Privacy Policy

1. Introduction

SwingFolio ("we," "us," or "our") operates the SwingFolio platform at https://swingfolio.com (the "Service"). SwingFolio is operated by Intra Finance Group Pty Ltd (ABN 43 653 229 335), an Australian company.

We are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and other applicable privacy laws including the General Data Protection Regulation (GDPR) for EU/UK residents and the California Consumer Privacy Act (CCPA) for California residents.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. Please read this policy carefully. By creating an account, you enter into a contract with us that enables us to provide the Service. Some features may require your specific consent, which you can withdraw at any time.

Important: SwingFolio is a portfolio tracking and trade journaling tool only. We do not provide financial advice, investment recommendations, or trading signals. We do not hold an Australian Financial Services License (AFSL). Always consult a licensed financial advisor before making investment decisions.

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

• Email address
• Name (if provided)
• Password (stored in encrypted/hashed form - we never store plaintext passwords)
• Profile preferences and settings

2.2 Financial and Trading Data

To provide our portfolio tracking and trade journaling services, we collect:

• Portfolio information (names, currencies, broker details)
• Trade entries and exits (symbols, dates, prices, quantities)
• Trading strategies and rules you define
• Trade notes, ideas, and journal entries you create
• Calculated metrics (profit/loss, R-multiples, win rates)
• Cash transactions (deposits, withdrawals, dividends)
• Alert configurations

Important: We do not have access to your brokerage accounts. All trading data is manually entered by you or imported from files you upload. We do not execute trades on your behalf.

2.3 Technical and Usage Data

We automatically collect:

• IP address
• Browser type and version
• Device type and operating system
• Pages visited and features used
• Time spent on the Service
• Referring website or source
• Error logs and performance data

2.4 AI Interaction Data

When you use our AI-powered features (such as trade analysis or the AI assistant), we collect:

• Questions and prompts you submit
• AI-generated responses
• Portfolio and trade data shared with the AI for analysis (summary metrics, not raw account credentials)

2.5 Communication Data

We collect information when you:

• Contact us for support
• Respond to surveys or feedback requests
• Subscribe to newsletters or updates

3. How We Use Your Information

We use your information to:

• Provide the Service: Create and manage your account, track portfolios, record trades, and calculate performance metrics
• Power AI Features: Analyze your trading data to provide personalized insights, identify patterns, and offer suggestions
• Improve the Service: Understand how users interact with SwingFolio to enhance features and user experience
• Provide Market Data: Display current and historical prices for securities you track
• Send Communications: Service updates, security alerts, and (with your consent) marketing communications
• Ensure Security: Detect and prevent fraud, abuse, and unauthorized access
• Comply with Legal Obligations: Meet regulatory requirements and respond to lawful requests
• Generate Aggregated Insights: Create anonymized statistics about trading patterns (never identifying individual users)

4. Legal Basis for Processing

Under Australian Privacy Principles and applicable international laws, we process your personal information based on:

• Contract Performance: Processing necessary to provide the Service you requested
• Legitimate Interests: Improving our Service, ensuring security, and conducting business operations, balanced against your privacy rights
• Legal Compliance: Meeting our legal and regulatory obligations
• Consent: Where you have given explicit consent (e.g., marketing communications, optional AI features)

5. AI Features and Data Processing

SwingFolio uses artificial intelligence to provide trading insights and analysis. Here's how your data is handled:

AI Providers

We may use the following AI service providers to power our AI features. The specific provider used may vary based on feature requirements and availability:

• Google Generative AI (Gemini) - Primary AI provider for trade analysis and insights. Privacy Policy
• OpenAI - AI-powered analysis features. Privacy Policy
• Anthropic - AI-powered analysis features. Privacy Policy
• DeepSeek - AI analysis features. Privacy Policy

When you use AI features:

• Your prompts and relevant trading context are sent to the AI service provider
• The provider processes this data to generate responses according to their respective privacy policies linked above
• We do not send sensitive account credentials or passwords to AI services

What We Share

For AI analysis, we may share summary information such as trade statistics, performance metrics, and portfolio allocations. We minimize the data shared to what is necessary for the requested analysis.

AI-Generated Insights Disclaimer

Our AI features analyze historical data and patterns but do NOT constitute financial advice. AI-generated insights are based on past performance (which does not guarantee future results), may contain errors or inaccuracies, and should not be the sole basis for investment decisions.

Automated Decision-Making

Our AI features provide analytical insights to assist your decision-making. We do NOT make automated decisions that produce legal or similarly significant effects. You remain in full control of all trading and investment decisions. AI insights are suggestions only and always require your review.

Opting Out

AI features are optional. You can use SwingFolio's core portfolio tracking and journaling features without using AI analysis.

6. Third-Party Services

We work with trusted third-party service providers to operate SwingFolio:

We maintain Data Processing Agreements (DPAs) with all service providers who process personal data on our behalf, ensuring they comply with applicable data protection laws and only process data according to our instructions.

Market Data Disclaimer

Price data, charts, and fundamental data are provided by third-party sources (EODHD and TradingView) and displayed for informational purposes only. We do not guarantee the accuracy, completeness, or timeliness of this data. Always verify information with your broker before making trading decisions. We are not responsible for any errors, omissions, or delays in the data provided by these third-party services.

7. International Data Transfers

SwingFolio is operated from Australia, but your personal information may be transferred to and stored in the United States and other countries where our service providers operate.

