1. Identity of the Controller
This Policy is issued by the operator of the website published at appreviewhub.com, referred to as the Operator and the Website. The Operator determines the purposes and means of the processing described below and acts as controller in respect of it. Correspondence concerning this Policy, including requests under clause 11, must be addressed to contact@appreviewhub.com.
AppReviewHub publishes editorial material concerning fraudulent investment schemes, counterfeit brokerage platforms and deceptive trading applications. The processing described here is incidental to that editorial activity and to the enquiry facility on the Website.
2. Scope of this Policy
This Policy governs the processing of Personal Data relating to persons who visit the Website, submit an enquiry, or otherwise correspond with the Operator. It does not extend to any website or service operated by another person, notwithstanding that access may be obtained through a link published on the Website.
3. Definitions
“Personal Data”, “processing”, “controller” and “supervisory authority” bear the meanings assigned by Article 4 of Regulation (EU) 2016/679. “Data Subject” denotes the natural person to whom Personal Data relates. “Independent Legal Adviser” denotes a qualified lawyer, law firm or regulated advisory practice with which the Operator maintains a referral arrangement and which acts as a separate controller in respect of data transmitted to it.
4. Categories of Personal Data Processed
- Identification data. Name or alias supplied voluntarily in the enquiry facility.
- Contact data. Electronic mail address and, where volunteered, telephone number and country of residence.
- Enquiry content. The narrative submitted by the Data Subject, with any dates, sums or platform names volunteered within it.
- Technical data. Abbreviated internet protocol address, browser type, operating system, referring address and pages requested.
- Usage data. Aggregated measures of session duration and page sequence, with geographic region at country level.
- Correspondence data. The content and metadata of electronic mail exchanged with the Operator.
The Operator does not solicit the special categories of data enumerated at Article 9 and requests that Data Subjects refrain from submitting them. Where such data is nonetheless volunteered it is used solely to answer the enquiry and is deleted under clause 6.
5. Sources of Personal Data
Personal Data is obtained directly from the Data Subject whenever it is submitted through the enquiry facility or by correspondence. Technical and usage data is generated automatically by the interaction of the device of the Data Subject with the hosting servers. The Operator does not purchase Personal Data and does not enrich its records from commercial sources.
6. Purposes of Processing and Lawful Basis
Each processing operation rests upon a lawful basis identified in Article 6(1) of the General Data Protection Regulation, as follows.
| Purpose | Lawful basis under Article 6 GDPR | Retention |
|---|---|---|
| Reply to an enquiry submitted through the contact facility | Article 6(1)(b), steps taken at the request of the Data Subject, and Article 6(1)(f), legitimate interest in answering correspondence | 24 months from the last exchange |
| Transmission of enquiry details to an Independent Legal Adviser | Article 6(1)(a), explicit consent | 36 months, as a record of consent |
| Verification of enquiry assertions against published material | Article 6(1)(f), editorial accuracy | 24 months from verification |
| Operation and security of the Website, including logging | Article 6(1)(f), network and information security | 12 months from the entry |
| Aggregate audience statistics | Article 6(1)(a), consent at the cookie interface | 14 months |
| Defence of legal claims and compliance with legal obligation | Article 6(1)(c) and Article 6(1)(f) | The limitation period |
Where processing rests upon Article 6(1)(f) the Operator has conducted a balancing assessment and concluded that the interests pursued are not overridden by the rights of the Data Subject. A summary is available on request.
7. Enquiries Submitted Through the Contact Facility
Submission is voluntary. Only an electronic mail address and a narrative are required; further fields may be left blank without consequence to the handling of the enquiry.
Enquiry content is reviewed by editorial personnel and may be used to amend material already published. No enquiry is republished in identifiable form, and no name, address or transaction reference supplied by a Data Subject appears on the Website, unless separate written permission has been given.
8. Transmission to Independent Legal Advisers
AppReviewHub maintains referral arrangements with Independent Legal Advisers who assist individuals in preparing and lodging reports to financial regulators, law enforcement bodies and other competent authorities. Those practices are separate undertakings, not agents or subsidiaries of the Operator, and they determine independently the purposes and means of their own processing.
