respond to your request within 30 days.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption of data in transit and at rest, regular security assessments, and staff training on data protection. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers are located. When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or adequacy decisions.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information about our use of cookies, please refer to our Cookie Policy.

Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the Irish Data Protection Commission or your local supervisory authority if you believe we have not handled your personal data in accordance with applicable laws.

Supervisory Authority

If you have concerns about how we handle your personal data, you can contact us directly. You also have the right to lodge a complaint with the Irish Data Protection Commission at www.dataprotection.ie or your local data protection authority.