Foliotron Privacy Policy

2a. Account data

What

Email address, first name, last name (optional), profile picture (optional), subscription tier. Your password itself is neither transmitted nor stored: your browser derives a login value from it, and only a bcrypt hash of that value is kept (irreversible). Foliotron additionally stores two encrypted copies of your personal data key, one locked with your password and one with your recovery code; see section 5.

Why

To create your account, authenticate you, and provide access to the application.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account. Erased within 30 days of account deletion.

2b. Portfolio data

What

Platforms (broker names, currencies, notes), positions (instrument names, ISIN codes, quantities, purchase prices, strategy labels, conviction level, notes), the investment case per instrument (core idea, assumptions, invalidation criteria, risks, catalysts, expected outcome, open questions, and per saved version an optional short note, the source of the change and the date; for a review also your verdict and note), transactions (purchases, sales, transfers in and out, dividends, fees, coupons, staking rewards, airdrops — with date, amount, currency, and optional notes), cash accounts (name, currency, optional account label, balances, transactions).

Why

To record, track, and analyse your investment portfolio. This is the core functionality of Foliotron.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account. Every saved version of the investment case, the note on an instrument, a portfolio's strategy and description and the note on a platform is kept, so you can read back and restore earlier versions; older versions are not deleted automatically. After account deletion, portfolio data, including all kept versions, is erased within 30 days.

Encryption. Quantities, prices, fees and amounts, cash movements and balances, the notes on a transaction, a cash movement or a platform, the investment case including every saved version, and a portfolio’s strategy and description are stored encrypted under your personal data key (section 5). What stays readable: the date and type of a transaction, which instrument and which platform it concerns, and the names of your portfolios, platforms and accounts. Foliotron can therefore see what you hold or have held and when you traded, not how much.

Importing transactions

When you import transactions from a broker or exchange file, that file is parsed in your browser and is never uploaded or stored. Only the resulting transactions are saved. To make a later import automatic, Foliotron remembers, per account, how a line in your file maps to an instrument (its ISIN, the product label as your broker names it, and the exchange code) and which import format that account uses.

If an import fails, you can optionally share your file with a support report. Only then is the file uploaded — the entire file, including any worksheets the import does not read. It is visible only to the administrator and deleted after at most 30 days (see 2p).

If Foliotron does not recognise the file format, you can map the columns yourself. You may then optionally share that column mapping to improve importing for other users. In that case only the column mapping and format settings (column headers and parsing hints) are submitted — never the data from your rows.

Connecting a crypto exchange

You can optionally connect a platform to a crypto exchange or platform (Kraken, Bitstamp, Bitfinex, Iconomi, eToro or Bitvavo) using a read-only API key that you create at that exchange yourself. That key and its secret are stored on the server encrypted under your personal data key (section 5), like your amounts; the server can only use them while you are using the app. Connecting verifies the key by making a read request to the exchange on your behalf; where the exchange makes this verifiable, a key that can withdraw funds or place orders is refused. You can disconnect at any time, which deletes the stored credentials immediately.

Foliotron uses that key to read your trade history, incoming and outgoing crypto transfers and balances from the exchange, and stores them as transactions in your portfolio — the same data you would otherwise enter manually or through a file. This happens on the server: when the app is opened and the last synchronisation is more than an hour old, and whenever you press sync yourself. Alongside the transactions, the exchange's original data is kept (trade id, market, amounts, fees, timestamp and, for on-chain transfers, the transaction hash and destination address) so that an import stays repeatable and auditable. The last balance read per coin is kept so differences with your portfolio can be shown. This is separate from the file import above, which continues to be parsed entirely in your browser.

2c. Research items and notes

What

Titles, freeform notes (text), links to external sources, tags, information about which user created or modified the item, archived items, favorite markings, and (on import) the original publication date of the source.

Why

To help you track and organise investment research.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account. Every saved version of a research note's text is kept, so you can read back and restore earlier versions; older versions are not deleted automatically. Erased within 30 days of account deletion, including all kept versions.

Encryption. The text of a research note and of a saved article is encrypted under your personal data key (section 5), including every saved version. The title, link, source, author, dates and tags stay readable: the title sits in the note’s URL. An article Foliotron fetches for you waits readable on the server until you first open the note; after that its text is encrypted too.

2d. Reminders and alerts

What

Reminder titles, notes, due dates, price alert thresholds, links to instruments or research items, per-reminder notification preferences (email and push).