Transmission occurs only where the Data Subject has given explicit and specific consent. Consent is obtained by an unbundled affirmative act, distinct from the submission of the enquiry, and the identity of the intended recipient is disclosed beforehand. Silence does not constitute consent.
Consent may be withdrawn at any time by notice to contact@appreviewhub.com, with prospective effect. Following transmission the Independent Legal Adviser processes the data as an autonomous controller, and the Data Subject should address that practice directly in respect of rights arising against it.
9. Recipients and Processors
- The hosting provider, as processor under a written contract compliant with Article 28.
- The provider of electronic mail transport and storage, as processor.
- The provider of audience measurement, where consent has been signified.
- Independent Legal Advisers, as separate controllers, upon the consent described at clause 8.
- Professional advisers and competent public authorities, where required by law.
The Operator does not sell Personal Data and discloses none of it for advertising, profiling or the construction of marketing audiences.
10. International Transfers and Safeguards
Certain processors maintain infrastructure outside the European Economic Area. Where data is transferred to a country for which no adequacy decision has been adopted, the transfer is effected under the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914, supplemented where necessary by encryption in transit and at rest and by a documented assessment of the destination jurisdiction. A copy of the clauses relied upon may be requested at contact@appreviewhub.com.
11. Rights of the Data Subject
Subject to the conditions provided by applicable legislation, the Data Subject enjoys the following rights:
- Access. Confirmation whether Personal Data is processed, and a copy with the information specified at Article 15.
- Rectification. Correction of inaccurate data and completion of incomplete data.
- Erasure. Deletion in the circumstances set out at Article 17.
- Restriction. Limitation of processing under Article 18.
- Portability. Receipt of data in a structured, commonly used and machine readable format.
- Objection. Objection, on grounds relating to the particular situation, to processing under Article 6(1)(f).
- Withdrawal of consent. At any time where processing rests upon Article 6(1)(a).
- Complaint. Application to a supervisory authority as described at clause 12.
Requests should be submitted to contact@appreviewhub.com and should identify the right invoked with sufficient particularity to permit the records to be located. The Operator replies within one month, extensible by two further months where the request is complex, in which event the Data Subject is informed within the first month. No fee is charged save where a request is manifestly excessive. Where reasonable doubt exists as to identity, further information may be requested first.
12. Complaints and Competent Supervisory Authority
A Data Subject who considers that processing infringes applicable legislation is invited, though not obliged, to raise the matter at contact@appreviewhub.com in the first instance. Independently of any such approach, the Data Subject retains the right to complain to the supervisory authority of the Member State of habitual residence, of the place of work, or of the place of the alleged infringement. Data Subjects resident elsewhere may apply to the authority competent in their own jurisdiction.
13. Security Measures
The Operator implements technical and organisational measures appropriate to the risk. These include transport layer encryption across the whole of appreviewhub.com, encryption at rest of stored enquiry records, restriction of administrative access to named personnel under confidentiality obligations, multiple factor authentication, periodic review of privileges and prompt application of security patches. Enquiry records are purged automatically at the expiry of the periods stated at clause 6.
No system of transmission or storage is wholly secure. The Operator does not warrant absolute security but undertakes to notify the competent authority, and where required the affected Data Subjects, of any personal data breach in accordance with Articles 33 and 34.
14. Children Under Sixteen and Amendments
The Website is directed to an adult audience. The Operator does not knowingly process Personal Data relating to a person under sixteen years of age. Where it becomes aware that such data has been submitted, the record is deleted and the enquiry closed without substantive reply. A parent or guardian may notify contact@appreviewhub.com and the record will be erased.
This Policy may be amended to reflect changes in processing operations or in applicable law. The version in force is that published at appreviewhub.com and bears the year 2026. Where an amendment materially alters the manner in which Personal Data is processed, notice will be displayed on the Website for not less than thirty days beforehand. This Policy was last reviewed in 2026.