Privacy Policy

1. Introduction

Welcome to PieFolio AI ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and mobile application (collectively, the "Services") for portfolio tracking and AI-assisted analysis, in compliance with the General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws.

2. Data Controller

PieFolio AI is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or our data practices, please contact us at contact@getpiefolio.com.

3. Legal Basis for Processing Data

Under GDPR / UK GDPR, we process your data based on the following legal grounds:

• Consent: When you create an account, opt in to marketing emails, accept cookies, or generate an AI report, you provide explicit consent for the related processing.
• Contractual Necessity: Processing required to provide the Services you have requested (e.g., portfolio tracking, Portfolio Health score, AI-written analysis, dividend calendar).
• Legitimate Interest: Improving app functionality, user experience, security monitoring, fraud prevention, and aggregate analytics.
• Legal Obligation: When we are required by law to process or retain your data.

4. Information We Collect

4.1 Information You Provide

• Account Information: Email address (and optional display name) when you create an account.
• Portfolio Information: Holdings, tickers, quantities, cost basis, and the portfolios you create. This is information you manually enter; we do not connect to your broker or pull positions automatically.
• Preferences: Settings such as base currency, language, theme, favorites, and notification preferences.
• Communication Data: Messages, feedback, ratings on AI reports, and support requests you send to us.
• Subscription & Purchase Metadata: If you purchase Premium Monthly, Premium Annual, or the one-time Founding Lifetime purchase, we receive purchase metadata from Apple or Google through RevenueCat, Inc., which manages in-app purchase and subscription status. This includes a transaction identifier, original purchase date, purchase option (monthly / annual / one-time Founding Lifetime), renewal and expiry timestamps where applicable, store country, and a receipt token used to validate your Premium access. We do not receive your card number, CVV, full billing address, or Apple ID / Google account password — those remain with Apple and Google. See our Subscription Terms and RevenueCat's Privacy Policy.

4.2 Information Collected Automatically

• Device Information: Device type, operating system, app version, locale, and (mobile only) anonymised device identifiers.
• Usage Data: Screens visited, features used, session duration, and high-level navigation patterns.
• Log Data: IP address, user-agent, referring/exit pages, and timestamps for security and abuse prevention.
• Analytics Data: Aggregated, privacy-respecting analytics to help us understand which features matter to users.

4.3 Mobile Application Permissions

The PieFolio AI mobile app requires only standard internet permission to function. We do not request or access your camera, contacts, location, microphone, photos, or device storage.

4.4 Information We Do Not Collect

• Brokerage credentials or login details.
• Bank account or card numbers — Premium subscription and Founding Lifetime payments are processed exclusively by Apple and Google, who do not share payment-instrument details with us.
• Government-issued identifiers (passport, SSN, national ID).

5. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services across web and mobile platforms
• Calculate your Portfolio Health score, risk band, and diversification metrics
• Generate AI-written portfolio analysis on demand and surface upcoming dividend payouts
• Send you transactional emails (e.g., account verification, security alerts) and, with your consent, product updates
• Respond to your inquiries and provide customer support
• Protect against fraudulent or unauthorised activity
• Analyse aggregated usage patterns to improve user experience
• Comply with legal obligations

6. AI-Generated Analysis

A core part of PieFolio AI is on-demand portfolio analysis written by large language models. When you tap Generate, we send the necessary information to third-party AI providers so they can produce your report. Specifically:

• What we send: Your portfolio composition (tickers, weights, sector/asset mix, currency), derived metrics (e.g., Health score, risk band, diversification), and the report instructions. We do not send your name, email, account ID, payment information, IP address, or any contact details.
• Who processes it: Reputable third-party AI providers operating under enterprise agreements with us. These providers act as data sub-processors and are contractually prohibited from training their public models on the data we send.
• Where it runs: Processing may take place in the EEA, the United Kingdom, or other jurisdictions with appropriate safeguards (Standard Contractual Clauses or equivalent adequacy mechanisms).
• Retention: Generated reports are cached on our servers for around 12 hours so the same snapshot is not regenerated repeatedly. You can request a fresh report at any time, and you can delete reports from the app.
• Your control: AI analysis runs only when you actively trigger it. You can use PieFolio AI without ever generating a report.
• Provider list: We may change AI sub-processors as the technology landscape evolves. The current list of sub-processors is available on request at contact@getpiefolio.com.