When we transfer data internationally, we take steps to ensure your information receives adequate protection:

• We use service providers who participate in recognized data protection frameworks
• We implement Standard Contractual Clauses where applicable
• We apply appropriate technical and organizational security measures

When we disclose personal information to overseas recipients, we take reasonable steps to ensure they do not breach the Australian Privacy Principles. We remain accountable for their handling of your information under APP 8.1.

Please note that privacy laws in other jurisdictions may differ from those in Australia.

8. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes described in this policy:

• Account Credentials: Duration of account plus 30 days after deletion
• Trading Records: 7 years (to support Australian tax compliance requirements)
• Technical Logs: Up to 12 months
• AI Conversation History: Duration of account plus 90 days
• Marketing Preferences: Until consent withdrawn plus 30 days

After account deletion, we may retain certain information as required by law or for legitimate business purposes (such as fraud prevention or resolving disputes). Deletion requests are processed within 30 days unless legal retention requirements apply.

Tax Reporting

SwingFolio provides tools to track trading activity for your tax records. However, you are responsible for reporting capital gains/losses to tax authorities. We do not file tax reports on your behalf or provide tax advice. We recommend consulting a tax professional.

9. Your Rights

Under Australian Privacy Principles and applicable laws, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your account and associated data (subject to legal retention requirements)
• Data Export: Export your trading data in a portable format
• Opt-Out: Unsubscribe from marketing communications at any time
• Restrict Processing: Request that we limit how we use your data in certain circumstances
• Complain: Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the Privacy Act

To exercise these rights, contact us at hello@swingfolio.com. We will respond within 30 days. Your first copy of data is provided free of charge.

Withdrawing Consent

Where we process your data based on consent, you can withdraw consent at any time by:

• Adjusting settings in your account preferences
• Clicking "unsubscribe" in marketing emails
• Disabling AI features in your settings
• Contacting us at hello@swingfolio.com

Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

10. Cookies and Tracking

SwingFolio takes a privacy-first approach. We use only essential and functional cookies/storage technologies:

• Essential Cookies: Required for authentication and security (Supabase authentication)
• Functional Storage: Remember your settings and preferences (theme, table customisations, last viewed page)

What We Don't Use

We do NOT use analytics tracking cookies (such as Google Analytics), advertising cookies, or third-party marketing pixels. Your browsing behaviour on SwingFolio is not tracked or shared with advertisers.

Managing Preferences

You can manage cookies through your browser settings. Disabling essential cookies will prevent you from logging in. Clearing browser storage will reset your preferences to defaults.

For full details, please see our Cookie Policy.

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption of data in transit (TLS/HTTPS)
• Encryption of sensitive data at rest
• Secure password hashing
• Row Level Security (RLS) for database access control
• Regular security assessments
• Access controls and authentication requirements

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

Data Breach Response

In the event of a personal data breach that is likely to result in serious harm:

• Australian Users: Under the Notifiable Data Breaches (NDB) scheme, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable
• EU/UK Users: We will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay
• California Residents: We will notify affected residents in compliance with California Civil Code § 1798.82

All breach notifications will include the nature of the breach, categories of data involved, likely consequences, and measures taken to address the breach.

12. Children's Privacy

SwingFolio is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children.

During account registration, we require users to confirm they are at least 18 years old. If we discover that a user is under 18, we will immediately suspend the account and delete all associated personal information within 30 days.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at hello@swingfolio.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page
• Updating the "Last Updated" date
• For significant changes, sending an email notification to registered users

Your continued use of SwingFolio after changes become effective constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Email: hello@swingfolio.com

Office of the Australian Information Commissioner
If you are not satisfied with our response to a privacy concern, you may lodge a complaint with the OAIC:
Website: www.oaic.gov.au
Phone: 1300 363 992

15. Additional Rights for EU/UK Residents (GDPR)

If you are located in the European Union or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing

We process your data based on:

• Contract: To provide the Service you signed up for
• Legitimate Interest: For security, improvement, and business operations
• Consent: For marketing and optional AI features
• Legal Obligation: To comply with applicable laws

Additional Rights

Beyond the rights listed in Section 9, you may also:

• Data Portability: Receive your data in a structured, commonly used, machine-readable format
• Object to Processing: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Automated Decision-Making: Not be subject to decisions based solely on automated processing (we do not make such decisions)

International Transfers

When we transfer your data outside the EEA/UK, we rely on Standard Contractual Clauses approved by the European Commission and UK ICO to ensure adequate protection.

Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. For the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

16. Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights:

Categories of Personal Information

We collect the following categories of personal information:

• Identifiers (email, name, IP address)
• Commercial information (trading records, portfolio holdings)
• Internet activity (usage data, browsing history on our Service)
• Inferences (trading patterns, performance metrics derived from your data)

Sources of Information

• Directly from you (account registration, trade entries)
• Automatically from your device (usage data, IP address)
• From third parties (market data providers like EODHD for symbol information)

Sensitive Personal Information

We do not collect "sensitive personal information" as defined by CPRA (such as social security numbers, precise geolocation, or financial account login credentials). Your trading data (holdings, transactions) is commercial information, not sensitive PI under CPRA definitions. However, we treat all financial data with enhanced security measures.

Your Rights

• Right to Know: Request disclosure of the categories and specific pieces of personal information we collect
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

Sale of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

Exercising Your Rights

To exercise your CCPA rights, contact us at hello@swingfolio.com. We will verify your identity before processing your request. You may designate an authorized agent to make requests on your behalf.