Why

To notify you of relevant dates or price events.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account. Erased within 30 days of account deletion.

2e. Settings

What

Display currency, language and locale preference, notification preferences (push and email for dividends and earnings), default dividend tax rate.

Why

To personalise the application to your preferences.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account. Erased within 30 days of account deletion.

2f. Optional third-party integrations

What

Username and encrypted password, or API key and encrypted secret, for optional external integrations (such as Beleggers Belangen) — only if you choose to set them up. Credentials are encrypted using AES-256-GCM (256-bit key) under your personal data key (section 5), and can therefore only be opened while you are in the application yourself. Keys for exchange connections (including Iconomi) are covered by the exchange connection above.

Why

To retrieve data from the relevant external service on your behalf.

Legal basis

Consent (Art. 6(1)(a) GDPR). You grant consent by configuring the integration yourself. You can delete these credentials at any time via your account settings.

Retention

Until you delete the integration or close your account.

2g. Uploaded images

What

Image files you upload (e.g. screenshots), including file name, format, and SHA256 hash.

Why

To display images within your research notes.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR).

Retention

For the duration of your account, or until you delete the image.

Encryption. Uploaded images are not encrypted under your personal data key. A screenshot of a statement or a portfolio overview is therefore readable on the server, even when the note around it is not.

2h. Push notification subscriptions

What

Browser-generated endpoint URL and cryptographic keys for web push notifications, if you enable push notifications.

Why

To send push alerts for reminders and price events.

Legal basis

Consent (Art. 6(1)(a) GDPR). You grant consent by enabling push notifications in your browser. You can withdraw consent at any time via your browser or account settings.

Retention

Until you withdraw consent or delete your account.

2i. Login events and security logs

What

Timestamp of login attempts, success or failure, browser and device information (user agent), and failure reason. IP addresses are used temporarily for rate limiting (to prevent brute-force attacks) but are not stored permanently in the database.

Why

To monitor account security and detect and prevent abuse.

Legal basis

Legitimate interest (Art. 6(1)(f) GDPR). The interest is the security of the application and your account.

Retention

90 days, after which records are automatically deleted.

2j. Usage events (product analytics)

What

Records of general usage actions such as viewing the dashboard, viewing an instrument or research item, or creating a transaction or research item. No page URLs or detailed session data are stored.

Why

To understand how the application is used so Foliotron can be improved.

Legal basis

Legitimate interest (Art. 6(1)(f) GDPR). Data minimisation is applied: Foliotron records only broad usage actions and does not collect detailed click paths, heatmaps, or advertising profiles.

Retention

90 days, after which records are automatically deleted.

2k. Technical error logs

What

Server errors including API route, HTTP method, user ID, browser and device information, and error details. Additionally, errors during file imports: the error code and technical characteristics such as column headers, row count, file size and file type — never cell values or file names. Personal data is minimised in these logs.

Why

To identify and resolve technical issues.

Legal basis

Legitimate interest (Art. 6(1)(f) GDPR).

Retention

30 days.

2l. Transactional emails

What

Email address, name, language preference, and content of transactional messages such as account notifications, security alerts, reminders, price alerts, or system updates. In addition, delivery information is recorded per message sent (subject, delivery status and, on a failed delivery, the reason such as a bounce or block) to detect deliverability problems. This delivery information is linked to your account so deliverability problems can be traced per user. Emails are sent via Mailjet (EU). Tracking techniques are disabled per message: emails contain no tracking pixel and links are not rewritten — whether you open an email or click its links is not recorded.

Why

To send necessary or user-configured messages about your account and use of Foliotron, and to monitor their delivery.

Legal basis

Performance of a contract (Art. 6(1)(b) GDPR) for necessary account and service emails. Consent or user preferences for optional notifications. Recording delivery status relies on legitimate interest (Art. 6(1)(f) GDPR): monitoring the deliverability of sent emails.

Retention

For the duration of your account, or as long as needed for delivery, security, and error handling.

2m. AI integration (optional)

AI features are entirely optional and only active if you supply your own API key from a third-party provider (Anthropic, OpenAI, or Google). When AI features are enabled:

What

Instrument names, position sizes, tags, vision fields (strategy, conviction, horizon, portfolio role), notes, research items, transactions, dividends, and, if you have cash accounts enabled, cash positions (platform names, account labels, currencies, and current balances; this option is on by default for new accounts and can be switched off under Settings → AI) — as selected by your context permissions in Settings → AI.

