Legal
Privacy Policy
This policy explains how Tobailey handles personal information when you visit or use the platform.
Effective 17 July 2026 · Last updated 17 July 2026
1. Who we are
Tobailey is an independent portfolio monitoring and decision-support platform. For privacy questions or requests, please use our contact form.
2. Information we process
Depending on the features you use, we may process:
- account and contact information;
- portfolio holdings, quantities, purchase prices and currencies;
- uploaded CSV files and Excel files;
- financial goals and contribution assumptions;
- technical, security and limited usage information;
- support messages and attachments you send us.
We do not ask for broker login credentials and do not connect to broker accounts in the MVP.
3. Why we use this information
We use information to provide and secure the service, recognise and verify uploaded holdings, calculate portfolio insights, personalise briefings and goals, process subscriptions, provide support, prevent misuse and improve reliability.
4. Legal grounds
Where applicable, we process information because it is necessary to provide the service you requested, because we have a legitimate interest in operating and securing the platform, because you have given consent, or because we must comply with a legal obligation.
5. AI-assisted processing
Tobailey may use AI services to produce portfolio summaries and analysis. AI output can be inaccurate. Imported and manually entered information must be reviewed before it is saved or relied upon. Uploaded information is shared with service providers only as needed to perform the requested function.
6. Service providers and international transfers
We may use carefully selected providers for hosting, authentication, market data, AI processing, analytics, email and payments. They may only process information for the agreed service. If information is transferred outside the European Economic Area, we use an appropriate legal transfer mechanism where required.
7. Retention
We keep personal information only for as long as necessary for the purpose for which it was collected, to meet legal obligations, resolve disputes and protect the service. Retention periods may differ by data category. Account information will normally be deleted or anonymised after the account and any applicable legal retention period end.
8. Security
We use reasonable technical and organisational safeguards designed to protect information. No online service can guarantee absolute security. Do not upload passwords, identity documents or information that is not needed to use Tobailey.
9. Your privacy rights
Subject to applicable law, you may request access, correction, deletion, restriction, portability or objection to certain processing. You may also withdraw consent where processing relies on consent and lodge a complaint with your local data-protection authority. Use our contact form to submit a request; we may need to verify your identity first.
10. Cookies and local storage
The MVP may use strictly necessary cookies or browser storage to maintain sessions, preferences and recent market information. Optional analytics or marketing technologies will only be introduced with the required notice and choices.
11. Changes to this policy
We may update this policy as the product develops or legal requirements change. The latest version and effective date will always appear on this page. Material changes will be communicated where appropriate.