EasyPortfolio ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by EasyPortfolio when you use our website and services (collectively, the "Service").

By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

1. Information We Collect

Personal Information: When you create an account, we collect your name, email address, and password. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

Financial Data: When you add portfolio holdings, we collect transaction data, quantities, prices, and other financial information necessary to provide our services. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

Usage Data: When you consent, we collect information about how you interact with our services, including browser type, pages viewed, and time spent on the service. Legal basis: consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time in your account settings.

Cookies and Similar Technologies: We use cookies and similar tracking technologies as described in our Cookie Policy. Non-essential cookies are only set after you give explicit consent via our cookie banner. Legal basis: consent (Art. 6(1)(a) GDPR).

2. Cookies and Advertising

Our Use of Cookies: We use various types of cookies to enhance your experience on our website:

• Necessary Cookies: Essential for website functionality and cannot be disabled
• Analytical Cookies: Help us understand how visitors interact with our website
• Functional Cookies: Enable enhanced functionality and personalization
• Advertising Cookies: Used to deliver personalized advertisements

Third-Party Advertising: We participate in advertising programs that may use cookies to serve ads:

• Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to our website or other websites.
• Google's use of advertising cookies enables it and its partners to serve ads to our users based on their visit to our sites and/or other sites on the Internet.
• Users may opt out of personalized advertising by visiting Google Ads Settings.
• Alternatively, you can opt out of a third-party vendor's use of cookies for personalized advertising by visiting www.aboutads.info.

Cookie Consent: When you first visit our website, you will be presented with a cookie consent banner. You can manage your cookie preferences at any time by clicking the cookie settings in our footer or visiting our Cookie Policy page.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Process and complete transactions
• Send you technical notices, updates, and support messages
• Respond to your comments, questions, and requests
• Monitor and analyze trends, usage, and activities in connection with our services
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Personalize the services we provide to you

4. How We Share Your Information

Service Providers: We may share your information with third-party vendors, consultants, and other service providers who need access to your information to perform services on our behalf.

Financial Institutions: We may share your information with the financial institutions you choose to connect with through our service, to the extent necessary to provide our services.

Compliance with Laws: We may disclose your information where required by law or if we believe disclosure is necessary to comply with a legal obligation.

Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

5. Data Retention

We retain different categories of data for different periods, based on necessity and legal requirements:

• Account & Profile Data: Retained for as long as your account is active. Deleted within 30 days of account closure.
• Financial Data (holdings, transactions, dividends): Retained for as long as your account is active and deleted when you delete your account.
• Blog Analytics & Usage Data: Automatically purged after 90 days (configurable). IP addresses and user agent data are included in this purge cycle.
• Consent Records: Retained for 5 years after the consent action as required by GDPR Art. 7(1) to demonstrate that valid consent was obtained.
• Payment Records: Retained for the period required by applicable tax and accounting legislation (typically 7 years).

You may request deletion of your data at any time via your account settings or by contacting us.

6. Data Security

We implement appropriate technical and organizational measures to protect the security of your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

7. Your Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation. EasyPortfolio aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

You have the following data protection rights:

• Right of Access (Art. 15): You can download a copy of all your personal data from your account settings (Data & Privacy tab).
• Right to Rectification (Art. 16): You can update your information at any time in your profile and account settings.
• Right to Erasure (Art. 17): You can permanently delete your account and all associated data from your account settings.
• Right to Restrict Processing (Art. 18): You can disable usage data collection and cookies in your privacy settings.
• Right to Data Portability (Art. 20): You can export your data in CSV, Excel, or JSON format from your account settings.
• Right to Object (Art. 21): You can object to our processing of your personal data by contacting us.
• Right to Withdraw Consent (Art. 7(3)): Where we rely on consent, you may withdraw it at any time in your privacy settings. Withdrawal does not affect the lawfulness of prior processing.

To exercise any of these rights, use the controls in your account settings or contact us at [email protected]. We will respond within 30 days.

8. International Data Transfers

Your data is primarily stored and processed within the European Union (Microsoft Azure, West Europe region). Some third-party services we use may process data outside the EEA:

• Google (OAuth, AdSense): United States — covered by the EU-US Data Privacy Framework.
• Whop (payment processing): United States — data shared under Standard Contractual Clauses (SCCs).
• Yahoo Finance / CoinGecko (market data APIs): We send only public security identifiers (stock tickers, ISINs); no personal data is transmitted.

We ensure that any cross-border transfer is protected by appropriate safeguards as required by GDPR Chapter V.

9. Children's Privacy

Our Service is not directed to children under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at [email protected].

Our Data Protection Officer (DPO) can be reached at [email protected].

If you believe your data protection rights have not been adequately addressed, you have the right to lodge a complaint with your local supervisory authority.