Why

To answer questions and generate proposals in the portfolio chat. Data is sent only when you actively use the chat and only for the categories you have enabled.

Legal basis

Explicit consent (Art. 6(1)(a) GDPR). You provide consent by entering your API key and accepting the AI consent modal. Consent can be withdrawn at any time by disabling AI or deleting your API key in Settings → AI.

Retention

Foliotron does not log or store prompts or responses. Interaction metadata (provider, model, token counts, duration, success) is stored in AiInteractionLog for the lifetime of your account if the audit log is enabled. Conversation messages are stored only if you enable conversation retention, and only for the lifetime of your account.

Your API key is stored encrypted (AES-256-GCM) under your personal data key (section 5). Your AI documents and, if you enable conversation retention, the content of your conversation messages are encrypted the same way. To answer a question, Foliotron opens the data involved with your key at the moment of your request, and sends only the categories you enabled to the provider you chose. Foliotron never shares your API key with any party other than the AI provider you select. Switching provider clears your prior consent and requires a new acknowledgement before AI features re-enable.

AI web and financial news search (optional)

When the administrator has enabled web search, the AI assistant can perform searches via Brave Search and fetch public web pages. Search queries may contain instrument names or research topics. These queries are processed by Brave Search (Brave Software, Inc., United States). This only occurs when you explicitly ask the AI to search the web during a chat session. No directly identifying personal data such as your name or email address is included in search queries.

In addition, the AI assistant can fetch financial news and live quotes from Yahoo Finance to answer questions about market movements (for example "why is crypto up today?"). Requests may contain tickers, instrument names, or market topics, and are only sent when you ask a relevant question in the AI chat. No directly identifying personal data is included.

Voice input (dictation, optional)

When the voice input (dictation) feature is used, the browser captures a short audio recording and sends it to the Foliotron server. The server forwards it to OpenAI for transcription. The audio is processed entirely in memory and is never written to disk or stored in any database. OpenAI's data processing terms apply to this audio data.

Text extraction from images (optional)

When you explicitly run text extraction on an image, the Foliotron server sends that image to the AI provider you selected in Settings → AI (Anthropic, OpenAI, or Google) so the text in it can be read. This happens only on that explicit request and is covered by the same per-provider consent as the other AI features. The image is processed entirely in memory: for this feature Foliotron does not store the image separately, and the extracted text is not logged. An image you insert into a note is of course kept as an upload (see section 2g). The data processing terms of the selected provider apply to the transmitted image.

2n. Cookies and local storage

What

Session cookie (foliotron_session): contains a JWT with user ID and role (no email address). Local storage: UI preferences (including chart range, ‘hide amounts’, panel width, feedback-button visibility, the language chosen on the login page), per-instrument UI hints, local-cache timestamps, and temporary share state (cleared immediately after use). Session storage (cleared when you close the tab): the ongoing AI chat — your messages and the replies — and a few UI states. Local cache (IndexedDB): downloaded prices and exchange rates, and a local copy of your portfolio, transaction and balance data so pages load instantly; plus your user ID to keep the cache isolated per user.

Why

The session cookie is strictly necessary for authentication. Local storage retains functional preferences so the application behaves as expected. The local cache speeds up loading and is always re-fetchable from the server.

Legal basis

The session cookie is strictly necessary to provide the service. For functional local storage and cache, Foliotron relies on legitimate interest (Art. 6(1)(f) GDPR): remembering user preferences, speeding up the application, and keeping data isolated per user.

Retention

Session cookie: until 90 days after your last visit (every visit extends it), deleted on logout. Local storage and cache: until browser storage is cleared or the user deletes the data. Session storage: until you close the tab. Your account-specific cache (portfolio, transactions, balances) and your user ID are cleared on logout; they can also be cleared manually via Settings.

Foliotron does not place tracking cookies, advertising cookies, or third-party analytics cookies.

The website foliotron.com sets one functional cookie (foliotron_lang) that remembers the language you chose, and keeps your light or dark display choice in your browser's local storage. Both are functional and require no consent.

2o. Waitlist and invitation data

What

If you sign up for early access (or are invited manually): name, email address, language preference, the interests you select (such as testing, an interview, or staying informed), and optionally which tool you currently use to track your portfolio. For an invitation, the invitation status and an encrypted (hashed) invitation token with an expiry date are also stored. This signup does not create an account yet. In addition, an existing user can sign you up via the ‘invite a friend’ feature: in that case your name (optional) and email address are placed on the waitlist, together with a reference to the user who signed you up, and you receive a single email about this. If you do not want this, you can reply to that email and your details will be removed immediately.

