Privacy by design
MTBM Capital uses first-party usage measurements to understand whether the private site works reliably and which pages are useful. The analytics system is not used for advertising, profiling, data sales, or tracking people across websites.
Data collected
- Page category without query strings or record identifiers
- Referring domain without its path or query
- Coarse device, browser, and operating-system family
- Optional country code only when supplied by a trusted proxy
- A daily rotating pseudonymous visitor key
Not stored in analytics
- Raw IP addresses or precise location
- Full browser user-agent strings or device fingerprints
- Passwords, authentication tokens, or form contents
- Portfolio values, model selections, or financial records
- Persistent cross-day visitor identifiers
Purpose and lawful basis
MTBM Capital relies on legitimate interests under Article 6(1)(f) of the UK GDPR and EU GDPR, where applicable, to operate, secure, and improve this private service. The measurement is limited to what is necessary for reliability, capacity planning, and understanding page use. It is not used for advertising, financial profiling, or automated decisions. You may object at any time by disabling usage analytics on this page without losing access to the site.
Retention and safeguards
Daily visitor keys rotate every UTC day and are removed from events after 2 days. Detailed page-view records are retained for 30 days. Non-identifying daily totals may be retained for up to 730 days. Access is restricted to the authenticated administrator, and collection failures never block access to the site.
Standard server and security logs may process network addresses separately for abuse prevention and operations. Those logs are not joined to the visitor dashboard and follow their own restricted retention policy.
Investor portal records
If you are given individual investor access, the service processes your name, optional email address, contribution and withdrawal ledger, distributions, fees, valuation history, access status, and latest login time to provide and secure your portfolio view. Passwords are not stored in readable form. Investor records are not added to the visitor analytics dashboard and are not used for advertising or automated decisions.
These records are retained for the investor relationship and any applicable financial, legal, or accounting period. You may request access, correction, restriction, or deletion where applicable by contacting the address below. Some ledger records may need to be retained to meet legal obligations or establish and defend legal claims.
Questions and privacy rights
The daily identifier is deliberately not connected to a name or account, so the operator generally cannot identify an individual analytics record. You may disable collection in this browser at any time. Where applicable, you may object to this processing, request access or deletion when a record can reasonably be linked to you, and lodge a complaint with your local data-protection authority. For access, deletion, objections, or other privacy questions, contact mtbmcapital@gmail.com.