Effective date: 12 June 2026

Who we are. This site is operated by Altiora Limited, a company registered in Gibraltar at 5-9 Main Street, PO Box 411, Gibraltar (“we”). We are the data controller for the personal data described below. Contact: help(at)fivecardguy(dot)com

What we collect and why

1. Attribution analytics (our own, first-party).
When you arrive at this site through one of our links (for example from a YouTube video description via go.fivecardguy.com), we record:

• A random visitor ID and the link you clicked (stored in the cookies described below).
• A pseudonymised (hashed and salted, irreversibly truncated) version of your IP address and your browser’s user-agent string, used to filter out bots and de-duplicate clicks. We never store your raw IP address.
• The pages you visit on this site.

We use this to understand which of our videos lead people to our training and programs. We do not use third-party advertising trackers, we do not build advertising profiles, and we do not sell or share this data for marketing. Legal basis: consent (given via the cookie banner) for the cookies and page-visit tracking; legitimate interest for bot filtering.

2. Email signups.
If you subscribe to a list or download a free training, we collect your email address (and the video that referred you, if known) to send you the content you asked for and related emails. You can unsubscribe at any time via the link in every email. Legal basis: consent.

3. Call bookings and purchases.
If you book a call or buy a program, we collect your name, email, booking details and payment records (amount, date, payment method). Legal basis: performance of a contract; we keep payment records as required by accounting and tax law.

Cookies

Cookie	Purpose	Duration
visitor_id	Random ID so we can count you as one visitor	1 year
vid	Remembers which of our links first brought you here	1 year

Both are first-party cookies set on .fivecardguy.com. They contain no personal details — only a random ID and a link name. We use no third-party advertising cookies. Embedded services (Calendly scheduling, Kit signup forms) may set their own cookies when you use them; see their policies.

Analytics cookies and tracking are only activated after you accept them in the cookie banner. You can withdraw consent at any time via the cookie settings link in the footer, or delete the cookies in your browser.

Who processes your data

We use these service providers (processors) to run the site:

• Kit (ConvertKit, USA) — email list and signup forms.
• Calendly (USA) — call scheduling.
• Railway (USA) — hosting for our analytics database.

Where data is transferred outside Gibraltar/the UK/the EEA (all three providers are US-based), the transfer is protected by the providers’ standard contractual clauses and/or their certification under the EU–US / UK Data Privacy Framework.

How long we keep data

• Click and page-visit analytics: deleted or anonymised after 24 months.
• Email signup data: kept while you are subscribed; removed after you unsubscribe (Kit retains unsubscribe records to honour your opt-out).
• Booking and payment records: kept up to 6 years after the transaction, as required for accounting and tax purposes.

Your rights

Under the Gibraltar GDPR and the Data Protection Act 2004 you can ask us for access to, correction of, deletion of, or a copy of your personal data, and you can object to or restrict our processing. Email: help(at)fivecardguy(dot)com — we respond within one month. You can also complain to the Gibraltar Regulatory Authority (Information Commissioner), www.gra.gi.

Changes

We will update this page when our tracking or providers change, and revise the effective date above.