Privacy Policy

1. Introduction

Finvygo is a free wealth tracking app. This policy explains what data we process, where it is hosted, who can access it, and how to retrieve or delete it. It applies to the mobile app and the website alike.

2. No connection to your accounts

Finvygo is declarative: you enter your assets yourself. The app never connects to a bank, a broker or an exchange. We use no banking aggregator and never ask for your bank, broker or exchange credentials. We therefore have no access to your accounts, neither read nor write, and no transaction statement passes through our servers.

3. Data we collect

What we hold depends on the sign-in method you choose:

• Private key sign-in: no personal data at all, no name and no email address. We keep only a cryptographic fingerprint of your key, never the key itself.
• Email sign-in: your email address, used only to find your account and send you your sign-in codes.
• Google or Apple sign-in: the account identifier passed on by the provider and the associated email address.
• In every case: what you enter (assets, quantities, purchase prices) and your preferences (language, currency, tax residency, time zone).
• Audience and performance measurement, without cookies: page viewed, referrer, device type, browser and country. Our provider derives a technical fingerprint from the request, renewed every 24 hours, which can neither identify you nor follow you from one site to another.

4. How we use your data

Your data is used solely to run the service:

• Calculate, revalue and display your net worth
• Adapt the product catalogue to your country of tax residence
• Send you your sign-in codes and service notifications
• Diagnose failures and improve the app

5. The legal basis for all this

The General Data Protection Regulation requires us to justify every processing operation. Here are ours:

• Performance of our contract with you: creating your account, storing your assets, revaluing your net worth and sending you your sign-in codes. Without this data the service cannot work.
• Legitimate interest: diagnosing failures, protecting the service against abuse, and measuring audience in aggregate. You can object to this at any time.
• Legal obligation: keeping accounting records if you make a donation.

6. Where your data is hosted

All your data is hosted in the European Union. Our database and application server run in Amsterdam, in the Netherlands. The website is rendered from Paris, in France. None of your wealth data is stored outside the European Union.

7. Transfers outside the European Union

Your data is stored in the European Union, but some of our providers are companies established outside it, mainly in the United States. Where a transfer takes place on that basis, it is governed by the standard contractual clauses adopted by the European Commission, which bind the recipient to a level of protection equivalent to the GDPR. We transfer your data to no country outside that framework.

8. Encryption and security

Your data travels over HTTPS only and is encrypted at rest by our host. Your private key is never stored on our servers: we keep only a cryptographic fingerprint, from which the key cannot be derived. On mobile, the app locks with a PIN or biometrics, and amounts can be hidden with a single gesture. In the interest of transparency: we do not use end to end encryption. Our servers can read your data, and that is precisely what lets them revalue your holdings every day.

9. Who can access it

Nobody browses your portfolio. Technical access to the production database is limited to operating and troubleshooting needs, and restricted to the people responsible for them. Our internal back office is designed never to display an identity: it shows no name, no email address and no account identifier, not even to our own team.

10. Sharing your data

We never sell your data and never use it for advertising. We rely on a small number of providers, each for a specific purpose:

• Railway, a US company: hosting for the application and the database, on servers located in Amsterdam
• Vercel, a US company: hosting for the website, rendered from Paris, and cookieless audience measurement
• Sentry, on its European region in Germany: technical error reports, stripped of any identity before they are sent
• Resend: delivery of your sign-in codes and service emails
• Google and Apple: only if you choose their sign-in button
• Stripe: processing donations, if you choose to make one
• Our market data providers, which receive only the identifier of the assets to be valued, never your quantities, your amounts or your identity
• The competent authorities, where the law requires it
• The external applications you connect yourself: your wealth data is shared with them at your request, and then falls under their publisher's responsibility. You can withdraw this access at any time from your settings.

11. Your rights (GDPR)

The General Data Protection Regulation grants you the following rights, which you can exercise at any time by writing to us:

• Right of access to your data
• Right to rectification
• Right to erasure (the right to be forgotten)
• Right to restriction of processing
• Right to portability: we send you all of your data on request
• Right to object to processing
• Right not to be subject to a solely automated decision: we make none and carry out no profiling
• Right to lodge a complaint with the data protection authority of your place of residence

12. Cookies

The website uses only technical cookies, needed for your session and your preferences. No advertising cookies, no third party trackers, no profiling. Our audience measurement works without cookies. Since none of our processing relies on your consent, we have no cookie banner to show you.

13. Retention and deletion

Your data is kept for as long as your account exists. Deletion is immediate and final: deleting your account from the app erases your profile, your assets and your history straight away, with no retention period. Our technical backups, encrypted at rest, expire on their own after six days, which is when every trace has genuinely gone. All that remains afterwards is an anonymous statistical record, with no identifier and no link to your account: sign-in method, country, account age, platform used, reason for leaving and whether or not you had added an asset. That record cannot lead back to you and has no limited retention period. If you leave a free text comment on your way out, it is kept exactly as you wrote it.

14. Changes to this policy

We may update this policy, for instance if we change provider or add a feature. The date of the last update appears at the top of this page. If something important changes in the way we handle your data, we will tell you in the app before it takes effect.

15. Contact

The controller of your data is Exocore Group, a French simplified joint-stock company whose registered office is at 200 rue de la Croix Nivert, 75015 Paris, France. To exercise your rights or for any question about this policy: contact@finvygo.com. Our full details appear in our legal notice.