Privacy notice
Template — to be completed by the operator and reviewed by a lawyer before the service opens. It describes what the software keeps and the Swiss hosting set out in `deploy/README.md`; text in [brackets] is for the operator. Version 2026-11-03. Written for the Swiss Federal Act on Data Protection (FADP, art. 19–21 duty to inform) and Hong Kong's Personal Data (Privacy) Ordinance (PDPO, Data Protection Principles 1 and 5: collection statement and policy statement).
Who is responsible. [Company name] Limited, a company incorporated in Hong Kong ([registered office address]; Business Registration No. [number]), is responsible for the personal data described here: the data user under Hong Kong's PDPO, and the controller under the Swiss FADP for the people it serves in Switzerland. Contact for anything about your data: [privacy e-mail]. [Only if a lawyer finds it required (FADP art. 14): our representative in Switzerland, name and address.]
What we keep, and why
| Data | Why | Needed? | Kept |
|---|---|---|---|
| User name, e-mail address (kept encrypted), password (only as a scrypt hash) | to open and protect your account, confirm your address, reset your password | yes — without them we cannot open an account | while the account exists |
| The terms and privacy notice you accepted, and when | to show what you agreed to | yes | while the account exists |
| Your plan, payments and invoices | to provide your plan and bill it | yes, for a paid plan | invoices and payments: 10 years (Swiss accounting law, art. 958f CO); the rest while the account exists |
| How often you used limited features | to apply your plan's limits | yes | daily counts: 30 days |
| Your settings, interests, favourites, watchlists, followed companies, alert terms, dashboards, charts, conversations with "Ask", notifications, reading history | to provide the service as you set it up | no — you choose what to add | until you delete them or the account |
| Signed-in devices: browser family, network (shortened), times | to keep your account secure and let you sign out elsewhere | yes | 30 days after the session ends |
| Security activity: sign-ins, refused sign-ins, changes to your sign-in, actions of our support on your account | to detect misuse and show you what happened | yes | one year |
| Messages you send us, and notes our support team writes about them | to answer you | no | while the account exists |
If you do not give the data marked "yes", we cannot open or keep your account. We do not sell your data, show advertising, build profiles or make automated decisions about you. We do not use your data for direct marketing; we would ask for your consent first (PDPO Part 6A). The library of official records is the same for everyone.
Who receives it (the classes of recipients — PDPO DPP1, FADP art. 19)
| Recipient | What | Where |
|---|---|---|
| Our hosting provider [Exoscale (Akenes SA) / Infomaniak Network SA] — the server and the encrypted backup | everything above, on our behalf only | Switzerland ([Geneva / Zurich]) |
| Our mail provider [name] | your e-mail address and the messages we send you | [Switzerland] |
| Stripe [Stripe Payments Europe Ltd.] — only if you pay by card | your name, e-mail address and payment details (we never see your card number) | [Ireland (EU); Stripe may process in the United States under the Swiss-US Data Privacy Framework] |
| [AI provider, e.g. Anthropic PBC] — only for AI features the operator has switched on | official public records and your question to "Ask"; never your account details, portfolio, watchlists, alert terms or interests | [United States — safeguards: Swiss-US Data Privacy Framework / standard contractual clauses] |
| Our team [in Switzerland and Hong Kong] | your sign-in details; your own settings only while you allow it (Profile → Support access) | [Switzerland / Hong Kong] |
| Authorities | only when the law obliges us | — |
Each provider works under a data processing agreement and only on our instructions.
Abroad. We are a Hong Kong company, and we keep your data in Switzerland: on our server and in our encrypted backup there, run for us by a Swiss hosting provider under a contract that lets it use the data only on our instructions and keep it no longer than we do. If you are in Hong Kong, your data goes from Hong Kong to Switzerland when you use the service. If you are in Switzerland, it stays there, and our team may look at it from Hong Kong to run the service and help you; Hong Kong is not on the Swiss Federal Council's list of countries with adequate protection, so we protect that access with [the Swiss standard contractual clauses / your consent given at sign-up] in addition to the PDPO, which binds us. Transfers to Stripe and to an AI provider are covered as stated in the table.
Your rights. You can see and download everything kept about you (Profile → Your data → Download my data), correct your settings, erase your data and delete your account — at any time, on any plan. You can also write to [privacy e-mail] to ask for access or correction, to object, or to complain. We answer access requests within 30 days (FADP) and in any case within 40 days (PDPO s. 19), free of charge. You may complain in Switzerland to the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch), and in Hong Kong to the Privacy Commissioner for Personal Data (PCPD, pcpd.org.hk).
Security. Passwords as scrypt hashes; e-mail addresses and two-step keys encrypted; sessions of which only a hash is kept; optional two-step sign-in; a tamper-evident security trail; HTTPS only; the server and its backups in Switzerland, backups encrypted with a key the hosting provider does not have. After you delete your account, its data also leaves the backups within 30 days.
If something goes wrong. If a breach of security is likely to put your data at high risk, we tell the FDPIC as soon as possible, tell you when you need to protect yourself, and also tell the PCPD.
Changes. We will tell you of changes to this notice before they take effect.