Privacy policy
What we collect, what we deliberately do not collect, and what you can do about it.
Draft of 5 Aug 2026
1. Who is responsible for your data
The controller is the Belgian company operating Belfolio. Its legal name, company number, registered address and a contact address for privacy requests are to be inserted here before launch, together with whether a data protection officer is appointed.
2. What we collect
Your account: name, email address, interface language, password (stored hashed, never in readable form).
What your broker exports contain: transactions, positions, instruments, amounts, and the account references that appear in them.
Your email address if you asked for the calculator summary or for deadline reminders, together with the date and IP address of your confirmation, which is the evidence that consent was given.
Billing: your subscription state and Stripe identifiers. Your card details are handled by Stripe and never reach us.
Technical: server and error logs needed to operate and secure the service.
3. The public calculator stores nothing
When you use the calculator without an account, the file you upload is parsed in memory during the request. It is never written to disk and never written to the database.
The resulting figures are held in your encrypted session so the page survives a refresh and the email step. They disappear when the session expires or when you clear your browser. There is no retention period to explain, because there is nothing retained.
4. Broker statements uploaded to an account
When you are signed in, an uploaded statement is stored on a private disk that is not reachable from the web, parsed by a background job, and then deleted. Keeping the original file is off by default.
The parsed rows are kept, because they are the evidence behind every figure the product shows you and behind anything you may have declared.
5. Encryption
Financial content is encrypted at rest in the database: transaction rows, parse warnings and reconciliation data, account references, manually entered holdings, and the email addresses on the reminder list. Passwords are hashed, not encrypted — they cannot be read back at all.
All traffic is served over TLS.
6. We do not connect to your bank
Belfolio has no connection to your bank or broker accounts. It cannot log in on your behalf, cannot see your balances and cannot move anything.
This is by design. PSD2 account access covers payment accounts and does not reach investment accounts, and acting as an account information service provider requires authorisation from the National Bank of Belgium, which we do not hold. Data enters this product one way: a file you export from your broker and choose to upload.
7. Where your data is hosted
The application and its database run on servers located in the European Union, on a European hosting provider.
The exact provider, data-centre region and the equivalent details for backups and object storage are to be confirmed and stated here before launch.
8. Who else processes your data
Stripe, for payments, invoicing and VAT calculation. It receives your email address, your billing address and, if you provide one, your VAT number. It never receives your portfolio.
Our hosting provider, and the mail provider that sends account and reminder emails.
If enabled, a cookie-less analytics service and an error-tracking service. Neither receives any financial data.
The complete and final list of processors, the location of each, and the data processing agreements and transfer mechanisms behind them are to be completed before launch.
9. Why we are allowed to process it
In outline: performing the contract for your account and subscription, your consent for the reminder mailing list, a legal obligation for invoices and accounting records, and our legitimate interest in keeping the service secure.
The precise mapping of each processing activity to its legal basis is to be settled by legal review before launch.
10. How long we keep it
Today, your account data is kept while your account exists, including after a subscription ends — a cancelled subscription becomes read-only and nothing is deleted, because the figures may support a filed tax return. Uploaded files are deleted immediately after parsing. Anonymous calculator results are never stored.
Definite retention periods — in particular for invoices and accounting records, which Belgian law requires to be kept, and for the reminder list — are to be settled by legal review and stated here as concrete durations.
11. Your rights, and where to exercise them
You can download everything we hold about you, in machine-readable form, from Settings › Privacy. The export is generated from the same sources the product reads, so it is complete rather than a summary.
You can delete your account and its data from the same page. Deletion is real: the records are destroyed, not flagged. It is available whatever the state of your subscription — a paywall in front of erasure would be indefensible.
You also have the rights of access, rectification, restriction, objection and portability under the GDPR. Where to send such a request, and the identity checks that apply, are to be stated here before launch.
12. Cookies and measurement
Belfolio sets a session cookie, which is required for you to stay signed in, and a cookie remembering your language choice. Neither is used for advertising or profiling.
Analytics, where enabled, is cookie-less and self-hostable, and records page views and a small set of product events — an upload started, a parse succeeded or failed, a summary downloaded. No event ever carries an email address, an instrument identifier or an amount.
13. Complaints
If you think we are handling your data wrongly, tell us first — we would rather fix it. You also have the right to lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit).
Open points for legal review
Listed here rather than filled in with plausible wording, because a clause nobody has checked is more dangerous than a visible gap.
- Controller identity, privacy contact address, and whether a DPO is required or appointed.
- Hosting: exact provider, region, and the same for backups and object storage.
- Complete processor list with locations, data processing agreements, and transfer mechanisms for any processor outside the EEA.
- Legal basis for each processing activity, stated per activity rather than in outline.
- Concrete retention periods, including the statutory minimum for invoices and accounting records.
- Identity verification procedure for data subject requests.
- Whether the consent evidence we keep for the mailing list (date and IP address) is proportionate.
- Whether a record of processing activities and a DPIA are required for this product.