Privacy statement
This is a translation for your convenience. The Dutch version is legally binding.
Draft: this text is still to be reviewed by a lawyer.
In short: we process only what is needed to show you your own overview. Uploaded files are not kept, we measure nothing, set no cookies and do not trade in data.
1. Who is responsible
CrazyMedia (KvK 32100895) is responsible for processing your personal data through Kapitaaltrackr. You can reach us at info@kapitaaltrackr.nl.
2. Which data, what for and for how long
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account: name, e-mail address, hashed password, encrypted secret for two-step verification, linked sign-in service (if you use one) | Signing in and managing your account | Contract | Until you delete your account |
| Accounts, transactions, cash ledger (with the description from your export), dividends, savings movements, interest rates, owner per account, goals, preferences | Providing the service: calculating your overviews | Contract | Until you delete your account |
| Uploaded files | Importing | Contract | Not kept: processed in memory only during the request |
| IP address and browser per sign-in session | Showing your signed-in sessions and letting you end them; spotting misuse | Legitimate interest (security) | Until the session is ended; sessions unused for 60 days are removed at a later sign-in |
| IP address and e-mail address on a failed sign-in | Limiting sign-in attempts | Legitimate interest (security) | 15 minutes |
| The web server's technical log (IP address, time, page requested) and error reports | Fixing faults and protecting the service | Legitimate interest | Per the hosting company's policy; error reports until fixed |
| Share links you create yourself (only a fingerprint (hash) of the link, the expiry date and the number of views) | Sharing a read-only overview with whom you choose | Contract | Until you delete your account |
| E-mails you send us | Answering your question | Legitimate interest | As long as needed for your question, at most one year |
We measure nothing: there are no analytics, no trackers and no ads.
3. Who we share data with
- Hosting company (servers in the European Union): stores the database and the service's files. Which company this is and where exactly the servers are: (to be added)
- E-mail delivery: for an e-mail to reset your password. Which company this is: (to be added)
- Google Fonts: the site and the app load fonts from Google. Your browser connects to Google for this, so Google sees your IP address. Google is also outside the EU.
- Google and Microsoft if you choose to sign in with such an account yourself (not available yet).
- Price sources (Yahoo Finance, the European Central Bank, OpenFIGI and Meesman): the Kapitaaltrackr server requests prices with ISINs, ticker symbols and fund names. No personal data is sent, and the IP address they see is the server's, not yours.
We do not trade in data and do not pass it on to others, unless the law requires us to.
4. Outside the European Union
Google and Microsoft are American companies. Where your data reaches them (fonts, and signing in with their account if you choose to), this is based on the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.
5. Security
The connection is encrypted, passwords are hashed, two-step verification is available and sign-in attempts are limited. Each user sees only their own data. What we cannot promise is on Your data.
6. Your rights
You have the right to see your data, have it corrected, have it deleted and receive it in a common format, and to object to processing based on legitimate interest. Much of this you can do yourself in the app (changing data, deleting accounts, ending sessions). A button to download everything and to delete your account is still to come; until it is there, we handle it within one month of your request at info@kapitaaltrackr.nl.
If you disagree with how we handle your data, you can file a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens.
7. Changes
If this statement changes, it gets a new version number and date. We announce important changes in advance.