Privacy Policy

Invest Tracker is built privacy-first. You can use the core features without an account, and your DEGIRO CSV is processed in your browser. This policy explains what we do and do not process, why, how long we keep it, and the rights you have under the GDPR (AVG).

Last updated: September 2026

1. Who is responsible

Invest Tracker ("we", "us") is the data controller for the limited personal data described below. Invest Tracker is an independent project and is not affiliated with DEGIRO. You can reach us via the contact page.

2. Using Invest Tracker without an account

You can upload your DEGIRO CSV and see your holdings, profit and loss, dividends, allocation and performance without creating an account. In this mode your CSV is processed in your browser to build your dashboard and is not stored on our servers, and no personally identifiable information is saved.

3. What we process when you create an account

Creating an account is optional and unlocks saving your portfolio, notes, manual transactions and the AI assistant. If you choose to create one, we process:

• Username - to identify your account.
• Email address - used solely for account verification and password recovery.
• Password - never stored in plain text; only a securely hashed version is kept.
• Portfolio data you choose to save - your holdings, transactions and notes, so you do not have to re-upload your CSV each time.

4. Why we process it (legal basis)

• Performance of a service you request (Art. 6(1)(b) GDPR): creating and maintaining your account and saving your portfolio.
• Legitimate interests (Art. 6(1)(f) GDPR): keeping the service secure, preventing abuse (rate limiting), and improving the product through aggregated, non-identifying usage metrics.

5. AI portfolio analysis

The AI assistant is optional and requires a free account. When you ask the AI a question, the relevant portfolio figures and your question are sent to our AI provider, Google (Gemini API), to generate a response. Do not include information you would not want processed by a third party. AI answers are for information and education only and are not financial advice.

6. Third parties we rely on

We keep third parties to a minimum. We do not sell or rent your personal data to anyone. The services we use are:

• Yahoo Finance - to retrieve stock prices, exchange rates and dividend history. Security identifiers (e.g. tickers/ISINs) are sent to fetch prices; your identity is not.
• Google (Gemini API) - only when you use the optional AI assistant (see section 5).
• Email delivery (SMTP) - to send verification, password-reset and bug-report emails.
• Ko-fi - an optional embedded "Support me" donation widget. If you open it, Ko-fi may set its own cookies; it is only loaded when you interact with it.
• flagcdn.com - serves the small country-flag icons used by the language switcher.

7. Cookies and analytics

We use a strictly necessary session mechanism to keep you logged in when you have an account. We do not use advertising or cross-site tracking cookies. We record anonymous, aggregated interaction metrics (for example, how often a feature is used) to understand and improve the product; these metrics are not used to identify you.

8. How long we keep your data

We keep your account data for as long as your account exists. Email verification and password-reset codes expire shortly after they are issued. When you delete your account, your personal data and saved portfolio are removed. Aggregated, non-identifying usage metrics may be retained.

9. Where your data is stored

Your account data is stored securely within the European Union.

10. Your rights under the GDPR (AVG)

You have the right to access, rectify, or erase your personal data, to restrict or object to processing, and to data portability. You can delete your account and all associated data at any time, or contact us to exercise any of these rights. You also have the right to lodge a complaint with your national data protection authority.

11. Children

Invest Tracker is not directed at children and is intended for users who are old enough to hold a brokerage account.

12. Changes to this policy

We may update this policy from time to time. Material changes will be reflected by the "last updated" date above.

13. Contact

Questions about your privacy or this policy? Reach us via the contact page. See also our Terms & Conditions.