Data controller
Controller for the public website:
Sébastien Bartholomé — SB-ITM
Chaussée de Houffalize 4B
6600 Bastogne, Belgium
Email: sebastien@sb-itm.eu
This policy concerns the public SB-ITM website. The separate client portal, brokerage services and third-party marketplaces may be governed by additional privacy information.
Data concerned
Email contact: if you write to SB-ITM, we may receive your name or email address, the contents of your message and any information you voluntarily include.
Technical access: hosting and security systems may process connection information, such as IP address, date and time of access, requested pages, browser information and technical error or security events.
The public website does not include an account-registration form. Visitors may voluntarily submit information through the Jotform AI chatbot described below. Do not send passwords, IBKR credentials, API keys or sensitive financial records through the chat or general contact email.
Optional AI chatbot (Jotform)
The public website embeds an AI chatbot provided by Jotform. This assistant is automated, not a human operator. You may choose whether to use it. When you use the chat, your messages, the assistant's replies and relevant technical connection information may be processed to provide answers and operate the service. Chat conversations may be recorded and retained in the Jotform service, according to its applicable settings and policies.
These interactions are used to answer questions about SB-ITM products and documentation and to handle relevant follow-up requests. Depending on the request, the relevant GDPR legal basis may include steps requested before a possible contract (Article 6(1)(b)) or legitimate interests in responding to enquiries (Article 6(1)(f)); any non-essential cookies or similar tracking would require the appropriate consent where applicable.
Do not enter brokerage credentials, passwords, API keys, account statements or sensitive financial or personal information. For account-specific support, use the official SB-ITM contact or client channels.
Further information: Jotform Privacy Policy, Jotform AI Policy and Jotform AI Terms.
Purposes and legal bases
Email correspondence is used to answer enquiries and manage related follow-up. Its legal basis is the legitimate interest in responding to requests, or steps taken at your request before a possible contract where applicable (GDPR Article 6(1)(f) or (b)).
Technical connection data may be processed to deliver, troubleshoot and secure the website, on the basis of legitimate interests in availability and network security (Article 6(1)(f)). Where a specific legal obligation applies, processing may rely on Article 6(1)(c).
The public website does not currently use visitor data for advertising profiles or audience analytics.
Hosting and recipients
Hosting provider:
OVH SAS (OVHcloud)
2 rue Kellermann
59100 Roubaix, France
RCS Lille Métropole 424 761 419
Technical data may be accessible to the hosting provider where necessary to operate and protect the hosting service. Email correspondence may also be processed by the email services used by sender and recipient for delivery and storage.
Jotform and its AI-service subprocessors may process data provided in chat conversations to deliver the embedded assistant, subject to their applicable terms and privacy notices. SB-ITM does not sell visitors’ personal data. External destinations linked from the site manage their own information under their privacy policies.
Cookies and tracking
SB-ITM does not intentionally deploy its own advertising or audience-analytics scripts on this public site. The embedded Jotform AI chatbot loads a third-party service, which may use technical identifiers, cookies or similar technologies depending on its configuration and the visitor's interaction.
Any non-essential cookies or similar technologies must be subject to appropriate prior consent where required. The actual behaviour of the embedded widget must be verified in the deployed browser configuration; the presence of this policy alone does not establish cookie compliance.
The client portal and external destinations are separate services and may apply their own cookies and privacy rules.
Data retention
Contact emails are kept for the time reasonably required to answer the enquiry and handle necessary follow-up. They may be retained longer only where needed for a legal obligation or for the establishment, exercise or defence of legal claims.
Server and security logs are retained according to the effective hosting configuration, for as long as necessary for website operation, troubleshooting and security. They should not be retained longer than required for these purposes. Chat conversations may be stored through Jotform; the applicable retention period depends on the configured service settings and legal requirements. Contact SB-ITM to request information about retention or deletion of chat content.
External destinations and international transfers
The site includes an embedded chatbot operated by Jotform and potentially supported by AI-service subprocessors. Chat data may be processed in jurisdictions outside the European Economic Area according to the service configuration and applicable contractual safeguards. Clicking other external links, including the broker, portal, videos or marketplace, takes you to those providers’ services.
Any transfer of personal data outside the European Economic Area by SB-ITM must be assessed and protected as required by the GDPR. The actual email and hosting arrangements must be checked before any claim that all data remains within the EEA.
Your GDPR rights and complaints
Subject to the legal conditions, you can request access, rectification, erasure, restriction or portability of your data, and object to processing based on legitimate interests. You may also request information about how your data is handled.
For rights requests, write to sebastien@sb-itm.eu. You also have the right to lodge a complaint with the Belgian Data Protection Authority (APD).
Security and updates
Appropriate organisational and technical safeguards are intended to protect the public site and information involved. No online transmission can be promised completely secure.
This notice will be reviewed when hosting, messaging, cookies, data collection or providers change.
Scope: public information site only. The handling of client trading accounts, subscriptions and support within other services must be described in the applicable separate policies and agreements.