Back to Home

Legal Notice and Privacy Policy

Last updated: January 3, 2026

1. Site Editor

The Insider Momentum website is published by:

Name: Nathan Bonelli

Status: Sole proprietorship

Country of residence: France

SIRET: 91500788400017

Contact email: insider.momentum.strategy@gmail.com

2. Hosting

The site is hosted by Vercel Inc., located in the United States.

Vercel Inc.

340 S Lemon Ave #4133

Walnut, CA 91789, United States

European users' personal data is stored in the European Union via Supabase (EU region), in accordance with GDPR.

3. Service Purpose

Insider Momentum is an information service that provides data and analyses regarding insider transactions filed with the SEC (Securities and Exchange Commission) on US financial markets.

⚠️ Important: Nature of service

The service provides exclusively general information based on public data (SEC Form 4). The information disseminated is not personalized and does not take into account the user's financial situation, assets, tax situation, or investment objectives.

The service does not fall within the scope of investment advice within the meaning of MIFID II or the French Monetary and Financial Code. This is an independent and non-personalized information service.

  • We do NOT provide investment advice within the meaning of MIFID II and French regulations.
  • We do NOT practice automated trading or automatic order execution. Our service is limited to providing information and signals.
  • We do NOT manage funds or offer portfolio management services.
  • The information provided is for informational purposes only and does not constitute a solicitation to buy or sell financial securities.

4. Risk Warnings

⚠️ Investment Risks

Investing in financial markets carries risks of capital loss. Past performance does not prejudge future performance.

  • Risk of total or partial loss of invested capital
  • Market volatility: Asset prices can fluctuate considerably both up and down.
  • Liquidity risk: Some securities may be difficult to sell quickly.
  • Currency risk: Investments in foreign currencies expose to currency risk.
  • Risk specific to reported insider transactions: Insider transactions filed with the SEC do not guarantee the future performance of a security. Insiders may be wrong or have motivations other than performance.

It is strongly recommended to consult an independent financial advisor before any investment decision.

5. Limitation of Liability

The site editor strives to ensure the accuracy and updating of information disseminated on the site. However, the editor cannot guarantee the accuracy, precision, completeness, or timeliness of the information made available.

Liability exclusion

  • The editor cannot be held responsible for financial losses resulting from the use of information provided on the site or received via the newsletter.
  • The editor does not guarantee that the signals or information provided will lead to gains or positive results.
  • The user is solely responsible for verifying the suitability of the information with their personal, financial, asset, tax situation and investment objectives.
  • The user acknowledges using the information at their own risk and under their sole responsibility.
  • The editor cannot be held responsible for investment decisions made based on the information provided.
  • The editor does not guarantee the frequency, continuity, or permanent availability of signals or publications.

6. Right to Modify and Suspend

The editor reserves the right to modify, suspend, or stop all or part of the service at any time, without obligation of result or notice.

The editor also reserves the right to modify the content, methodology, or frequency of publications without obligation of result or notice.

7. Intellectual Property

All content on the site (texts, images, logos, graphics, etc.) is the exclusive property of Insider Momentum or its partners and is protected by French and international laws relating to intellectual property.

Any reproduction, representation, modification, publication, or adaptation of all or part of the site's elements, whatever the means or process used, is prohibited without prior written authorization from the editor.

8. Personal Data Protection (GDPR)

In accordance with the General Data Protection Regulation (GDPR - EU Regulation 2016/679) and the Data Protection Act, we inform you of our personal data protection policy.

8.1 Data Controller

The data controller for personal data is:

Nathan Bonelli

Email: insider.momentum.strategy@gmail.com

8.2 Data Collected

As part of our newsletter service, we collect only :

  • Your email address - necessary for sending the newsletter

We do NOT collect:

  • Your first or last name
  • Your IP address
  • Your user agent or browsing information
  • No other personal data

Cookies and analytics: We use Vercel Analytics to measure site performance (page views, Web Vitals). No third-party tracking cookies are used. Analytics data is stored anonymously and in accordance with GDPR.

8.3 Processing Purposes

Your data is collected and processed for the following purposes:

  • Sending the weekly newsletter (free or paid)
  • Managing your subscription
  • Service-related communication (changes, technical incidents)

8.4 Legal Basis for Processing

The processing of your data is based on:

  • Your consent: by subscribing to the newsletter, you consent to the processing of your email for sending our communications.
  • Contract performance: for paid subscribers, processing is necessary for the performance of the subscription entered into.

8.5 Data Recipients

Your data is accessible only to:

  • The data controller (Nathan Bonelli)
  • Our technical subcontractors, in compliance with GDPR:
    • Supabase (database hosting - EU servers)
    • Resend (transactional email sending)
    • Stripe (payment - for paid subscribers only)

Your data is never sold, rented, or transferred to third parties.

8.6 Retention Period

Your data is retained:

  • Active subscribers: for the entire duration of the subscription
  • After unsubscription: immediate and definitive deletion
  • Paid subscribers: billing data is retained according to legal accounting obligations (10 years) by Stripe

8.7 Data Transfer Outside EU

Your email data is stored on servers located in the European Union (Supabase - EU region).

Some subcontractors (Stripe, Resend) may process data in the United States. These transfers are governed by appropriate safeguards (European Commission Standard Contractual Clauses).

8.8 Your Rights

In accordance with GDPR, you have the following rights:

  • Right of access: obtain confirmation of processing of your data and receive a copy
  • Right of rectification: have your inaccurate data corrected
  • Right to erasure: request deletion of your data
  • Right to data portability: receive your data in a structured format
  • Right to object: object to the processing of your data
  • Right to withdraw your consent at any time

To exercise your rights:

  • Email: insider.momentum.strategy@gmail.com
  • Unsubscribe: unsubscribe page

You can also file a complaint with the CNIL (National Commission on Informatics and Liberty): www.cnil.fr

8.9 Data Security

We implement appropriate technical and organizational measures to protect your data:

  • Communication encryption (HTTPS/TLS)
  • Restricted data access (strong authentication)
  • Secure hosting with Supabase (SOC 2, ISO 27001 certifications)
  • No payment data storage (managed by Stripe PCI-DSS)

9. Payments and Paid Subscriptions

Payments for paid subscriptions are processed by Stripe, a PCI-DSS certified payment processor.

Stripe Payments Europe, Limited

We never have access to your credit card information. This is processed directly by Stripe securely.

To manage your paid subscription (modify, cancel), you can access your Stripe customer portal via our management page.

10. Terms of Use

Access to and use of the site is free and free for consulting public information.

Free Newsletter

Subscription to the free newsletter requires only your email address. You can unsubscribe at any time via the link in each email or via our unsubscribe page.

Paid Subscription

The paid subscription gives you access to daily insider activity analyses before their public publication. Payment is managed by Stripe.

Right of withdrawal: In accordance with Article L221-18 of the Consumer Code, you have a 14-day period to exercise your right of withdrawal without having to justify reasons.

Cancellation: You can cancel your subscription at any time from your Stripe customer portal. Access remains active until the end of the paid period.

11. Applicable Law and Competent Jurisdiction

These legal notices are governed by French law. In case of dispute and in the absence of an amicable agreement, the dispute will be brought before French courts in accordance with the rules of jurisdiction in force.

12. Contact

For any questions regarding these legal notices, data protection, or the service, you can contact us at the following address:

Email: insider.momentum.strategy@gmail.com

Response time: We commit to responding to any request relating to your personal data within a maximum of 30 days.