Privacy Policy
Effective date:
Your privacy is not just a feature — it is why this app exists. We built Private Portfolio Tracker so your financial data never leaves your device unless you choose iCloud sync. We do not want your data. We really, truly do not.
1. Data We Do Not Collect
We do not collect personal information, financial data, brokerage credentials, analytics, advertising identifiers, crash reports, location data, or device fingerprints. The app contains zero third-party SDKs.
We do not have the technical means to access your portfolio data. The app contains no code that transmits data to our servers, because we do not operate servers that receive user data.
In plain terms: There is no server. There is no database. There is no way for us to see what you track.
2. Data Stored on Your Device
All portfolio data — your accounts, holdings, snapshots, and settings — is stored locally on your device using Core Data. This data is protected by iOS Data Protection (NSFileProtectionComplete), which means it is encrypted whenever your device is locked.
If you uninstall the app, all local data is permanently and irrecoverably deleted.
Local Notifications
If you enable snapshot reminders, the app schedules monthly local notifications on your device to remind you to log your portfolio value. These notifications are processed entirely on your device and are never sent to our servers. You can disable reminders at any time in the app's settings or through iOS notification settings.
3. Optional iCloud Sync
iCloud sync is enabled by default. Your data is stored in your private CloudKit database — a per-user container that only you can access. As the developer, we cannot query, read, or export data from your private database. Apple does not provide developers with access to private database contents.
Encryption: Your data is encrypted in transit and at rest using your iCloud account encryption keys. We do not possess decryption keys and cannot read your synced data under any circumstances.
If you enable Apple's Advanced Data Protection, your iCloud data receives end-to-end encryption — meaning even Apple cannot access it.
You can disable iCloud sync at any time in the app's settings. Changes take effect after restarting the app. Disabling sync removes your data from iCloud per Apple's CloudKit data lifecycle.
Where is my data stored?
- iCloud sync off: Your data exists only on your device.
- iCloud sync on: Your data exists on your device and in your private iCloud account.
Lawful basis for processing
The lawful basis for processing your data through iCloud sync is your consent under GDPR Article 6(1)(a). You enable sync voluntarily in the app's settings and can withdraw consent at any time by disabling iCloud sync.
Data processor
When you use iCloud sync, Apple acts as a data processor under their Data Processing Addendum. Apple stores your data in your private CloudKit container and does not provide us access to it.
International data transfers
Your iCloud data may be stored in Apple data centers worldwide. Apple maintains appropriate safeguards for international data transfers, including Standard Contractual Clauses. See Apple's Privacy Policy at apple.com/privacy for details.
4. Subscriptions and Payments
All payments are processed by Apple through the App Store. We do not receive, process, or store any billing information, credit card numbers, or payment details. Apple handles all transaction processing, receipts, and refunds.
5. Data Retention and Deletion
Your data persists on your device for as long as the app is installed. You can delete individual portfolios, accounts, or holdings within the app at any time. Uninstalling the app permanently removes all local data.
Because we do not operate servers that store user data, there is no server-side data to retain or delete. If you use iCloud sync, disabling it removes your cloud copy per Apple's CloudKit data lifecycle.
6. Your Rights
Because we collect zero data, most data-rights requests do not apply — there is nothing for us to disclose, correct, or delete on our end. However, we respect your rights under applicable law:
- Data portability: You can export your data as a CSV file from within the app at any time.
- Right to delete: Delete data in-app or uninstall to remove everything.
- CCPA: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.
- GDPR: We do not process personal data on our servers. Your data remains under your control on your device and in your iCloud account.
- Withdraw consent: You can disable iCloud sync at any time in the app's settings.
- Right to rectification: You can correct your data directly within the app at any time.
- Right to restriction of processing: You can restrict processing by disabling iCloud sync, limiting data to your device only.
- Right to object: Because processing is based on your consent, you can object by disabling iCloud sync at any time.
- Supervisory authority: If you are in the EU/EEA, you have the right to lodge a complaint with your local data protection supervisory authority.
- Automated decision-making: We do not use automated decision-making or profiling.
7. App Tracking Transparency
We do not use the Identifier for Advertisers (IDFA). We do not track you across apps or websites owned by other companies. No App Tracking Transparency prompt is displayed because no tracking occurs.
Do Not Track: This website does not track visitors. We do not respond to Do Not Track browser signals because no tracking occurs.
Cross-site tracking: No third parties collect personally identifiable information about your online activities over time or across different websites when you visit this site.
8. Children's Privacy
Private Portfolio Tracker is not directed at children under 13. We do not knowingly collect data from anyone — children or adults. Because the app collects zero data, there is no age-specific data processing to address.
9. Third-Party Services
The app uses only first-party Apple frameworks: Core Data for local storage, CloudKit for optional iCloud sync, StoreKit 2 for subscription management, Swift Charts for data visualization, TabularData for CSV import and export, and UserNotifications for optional local reminders. We do not integrate any third-party SDKs, analytics services, crash reporters, or advertising networks.
10. This Website
This website is hosted on Cloudflare Pages. We do not use analytics, tracking pixels, cookies, or third-party scripts.
Cloudflare may process visitor IP addresses and request metadata for security and performance as part of its hosting infrastructure. This processing is governed by Cloudflare's Privacy Policy at cloudflare.com/privacypolicy.
No data about your visit is collected, stored, or accessible by us.
11. Changes to This Policy
If we update this privacy policy, we will post the revised version on this page with an updated effective date. Because we collect no email addresses or contact information, this page is the sole notification channel for policy changes.
12. Contact
Data controller: Gurinder Singh
Chandigarh, India
If you have questions about this privacy policy or your data, contact us at [email protected].