AI-generated content is informational and may contain inaccuracies. It is not financial, investment, legal, or tax advice. Always do your own research and consult a qualified professional before making investment decisions.

7. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

• Service Providers (sub-processors): Trusted third-party companies that assist in operating our Services (cloud hosting, authentication, analytics, email delivery, AI providers, market-data providers). They are contractually obligated to protect your information and process it only on our instructions.
• Legal Requirements: When required by law, court order, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with prior notice to you.
• With Your Consent: When you have given explicit permission for a specific purpose.

8. Third-Party Services

We integrate with the following types of third-party services:

• Cloud Hosting & Database: For secure data storage and authentication.
• AI Providers: Third-party large-language-model providers that generate your portfolio analysis on demand (see Section 6).
• Market Data Providers: To display prices, dividend dates, fundamentals, and ticker metadata.
• App Store Billing (Apple App Store and Google Play): Process Premium Monthly, Premium Annual, and one-time Founding Lifetime payments.
• RevenueCat (RevenueCat, Inc.): Manages in-app purchase and subscription status, including Premium access and receipt validation, alongside Apple and Google. See RevenueCat's Privacy Policy.
• Analytics: To understand how users interact with our Services and improve the experience.
• Email Services: To send transactional and (with your consent) marketing communications.
• Crash & Error Monitoring: To detect bugs and improve stability.

These third parties process data in accordance with their own privacy policies and operate under GDPR- compliant or otherwise adequate data protection frameworks.

9. Data Security

We implement appropriate technical and organisational security measures to protect your personal information, including encryption in transit (TLS) and at rest, role-based access controls, secret rotation, and continuous monitoring. However, no method of transmission over the Internet or electronic storage is 100% secure. We continuously review and improve our security practices.

10. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required by law. When your data is no longer needed, we securely delete or anonymise it. Specifically:

• Account & Portfolio Data: Retained for the duration of your account and deleted within 30 days of account closure.
• AI Reports: Cached for around 12 hours unless you save them; deleted with your account.
• Subscription & Purchase Records: Retained while needed to validate your Premium subscription or Founding Lifetime access, and afterwards for as long as required by applicable tax, accounting, and consumer-protection law.
• Marketing Subscriptions: Retained until you unsubscribe or request deletion.
• Analytics Data: Anonymised usage data may be retained for up to 24 months for trend analysis.
• Logs: Security and access logs are kept for up to 90 days.

11. Your Rights

If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data ("right to be forgotten"). You can also delete your account directly from the app. See How to delete your account.
• Right to Restrict Processing: Request that we limit how we use your data.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
• Rights Related to Automated Decisions: AI analysis is not used to make automated decisions that produce legal or similarly significant effects on you.

To exercise any of these rights, contact us at contact@getpiefolio.com. We will respond within 30 days.

12. Consent and Opt-Out

You can manage your data preferences through:

• Cookie Settings: Manage cookie preferences via our Cookie Policy or your browser settings.
• Marketing Emails: Unsubscribe via the link in any marketing email.
• Mobile App: Adjust analytics tracking and notifications in your device settings or in the app's Settings screen.
• Account Deletion: Delete your account in the app's Settings, or contact us to request full deletion. Step-by-step instructions are on our Delete Account page.

13. Cookies and Tracking

Our website uses cookies and similar tracking technologies. Essential cookies are required for the website to function properly, while optional cookies help us analyse traffic and improve the experience. The mobile app does not use browser cookies. You can control your cookie preferences at any time. For detailed information, please see our Cookie Policy.

14. Children's Privacy

Our Services are not intended for children under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 16 without parental consent, we will take steps to delete that information promptly.

15. International Data Transfers

Your data may be processed in countries outside the EEA or UK, including (but not limited to) the United States, where some of our cloud hosting and AI providers operate. When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or adequacy decisions recognised by the European Commission and other applicable regulators.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page, updating the "Last updated" date, and where appropriate, notifying you via email or in-app notification. We encourage you to review this policy periodically.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: contact@getpiefolio.com
• Website: getpiefolio.com

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.