Privacy Policy

1. Who we are (Controller)

The controller responsible for the processing of personal data is:

2. What the App does

Portfolium is a financial portfolio tracking application. It allows users to:

• View real-time and historical market data for stocks, ETFs, and other financial instruments
• Create and manage a personal investment portfolio by entering holdings and transactions
• Track the current value and performance of their portfolio over time

3. Personal data we process

We process only the data necessary to provide the App's functionality:

• Account data – e-mail address and password (stored in hashed form; we never store plain-text passwords); display name if provided
• Portfolio data – financial instruments added by the user (ticker symbols, quantities, purchase prices, transaction dates, notes)
• Device and usage data – device type, operating system version, unique device identifiers, session timestamps, features accessed, crash logs

We do not process sensitive categories of personal data (e.g., health data, biometric data). We do not process actual bank account numbers or brokerage credentials.

4. How we use personal data

We use personal data solely for the following purposes:

• App functionality: user authentication and account management; storing and displaying the user's portfolio; calculating performance metrics
• Security and integrity: preventing unauthorised access, detecting abuse, troubleshooting issues
• Service improvement: analysing aggregated, anonymised usage patterns to improve features and performance
• Communications: sending service-related notifications (e.g., policy changes, critical technical notices) to registered users

We do not use personal data for advertising, profiling, or marketing to third parties.

5. Legal basis (GDPR)

Where applicable under data protection law, we process personal data on the following legal bases:

• Performance of a contract – processing necessary to provide the App to you (account management, portfolio storage)
• Legitimate interests – operating the App securely, preventing fraud, improving the service
• Consent – where we ask for your explicit consent for optional features (e.g., push notifications); you may withdraw consent at any time

6. Data sharing

We do not sell personal data. We may share data only in the following cases:

• Service providers: third-party providers that support the App's infrastructure (e.g., cloud hosting, crash reporting), bound by appropriate data processing agreements
• Financial data providers: the App retrieves market data from third-party financial data services (e.g., Yahoo Finance, Alpha Vantage or equivalent). We do not share your personal data with these providers; they supply public market data to the App
• Legal obligations: if required by law, court order, or competent authority
• Business transfer: in the event of a merger or acquisition; users will be notified in advance

7. International transfers

We aim to process data within the European Economic Area (EEA). Where any service provider is located outside the EEA, transfers are carried out with appropriate safeguards in accordance with GDPR (e.g., Standard Contractual Clauses or an adequacy decision).

8. Data retention

We retain personal data only for as long as necessary:

• Account and portfolio data: for the duration of the active account and, where required, for a period thereafter to meet legal obligations
• Crash logs and diagnostic data: up to 12 months from collection
• Anonymised, aggregated analytics data: indefinitely (no personal data retained)

You may request deletion of your account and associated data at any time (see Section 10).

9. Security

We implement technical and organisational security measures appropriate to the risk, including:

• Encryption in transit (HTTPS/TLS)
• Hashed password storage (passwords are never stored in plain text)
• Access controls and authentication
• Security event logging and monitoring

No system is entirely secure. We encourage users to use a strong, unique password and to keep their credentials confidential.

10. Your rights

Under the GDPR (and applicable national law), you have the following rights regarding your personal data:

To exercise any of these rights, contact us at portfolium@pretoki.com. We will respond within 30 days. We may need to verify your identity before processing the request.

You also have the right to lodge a complaint with the competent supervisory authority. In the Republic of Croatia, the supervisory authority is:

11. Children's privacy

Portfolium is not intended for children under the age of 13 (or under the applicable minimum age in the user's jurisdiction). We do not knowingly collect personal data from children. If we become aware that a child has provided personal data, we will delete it promptly. If you believe a child has submitted data, please contact us at portfolium@pretoki.com.

12. Tracking technologies

The App does not use cookies. It may use similar technologies such as device identifiers and SDK-based crash reporting for core functionality, security, and diagnostics. The App does not display advertisements and does not use advertising or cross-app tracking SDKs.

13. Changes to this policy

We may update this Privacy Policy from time to time. If significant changes are made, we will notify users via the App or by e-mail (if a registered account exists). The "Last updated" date at the top of this document will always reflect the most recent revision. We recommend reviewing this page periodically.

14. Contact

For any questions about this Privacy Policy or to exercise your data rights, contact us: