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Privacy Policy

Last updated: [EFFECTIVE_DATE]

Draft. This policy is a working draft pending legal review and is not legal advice. Bracketed values are placeholders to be completed before publication.

1. Controller

The data controller is [LEGAL_ENTITY], [ENTITY_ADDRESS]. For any privacy question or to exercise your rights, contact [CONTACT_EMAIL].

2. What we collect

3. Why we use it (lawful basis)

4. Sharing & visibility

Your data is private by default. You control what is shared via per-wallet and per-entry visibility settings (private / friends / public), including an option to show percentage allocations while hiding absolute amounts. Anything you mark public may be visible to other users and, where applicable, via public share links.

5. Processors & hosting

We use third-party processors to run the Service: Supabase (database, authentication, storage), our hosting provider, and a market-data provider. User data is stored in [SUPABASE_REGION]. These providers process data on our behalf under data processing agreements. Market data is fetched from third parties to display prices and benchmarks.

6. International transfers

Where data is transferred outside the European Economic Area, we rely on appropriate safeguards such as Standard Contractual Clauses. [Confirm per processor.]

7. Retention

We keep your data while your account is active. When you delete your account, we delete your personal data, except where we must retain limited records to comply with law.

8. Your rights

Subject to applicable law, you have the right to access, correct, delete, export, and object to or restrict processing of your data, and to lodge a complaint with your supervisory authority (in Poland, the UODO). You can export your wallets and diary as CSV from within the app, and delete your account to remove your data.

9. Cookies

We use strictly necessary cookies for authentication and sessions. We do not use advertising cookies. If that changes, we will ask for consent.

10. Changes

We may update this policy and will post the new version with an updated date.

See also our Terms of Use.