What Oneiros Vision holds about you, why, how long for, and the rights you have over it.
Last Updated: October 2026 | Version: 1.6
This notice explains what personal data Oneiros Vision holds about the people who use its terminal, its API and its website, why, for how long, who else sees it, and the rights people have over it. It applies to the people who use the terminal under a subscription, to applicants, to the colleagues an adviser adds to a firm, and to visitors to www.oneirosvision.com.
What it does not cover. The books and mandate records a subscriber enters may contain data about the subscriber's own clients. Oneiros Vision processes that data on the subscriber's behalf, as its processor, under the Data Processing Agreement, and the subscriber's own privacy notice tells its clients about it.
The controller of your personal data is Oneiros Vision Research S.R.L., a company registered in Romania under registration number CUI 51610020 (trade register number J2025025914004; registered office Str. Stadionului nr. 15, bl. 3, sc. A, et. 2, ap. 12, Târgu Secuiesc, Covasna County), trading as Oneiros Vision. The change of the company's registered name to Oneiros Vision Research S.R.L. is being entered in the trade register; its registration code and trade register number stay the same, and this notice binds the same legal person throughout. Write to it at contact@oneirosvision.com.
Because Oneiros Vision is established in the European Union, the GDPR governs its processing of personal data for every subscriber, not only those resident in the EU.
Oneiros Vision has not appointed a Data Protection Officer, and is not required to (Article 37): it carries out no large-scale monitoring and processes no special categories of data.
For people in Switzerland, the Swiss Federal Act on Data Protection (FADP) also applies. No Swiss representative is required: article 14 of the FADP requires one only where all four of its conditions are met, and the processing here is neither large-scale nor high-risk.
Registration and account. From you, at registration: your full name, e-mail address, firm name and username; the professional attestation you give; a password, which is stored only as a bcrypt hash; and the secret for your authenticator app.
The registration form also asks how you heard about Oneiros Vision. It is optional, it is free text, and leaving it blank has no effect on your application. It is read by the administrator who reviews your registration and is used for nothing else: there is no analytics or advertising system for it to feed. If you name someone who referred you, that person's name is held on your account record and is subject to everything in this notice, including erasure.
The form also asks for your firm's website and a regulator and registration number (for example an SEC CRD or FCA FRN number). Both are optional. They are read by the administrator who reviews your registration, to check the firm against its public register, and are used for nothing else. When the form is submitted, the domain of your email address - never the address itself - is looked up in the public DNS to confirm that it can receive mail.
The record of your agreement. When you register, OV records which version of the Terms & Conditions you agreed to, which version of this notice you were shown, when, and the IP address the registration came from. When you accept a new version of the Terms in the terminal, and when you expressly accept the clauses the Terms list for that purpose, the acceptance is recorded in the same way. We also record which notice of a change to the Terms we e-mailed you. This is the evidence of the agreement between you and OV, held because the contract needs it.
Accounts on a firm's subscription. A Practice subscription is a firm account: the adviser who holds it is the firm's administrator, and the colleagues they invite use the terminal as members of that firm. The administrator sees each member's name, e-mail address and the time of their last sign-in, and may remove a member. A member's name and e-mail address come from the administrator, not from the member, and the invitation e-mail links to this notice. The books saved by any adviser of the firm are on every adviser's book bar, and a mandate's record names the adviser who wrote each entry.
Security and usage records. The time of each sign-in and the IP address it came from, and an administrative audit trail of actions on accounts, each entry with the address and browser it came from. Passwords are checked against known breaches by sending only the first five characters of a one-way hash of the password; the password and the full hash never leave the server.
Requests to the Platform's API. Subscribers on an API plan generate a second, separate record: one row per API call, holding the account name, the endpoint, the response and the address the call came from. It exists so that usage can be shown to an administrator and so that a leaked API key can be investigated. The rows are kept for up to 12 months, the longest period the usage view can display. The calling address is removed after 30 days, well before the row itself: it is the only part that identifies anyone, and the usage view never displays it.
Billing. Stripe gives us a customer reference and the state of your subscription. Card details are held only by Stripe and are never accessible to OV. Invoices show the billing name, address and VAT number given to Stripe.
Correspondence. E-mails you send us, and our replies.