Why

To manage interested testers, send early-access invitations, and follow up on signups.

Legal basis

Taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR), and legitimate interest (Art. 6(1)(f) GDPR) in managing beta access.

Retention

Until you create an account, or until the signup is declined or deleted. Signups that are not followed up are periodically purged.

The signup form on foliotron.com forwards what you enter straight to this waitlist in the application; the website itself keeps no copy.

2p. Feedback messages (beta testers)

What

When you submit a feedback message via the feedback button: the content of your message (free text, up to 5,000 characters), an optional screenshot of the page at the time of submission (stored as an image on the server), the page URL, the application route, your viewport dimensions, browser and device information (user agent), language setting, theme, app version, the coordinates of your click on the screenshot, and — where available — the component context at the clicked location. When this screenshot is captured, the ‘hide amounts’ feature is applied automatically so monetary amounts, portfolio values, and similar financial figures are not visible in the image. When reporting an import problem, you can additionally attach your import file; that file is then stored on the server in its entirety — including any worksheets the import does not read — and is visible only to the administrator. You can read back your own feedback messages and the administrator's replies under ‘My feedback’ and reply there yourself; those replies are stored with the message. When the administrator replies to your feedback or marks it done or closed, you receive an email about it at your account address; the reply text is included in that email. Optionally, you can include a summary of your local browser data when sending (off by default, ticked per message): counts and date ranges of the locally stored price, exchange-rate and transaction data, the identifiers of the instruments the page is showing, your time zone, screen density and the version of the local storage. Amounts, prices, exchange rates and transaction rows are never sent.

Why

To receive, prioritise, and act on bug reports, UX issues, and feature requests from beta testers, and to let you know what happened with them.

Legal basis

Legitimate interest (Art. 6(1)(f) GDPR): improving the application based on active user feedback. You submit feedback entirely at your own initiative. The feedback feature is enabled for all users and can be disabled per account by the administrator.

Retention

Feedback messages and associated screenshots are retained for the duration of your account or until they are no longer needed for product development. Screenshots are deleted when your account is deleted. Attached import files are automatically deleted after at most 30 days, and immediately when your account is deleted. An included local data summary is kept together with the feedback message.

2q. Connected external apps (MCP connections)

What

When you connect an external app to your account (for example an AI assistant): the name the app states for itself, the address it sends you back to, the permissions you approve, your setting per kind of data of what a connected app may read and write, and the access keys issued as a result. Keys are stored only as a hash, never in readable form. While the connection is active the app can request your portfolio data — value and price moves, positions, strategy/goals document, benchmark, transactions, dividends, cash accounts, per-instrument notes and reviews, research notes, watchlist, upcoming events, and reminders — and, only where you switch it on per kind of data under Settings → AI, write as well: your investment case and a review on it, a research note, the note on an instrument, a portfolio's strategy document, and create, snooze or complete a reminder. Writing is off by default. Every change made by an app is kept as a new version, with the app as its source, next to the versions you save yourself (section 2), and you can restore an earlier version. A day allows at most 100 changes and 20 emails; that count keeps only a number per day, no content, and expires after two days. The app can also, if you approve that permission, email you at your own account address. The app cannot delete anything, cannot add or change transactions, and cannot email anyone else. Foliotron does not record which data the app requests or what it does with it; what the app does with your data afterwards is governed by that provider's own privacy policy.

Why

To let you use your own data in an external app of your choosing, and to let you withdraw that access.

Legal basis

Consent (Art. 6(1)(a) GDPR): a connection is only established after you explicitly approve it on the consent screen, with each permission named. What an app may read and write you set per kind of data under Settings → AI as well; the consent screen shows that setting at that moment. You can withdraw the connection.

Retention

Access keys expire after one hour, refresh keys after at most 90 days of disuse. Revoked or expired keys are deleted after 30 days; registrations for apps that were never connected after 30 days of disuse.

Encryption. A connected app does not hold your data key and therefore cannot read the encrypted fields, not even while you are in the application yourself; if the app asks for them, it gets them back marked as encrypted. What stays readable to the app is what stays readable per section 2: which instruments you traded and when, names, dates and reminders. If you want the app to read your amounts and texts too, you can have a server copy of your data key kept; see section 5. That option is off by default.