Privacy Policy

1. Controller

The data controller is Ruokis Oy (Business ID 3551382-6, Uutiskatu 2, 00240 Helsinki, Finland). Privacy contact: [email protected].

2. Data we process

• Account data: email, password (stored hashed), language and settings.
• Imported brokerage data: trades, positions, dividends, fees and instruments imported from Interactive Brokers (read-only).
• Payment data: subscription status and limited billing data; card details are handled by our payment provider and not stored by us.
• Technical/usage data: IP address, device/browser, log and diagnostic data.
• Sign-up source: your answer to “How did you hear about us?” (optional) and — only if you accepted analytics cookies — campaign tags (UTM), the website that referred you and the first page you visited on our site; the Google Ads click identifier only if you also accepted advertising cookies. Stored with your account when you sign up.
• Cookies/analytics: see our Cookie Policy.

3. Purposes and legal bases

• Providing and operating the service, including import and calculations — performance of a contract.
• Account security, fraud prevention, debugging and improvement — legitimate interest.
• Understanding which channels bring new users (sign-up source): your answer to “How did you hear about us?” — legitimate interest; campaign tags, the referring website and the Google Ads click identifier — your consent. Withdrawing consent in cookie settings stops further collection; to delete a source already saved with your account, contact us (it is also deleted together with your account). If you had accepted advertising cookies when you signed up, we report your sign-up to Google Ads once (the click identifier and the time of sign-up) to measure which ads lead to sign-ups — your consent.
• Analytics, advertising measurement and marketing — your consent (you can withdraw it).
• Complying with legal and accounting obligations — legal obligation.

4. Retention

We keep your data while your account is active and for as long as needed for the purposes above or to meet legal obligations. You can delete your account and request erasure; we then delete or anonymize your data unless we must retain some by law.

Encrypted backups are kept for at most 30 days, so copies of deleted data also disappear from backups within 30 days of erasure.

5. Recipients and processors

We share data only with the service providers and partners listed below and do not sell your data. Paddle, Google (reCAPTCHA) and TradingView process data as independent controllers under their own privacy policies; the others act on our behalf.

• Hetzner (Germany) — hosting: our servers and backups are located in Finland.
• Cloudflare — DNS, content delivery and protection against attacks: every request to pnltrack.com passes through Cloudflare. Cloudflare terminates the encrypted (TLS) connection, so it technically sees the content of requests, including your portfolio data and your login credentials when you sign in, as well as your IP address, request headers (e.g. browser) and approximate location. Cloudflare also forwards email sent to our support address to our mailbox at Google.
• Resend — email delivery, for example address confirmation, password reset and our replies to your support requests: your email address and the content of the message.
• Paddle (United Kingdom) — payments as merchant of record; Paddle processes your billing data as an independent controller under its own privacy policy.
• Sentry (EU data region) — error monitoring: technical details of errors, the request and your internal user identifier (not your email).
• PostHog (EU servers) — product analytics, only with your consent and not linked to your account.
• Google: our support mailbox (Google Workspace) — your messages to support and our replies; reCAPTCHA on the sign-up form (IP address, browser and interaction data, to block automated sign-ups; Google acts as an independent controller); Google Fonts on the website and in the app — on every visit Google receives your IP address and browser data; Google Tag Manager on the website — loads only after you accept analytics cookies, and until then Google receives nothing through it; Google Analytics on the website and the sign-up event in the app — only with your consent; Google Ads measurement — only if you accepted advertising cookies (the click identifier and time of your sign-up).
• Telegram (Telegram Messenger Inc. / Telegram FZ-LLC) — service notifications to our administrator: internal technical identifiers (yours and, for example, of an import), the type of event (for example sign-up, sign-in, a failed import) and technical counters, without your email address, name, brokerage account numbers or financial data. The administrator looks up the details in the service itself.
• TradingView — the chart widgets and ticker search in the app load from TradingView: it receives the ticker of the security you open together with your IP address, and processes them as an independent controller under its own policy.

6. International transfers

Some of these providers process data outside the EU/EEA. Paddle is in the United Kingdom, which is covered by an EU adequacy decision. Cloudflare, Resend and Google may process data in the United States; Sentry and PostHog store our data in the EU but are US companies. For providers acting on our behalf, transfers rely on the EU Standard Contractual Clauses in their data processing agreements. TradingView, as an independent controller, transfers data under its own safeguards. Telegram is also located outside the EU/EEA; it receives only internal identifiers, the event type and technical counters (see section 5).

7. Your rights

Under the GDPR you may request access, rectification, erasure, restriction and portability, and object to processing, and withdraw consent at any time. Contact: [email protected]. You may also lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi).

8. Security

We use a read-only connection to Interactive Brokers (we cannot trade or withdraw funds), encryption in transit, access controls and other measures appropriate to the risk. No method is 100% secure.

9. Children

The service is not directed to persons under 18.

10. Changes

We may update this policy; material changes will be notified.

11. Contact

Ruokis Oy (Business ID 3551382-6, Uutiskatu 2, 00240 Helsinki, Finland). Email: [email protected].