A note on portfolio allocations. The Platform stores the holdings a subscriber enters, together with a free-text name for each portfolio. That name should not identify an end client. Oneiros Vision has no relationship with a subscriber's clients and does not wish to hold their names; a reference such as "Balanced mandate 3" tells one portfolio from another.
| Purpose | Lawful basis |
|---|---|
| Opening and running your account; signing you in with two factors; providing the terminal and the API; the service e-mails the account needs (verification codes, invitations, trial reminders, notices of changes to the Terms, and the alerts you set) | Performance of a contract, Article 6(1)(b), and before a contract exists, the steps you asked for |
| Checking an application: firm website, regulator number, DNS check of the e-mail domain | Article 6(1)(b), steps before a contract at your request; and legitimate interests, Article 6(1)(f), in admitting only professional firms |
| Charging for subscriptions | Article 6(1)(b) |
| Keeping invoices and accounting records | Legal obligation, Article 6(1)(c): Romanian accounting law (Law 82/1991) and the Fiscal Code |
| Security records: sign-in times and addresses, the audit trail, rate limits, API call records | Article 6(1)(f). The interest is keeping accounts belonging to financial professionals from being taken over, and detecting it if they are. |
| The record of your agreement; the pseudonymised billing record kept after a paid account is deleted; the record of deletions (section 8) | Article 6(1)(f): proving the contract, answering payment disputes and chargebacks, and keeping deletions in force |
| Product e-mails during the trial, which explain how the engine works | Article 6(1)(f), with the opt-out in section 11 |
| Server logs and site measurement (section 13) | Article 6(1)(f) |
| Establishing, exercising or defending legal claims, and answering lawful requests of authorities | Article 6(1)(c) or (f), as the case requires |
Providing the account data is a contractual requirement rather than a statutory one: it cannot be withheld and an account still opened.
Your right to object. Where we rely on legitimate interests, you may object at any time, on grounds relating to your situation, by writing to contact@oneirosvision.com. We then stop, unless we have compelling legitimate grounds that override your interests, or the processing is needed for legal claims. You may stop product e-mails at any time, with no reason needed.
Oneiros Vision uses a small number of providers.
Processors, which act on Oneiros Vision's instructions only:
Stripe, Inc. and Stripe Payments Europe, Ltd. — payments, invoices, receipts and the billing portal. Stripe acts partly for Oneiros Vision and partly as an independent controller, for fraud prevention and its own duties as a regulated payment provider; for that part, Stripe's own privacy policy applies.
Others, where needed: our accountant and lawyers, bound to confidentiality; authorities, where the law requires it; and, within a firm, the administrator (section 2).
No other provider receives personal data: market and macro data are read from their sources with no account or client identity attached, and the uptime checks see only the health addresses. Oneiros Vision does not sell, rent, lease or share personal data for marketing or advertising.
The server and the off-site backups are in the European Union. The operator also keeps an encrypted copy of the backups on its own workstation, which stays in the European Economic Area or in Switzerland; the European Commission recognises Switzerland as ensuring an adequate level of protection.
Stripe and Backblaze are established in the United States, and each relies on its own safeguards under Chapter V of the GDPR: the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795), where the company is certified, and the Commission's standard contractual clauses. What Backblaze holds is ciphertext. For people in Switzerland, the destination states are recognised as adequate under article 16 of the FADP, or the same safeguards apply.
| Data | Kept for |
|---|---|
| Account data after a subscription ends | 365 days after the subscription ended, up to 12 months, so that a returning customer finds the account in place; then erased automatically. The clock is cleared if the account resubscribes. |
| Portfolio allocations | They are kept for 30 days after the subscription lapses, then deleted. |
| The mandate record | With the account: erased with it, 365 days after the subscription ended |
| A registration whose e-mail address is never confirmed | 7 days |
| Firm members' accounts | As long as the member holds a seat; removing the seat deletes the account, and a firm's members go with the firm's account |
| The pseudonymised billing record of a deleted paid account | 12 months (section 9) |
| Invoices and accounting records | 5 years from 1 July of the year after the financial year in which they were issued (Law 82/1991, art. 25) |
| The audit trail | 3 years from each entry, the general limitation period for claims (Civil Code art. 2517); then deleted |
| The record of deletions: a one-way code for each deleted account, never its name | 13 months, as long as a backup can hold the account (section 8) |
| API call records | Up to 12 months; the calling IP address is removed after 30 days |
| Server logs | Retention: 14 days |
| Backups | At most 13 months, on a fixed schedule (section 8) |
| Correspondence | While the matter is open, and for 3 years after the last exchange |
A registration whose email address is never confirmed is erased 7 days after it was made, and nothing is sent to that address in the meantime: an unconfirmed registration cannot sign in, and it is often not the address holder's at all.
