Privacy Policy

Last updated: 2026-11-01

Your privacy matters to us. This policy explains what we collect, why, and how it's protected.

1. Overview

This Privacy Policy explains what information Portfonia collects, how it is used, and the choices you have. It covers the Portfonia web application and the reports it emails you.

2. Information We Collect

Account information: your email address and authentication credentials, handled by our authentication provider.

Holdings and investment data: positions, brokers/custodians, and quantities you upload, plus any report preferences questionnaire responses you provide.

Usage information: basic session and activity data needed to operate the Service securely (for example, sign-in timestamps and idle-timeout enforcement).

Payment and credit information: purchases are processed by Paddle as Merchant of Record. Paddle collects your payment details and billing information under its own privacy notice; we receive transaction records such as order ID, amount, currency, country, and the email used at checkout, but never your full card number. We also keep a record of your credit balance and every credit added or used.

3. How We Use Your Information

We use your data solely to generate and deliver your portfolio reports and to operate, secure, and improve the Service. We do not sell your data, and we do not use your holdings to build or improve any third-party product.

We use payment and credit records to provide your plan, process refunds, and meet accounting and tax obligations.

4. Data Storage and Security

Your holdings are encrypted at rest with field-level encryption, and so is the data derived from them: report text and the inputs each report is built from, daily portfolio snapshots, parsed uploads, holding change history and report coverage notes. The encryption key is not stored in the database or in its backups. Access to production systems is restricted, administrative actions are logged, and our administrative tools do not display your holdings or reports.

No system is perfectly secure, and we cannot guarantee absolute security, but protecting your data is treated as a first-class engineering requirement, not an afterthought.

5. Third-Party Processing

Generating a report involves sending portions of your data to third-party large-language-model providers to compose the report text. By default, every such call is configured to opt out of the provider using your data for model training.

Payments are processed by Paddle, which acts as Merchant of Record and handles your payment information under its own privacy notice.

6. Data Retention

We retain your account and holdings data for as long as your account is active. Some operational records (for example, upload-job metadata) are automatically purged after a short retention window. You may request deletion of your account at any time (see "Your Rights" below).

When your account is deleted, your holdings, report preferences, reports, API tokens, waitlist entry and other personal data are removed. Credit and transaction records are kept for accounting and tax purposes, no longer linked to your email address except for a one-way fingerprint of it, used only to prevent the sign-up credit from being granted twice.

7. AI Agent access

If you create an API token, we store a one-way hash of it together with its name, its permission (read-only or holdings-write), and its creation, expiry and last-use times. Each request made with a token is logged with the time, the token used, the endpoint and dates requested, the result, and the IP address and User-Agent of the caller. We keep these logs for 90 days to protect your account and to detect misuse. Every successful Agent write request, including unchanged writes, may trigger a separate daily modification notice. Only POST creation uses an idempotency key, and a retry within 24 hours returns the original result; these results are encrypted, and request bodies and idempotency keys are not stored in the request audit. Data returned through the API is delivered to the agent you chose; how that agent stores or uses it is under your control. An Agent write or file upload that sharply reduces holdings rows or changes total value may trigger a separate alert email, at most one per Eastern Time date of the write.

Holding change history from web, file upload, Agent writes and rollbacks is stored encrypted for 30 days. You can view it on the web; your Agent can read it while Jade is active. Successful reads of current holdings, holding change history, snapshots and Jade risk results share at most one access notice per Eastern Time day.

8. Your Rights

You can review and update your holdings and profile information directly in the Service. You can delete your account yourself on your Profile page, or ask us to delete it by contacting us; deletion removes your holdings, report preferences, and authentication account as described in Data Retention.

9. Cookies and Sessions

We use session cookies to keep you signed in and to enforce automatic sign-out after a period of inactivity. We do not use third-party advertising or tracking cookies.

10. Children's Privacy

The Service is not directed to, and not knowingly used by, anyone under 18. We do not knowingly collect information from minors.

11. Applicable Law

We handle personal data in accordance with the data-protection laws that apply to us, including those of the country where you live where they apply.

12. Changes to This Policy

We may update this Privacy Policy as the Service evolves. Material changes will be reflected on this page with an updated effective date.

13. Contact

Questions about this Privacy Policy, or requests regarding your data, can be sent to info@portfonia.com.