Privacy Policy
Last updated: [DD Month YYYY]
This Privacy Policy explains how [Company Legal Name]("PortfoliAI", "we", "us") collects, uses, discloses, and safeguards information when you use our website and application (the "Service"). This is a draft template — the bracketed placeholders must be completed and the whole document reviewed by qualified legal counsel before publication.
1. Who we are
PortfoliAI is operated by [Company Legal Name], registered at [Registered Address]. For any question about this policy or your data, contact us at [privacy@portfoliai.example].
2. Data we collect
We collect the following categories of data:
- Account data — name, email address, and profile picture provided via Google Sign-In, plus your declared role (Private Investor / Financial Advisor).
- Financial data you upload — transaction history (dates, tickers/ISINs, quantities, prices, fees, brokers) imported from CSV/Excel broker exports, or entered manually.
- Generated reports — the PDF analyses produced from your transaction data, and metadata about them (status, tags, timestamps).
- Usage data — log data, device/browser information, and interactions with the Service, collected automatically.
3. How we use your data
- To generate the portfolio analyses and PDF reports you request.
- To operate, maintain, and secure your account and the Service.
- To send service-related notifications (e.g. report completed/failed), subject to your notification preferences.
- To comply with legal obligations and enforce our Terms of Service.
We do not sell your personal or financial data to third parties.
4. Legal basis for processing (GDPR)
Where the General Data Protection Regulation (GDPR) applies, we process your data on the basis of: performance of a contract (providing the Service you signed up for), your consent (e.g. optional marketing communications), and our legitimate interest in maintaining and improving the Service.
5. Financial Advisors acting on behalf of clients
If you use PortfoliAI as a Financial Advisor to generate reports for your clients, you act as the data controller for your clients' data, and you are responsible for obtaining any necessary consents from your clients before uploading their transaction data. PortfoliAI acts as a data processor in that context.
6. Data sharing
We share data only with service providers strictly necessary to operate PortfoliAI (e.g. cloud hosting, market data providers, email delivery), each bound by appropriate data processing agreements. We do not share your data with third parties for their own marketing purposes.
7. Data retention
We retain account and financial data for as long as your account is active, and for a limited period afterwards as required to comply with legal, accounting, or reporting obligations. You may request deletion at any time (see Section 8).
8. Your rights
Subject to applicable law, you have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Request deletion of your data ("right to be forgotten").
- Export your data in a portable format.
- Object to or restrict certain processing.
To exercise these rights, contact us at [privacy@portfoliai.example].
9. Security
We use industry-standard technical and organizational measures — including encryption in transit, access controls, and short-lived signed URLs for document downloads — to protect your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Cookies
The Service uses only strictly necessary cookies/local storage required for authentication. If we introduce analytics or marketing cookies in the future, we will update this policy and request consent where required.
11. International data transfers
Where data is transferred outside your country of residence, we rely on appropriate safeguards (such as Standard Contractual Clauses) as required by applicable law.
12. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be notified via the Service or by email before they take effect.
13. Contact
Questions about this Privacy Policy can be sent to [privacy@portfoliai.example].