Privacy Policy
1. Who we are
bnauta02 is the data controller responsible for your personal data. We are based in the Netherlands.
| Contact email | hello@altumwealthinsights.com |
| KVK number | [To be filled in] |
This policy explains how we collect, use, store, and share your personal data when you use the Altum Wealth Insights platform (the "Service"). It applies to users worldwide and complies with the General Data Protection Regulation (GDPR, EU 2016/679) and applicable Dutch law.
2. What data we collect and why
| Category | Data | Purpose |
|---|---|---|
| Account data | Email address, username, date of birth, city, country | Collected at registration to create and manage your account |
| Uploaded portfolio data | CSV/Excel files uploaded by you | Used solely to generate your portfolio analysis. Files are not stored permanently after the session unless you explicitly save your portfolio. |
| Usage data | Pages visited, time spent, actions taken | Collected via Google Analytics (only if you consent) to help us improve the product |
| Technical data | IP address, browser type, device information | Collected automatically by the server for security, fraud prevention, and performance |
3. Legal basis for processing (GDPR)
| Processing activity | Legal basis |
|---|---|
| Account data (registration, login, service delivery) | Contract performance — Art. 6(1)(b) GDPR |
| Analytics and usage tracking (Google Analytics) | Consent — Art. 6(1)(a) GDPR |
| Security and technical data (IP hashing, abuse prevention) | Legitimate interest — Art. 6(1)(f) GDPR |
4. How long we store data
- Account data: Retained as long as your account is active. Deleted within 30 days of an account deletion request (subject to a grace period for recovery).
- Uploaded files: Not stored beyond the active session unless you explicitly save your portfolio. Saved portfolios are retained until you delete them or close your account.
- Analytics data: Retained per Google Analytics default settings (currently 14 months).
- Technical/security data: IP addresses are stored only as irreversible hashes. Session metadata follows a rolling retention schedule.
- Error and performance logs: Detailed logs (which may include a pseudonymous user ID) are automatically deleted after 90 days. Aggregated statistics (without any user identifier) are retained for up to 1 year for service reliability and improvement. This processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in maintaining the security and proper functioning of the application.
5. Who we share data with
| Third party | Purpose | Condition |
|---|---|---|
| Google Analytics | Aggregated usage analytics | Only with your consent. See Google's Privacy Policy. |
| Railway (hosting provider) | Application and data hosting | Data is processed on their servers as part of operating the Service. |
We do not sell your data to third parties, ever.
6. International data transfers
Google Analytics may process data outside the European Union. Google is certified under the EU-US Data Privacy Framework, providing adequate safeguards for data transfers to the United States. Where other transfers apply, we rely on Standard Contractual Clauses or equivalent mechanisms.
7. Your rights
Under the GDPR (and equivalent regulations worldwide), you have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Delete your data ("right to be forgotten")
- Restrict processing of your data in certain circumstances
- Export your data in a portable format (data portability)
- Withdraw consent at any time — via the cookie banner, your account settings, or by contacting us. Withdrawal does not affect prior lawful processing.
To exercise any of these rights, contact us at hello@altumwealthinsights.com or use the data tools in your account settings.
You also have the right to lodge a complaint with the Dutch data protection authority: Autoriteit Persoonsgegevens — autoriteitpersoonsgegevens.nl.
8. Cookies
We use functional cookies to keep you logged in and, with your consent, analytical cookies via Google Analytics. For full details, see our Cookie Policy.
Altum Wealth Insights provides portfolio analysis tools for informational purposes only. Nothing on this platform constitutes financial advice. Always consult a qualified financial advisor before making investment decisions. We are not liable for any investment decisions made based on the output of this tool.
9. Contact
For any questions about this Privacy Policy or your personal data, contact us at: hello@altumwealthinsights.com
10. Updates to this policy
We may update this Privacy Policy from time to time. Material changes will be reflected by the "Last updated" date at the top of this page. We encourage you to review this page periodically.