1. Data controller
The controller of your personal data is Finlyze (hereinafter, "Finlyze", "we"). You can contact us at hola@finlyze.es.
This policy is governed by Regulation (EU) 2016/679 (GDPR) and the Spanish Organic Law 3/2018 on Personal Data Protection and the safeguarding of digital rights (LOPDGDD).
2. Data we collect
- Account data: name, email address and hashed password used to authenticate you.
- Financial data you provide: portfolios, positions, transactions and rebalancing targets. You choose what to record; we never request these from third parties without your permission.
- Technical data: IP address, session identifier, browser and access logs, for service security and operation purposes.
3. Purpose and legal basis
We process your data to deliver the service (portfolio management, analytics and rebalancing), to keep your account secure and to comply with applicable legal obligations.
The main legal basis is the performance of the contract you accept when you sign up. For operational communications we rely on legitimate interest; for any commercial communications, we rely on your explicit consent.
4. Data retention
We retain your data while your account is active. After account deletion, the data is erased or anonymised within a reasonable timeframe, except for what we must retain due to legal obligations (for example, tax or security reasons).
5. Recipients
We do not sell your data. Some providers process it on our behalf for the sole purpose of providing the service to you (hosting, email delivery, monitoring). We work with processors bound by confidentiality and GDPR, preferably hosted within the European Union.
6. International transfers
If at any point we use providers located outside the European Economic Area, we will do so relying on safeguards recognised by the European Commission (standard contractual clauses, adequacy decisions or equivalent mechanisms).
7. Your rights
You can exercise at any time your rights of access, rectification, erasure, objection, restriction of processing and portability by writing to hola@finlyze.es. You also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
8. Cookies
Finlyze uses a technical session cookie that is strictly necessary to keep you authenticated. We do not use marketing or third-party cookies for advertising purposes.
9. Changes to this policy
We may update this policy to reflect legal or operational changes. We will always indicate the date of the last update at the top of the document.
This text is an indicative template and does not replace professional legal advice.