Privacy policy
Last updated 20 July 2026
This policy explains what personal data MyPholyo collects, why we collect it, who we share it with, and the rights you have. We keep data to a minimum and never sell it.
Who we are
MyPholyo (“we”, “us”) provides this app and is the data controller for the personal data described here. For any privacy question, or to exercise the rights below, contact us at hello@theportfolio-method.com.
The data we collect
- Account & sign-in: your email address and, if you choose Apple or Google sign-in, the verified account identifier and profile details that provider shares with us. We use these details to create or access your account and contact you about it.
- Audit & product data: the answers, rates, check-ins, goals, wins, income streams, and notes you enter, and the reports and insights generated from them.
- Billing: if you start a trial or subscription, our payment processor (Stripe) handles your card details. We never see or store your full card number; we receive your subscription status and limited billing metadata.
- Support: the messages you send us and the email address you reply from.
- Technical & usage: basic information needed to run the service securely (such as request logs), and, only with your consent, privacy-friendly product analytics and browser error diagnostics. We disable session recording, autocapture, performance tracing, and the collection of form bodies, free text, cookies, headers, or URL query strings. Server and Edge exceptions are processed without account identity or request contents so we can operate and secure the service. See our cookie policy.
How we use it, and our legal bases
Under the UK/EU GDPR we rely on the following legal bases:
- To provide the app: create your account, generate your reports and insights, and deliver the features you use (performance of our contract with you).
- To take payment: manage trials, subscriptions, and refunds (performance of our contract; legal obligation for tax and accounting records).
- To keep the service secure and improve it: prevent abuse, troubleshoot, and understand which features help (our legitimate interests, balanced against your rights).
- Optional analytics and any marketing: only with your consent, which you can withdraw at any time.
AI processing
To generate your audit report, insights, and coaching content, the information you provide is processed by AI systems, including large language models. This processing happens server-side through our trusted providers; the app in your browser never sends your data directly to a model provider. Automated output can be inaccurate; please read our important notices on how to use it.
Who we share it with
We share data only with the service providers that help us run the app, each under a contract that limits them to processing it on our instructions:
- cloud hosting and database providers that run the app and store your data;
- our payment processor, for trials, subscriptions, and refunds;
- an email provider, to send sign-in codes and respond to support;
- Apple or Google, when you choose one of them to verify your identity;
- AI/model providers, to generate your reports and insights;
- a privacy-friendly analytics provider, only if you consent;
- an EU-region error-monitoring provider for scrubbed server diagnostics and, only if you consent, browser diagnostics.
We do not sell your personal data or share it for advertising. We may disclose data if required by law or to protect our rights, users, or the public.
International transfers
Some of our providers process data outside your country, including in the United States. Where that happens, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) or an approved adequacy framework, so your data keeps an equivalent level of protection.
How long we keep it
We keep your account and product data for as long as your account is active, and for a limited period afterwards so you can reactivate and to meet legal, security, and accounting obligations. We delete or anonymise data when it’s no longer needed. Cookie lifetimes are listed in the cookie policy.
Your rights
Subject to local law, you can ask us to give you access to your data, correct it, delete it, restrict or object to how we use it, or provide it in a portable format. Where we rely on consent, you can withdraw it at any time without affecting earlier processing. To make a request, email hello@theportfolio-method.com. You also have the right to complain to your local data-protection authority.
Children
MyPholyo is not intended for children. Don’t use the app, or provide any personal data, if you’re under 16 (or the minimum age in your country).
Changes
We may update this policy as the product evolves. We’ll change the date above and, for significant changes, let you know in the app or by email.
Contact
Questions or requests: hello@theportfolio-method.com or the Support form.