You have the right to:
Write to contact@oneirosvision.com from the e-mail address on your account, or sign in and use Account settings. A request is answered within one month, as Article 12(3) requires; that period can be extended by two months for complex requests, and we tell you if it is. For people in Switzerland, information is in general given within 30 days (FADP article 25). Exercising your rights is free.
The database is backed up every night. The backups are kept on a fixed schedule: every backup for a week, one a week for a month and one a month for a year, then erased. The off-site copy in Amsterdam is encrypted before it leaves the server, cannot be altered or deleted for its first 30 days, and is erased a year and a day after it was taken; the operator's encrypted copy keeps the same year. A backup therefore never holds data for more than 13 months.
Backups are used only to recover the whole service after a disaster, never to restore or read a single account. If a backup is ever restored, the accounts deleted after it was taken are deleted again before the service reopens, from a record of deletions kept for that purpose and copied off the server every night.
You can delete your own account at any time from Account settings in the terminal; you do not need to ask. Any live subscription is cancelled, and your profile, sign-in details, second factor, books, mandates, mandate record and settings are erased from the service, at once.
Four things outlast the account, each for a stated time and reason:
You may complain to us first, at contact@oneirosvision.com, or to a supervisory authority at any time:
Oneiros Vision sets only authentication and security cookies, and only on the terminal. The public website at www.oneirosvision.com sets no cookies at all.
| Cookie | What it is for | How long it lasts |
|---|---|---|
| __Host-auth_token | Your session on the terminal: it keeps you signed in from one page to the next. | 24 hours from signing in, or less if the session itself expires sooner; a terminal left alone is signed out after 30 minutes without activity |
| __Host-mfa_token | Holds your place between your password and the code from your authenticator app. It opens nothing on its own. | 5 minutes |
| __Host-mfa_enroll_secret | Used only while you set up an authenticator app for the first time, and deleted when setup finishes. | 5 minutes |
All of them are first-party, are sent only over an encrypted connection, and are readable only by the Oneiros Vision server, never by scripts in your browser.
Settings kept in your browser. The terminal also keeps a few of your own settings in the browser's storage on your device: the text size you chose; the order list's minimum order and drift band; the time of your last activity, so that every open tab is signed out together after 30 minutes without it; the screen you were last on; and whether you put away the notice of a coming change to the Terms, for that version. None of them leaves your device or identifies you.
Why you are not asked to consent to them. Every one of them is strictly necessary to provide a service you explicitly asked for, and they are therefore exempt from the consent requirement in Article 5(3) of the EU ePrivacy law, implemented in Romania by Law 506/2004. Oneiros Vision runs no analytics, no advertising and no tracking of any kind, on the terminal or the public website. If that ever changes, consent will be asked for before any such script runs, and declining will leave it switched off. A control that records a preference and then ignores it is not consent, and Oneiros Vision will not ship one.
The servers keep a log of the requests they receive: the IP address the request came from, the time, the page or file asked for, the response, the browser's self-description and the page that linked there.
Two purposes, and no others: keeping the service running and secure, and counting, in aggregate, visits to the public site. The lawful basis is Article 6(1)(f).
Retention: 14 days for raw logs. Statistics are kept only in aggregated form, and addresses are truncated before they reach the analytics system at all. Log data is never matched against Subscriber accounts, and there is no third-party script on either site. Because nothing is stored on or read from your device to do this, no consent is required; if that changes, consent will be requested first.
Oneiros Vision makes no decision producing legal or similarly significant effects about you by automated means, and carries out no profiling within the meaning of Article 22. Regime classifications are computed from market data, not personal data. A portfolio's measurements describe the portfolio; they are not a decision about a person, and they are not investment advice.
Two factors on every account, encrypted connections, a database that cannot be reached from the internet, encrypted off-site backups, and access limited to the people who run the service. The Security Overview, available on request, sets out more for the security reviewers of subscribing firms.
Each version is numbered and dated. Material changes are announced by e-mail and in the terminal before they apply. Earlier versions are available on request.
Contact: Oneiros Vision Research S.R.L. (trading as Oneiros Vision), CUI 51610020, contact@oneirosvision.com, www.oneirosvision.com, +40 748 910 049 (Romania), +41 77 807 46 17 (Switzerland, in English).