
See real returns since your first 2017 buy — with EUR, USD and GBP pairs reconciled, lot-level cost basis to your cold-storage wallet, and capital-gains tax ready for the jurisdiction you file in.
Capitally tracks every Bitstamp position back to your first 2017 buy: real time-weighted and money-weighted returns per coin, fees and FX moves on every pair pulled out, and a benchmark of your choice next to your active stack.
Cost basis carries lot by lot across EUR, USD and GBP, then out to your cold-storage wallet — and capital-gains tax reports come ready for the jurisdiction you actually file in. End-to-end encrypted; no API keys, no Plaid, no third party touching your trades — and the Bitstamp CSV reaches back to your first 2017 trade, well past anything an aggregator would surface.
Bitstamp's transaction history is a list. There's no money-weighted return, no time-weighted return, no per-coin contribution, no benchmark — and no honest reckoning with the fees and currency conversions sitting in separate columns of every trade.
Capitally rebuilds the picture: real performance per coin and per fiat pair, dollar-cost averaging plotted over years, and any benchmark you choose laid alongside — so you can answer whether holding BTC since 2017 actually beat the S&P, the Stoxx 600, or just sitting in EUR cash.
Bitstamp probably isn't the only place your crypto lives, and it's certainly not the only place your money lives — there's the brokerage account, the pension, an old Kraken or Binance balance, maybe a hardware wallet. Bitstamp's app sees none of it.
Capitally pulls every account into one view, organises them by household member, goal or strategy, and reconciles every coin and currency into your base. The whole portfolio in one place — no wallet keys, no API tokens, nothing handed to a third party.
Bitstamp is crypto-only — and that's fine, until you remember that crypto isn't the only thing you own. A tracker that ignores everything else is just another silo.
Capitally treats Bitcoin, Ethereum and any altcoin you've ever held on Bitstamp the same way it treats stocks, ETFs, cash, bonds and real estate: positions in one portfolio, valued in your base currency, with cost basis and returns calculated the same way across the board. One portfolio, one tax-ready answer per jurisdiction.
End-to-end encrypted on your device — before anything leaves your device. We can't see your data, and neither can anyone else.
Advanced retail investors, multi-currency expats, and high-net-worth individuals — across all continents.
"Really pleased to be part of Capitally’s clients! Love the fact that it brings so many functionalities within an efficient interface. Every time I think of something I'd like to do or a piece of data I'd like to have, I always find a way to get it. It's amazing! I’ve also added a shortcut on my iPhone’s home screen, so I can easily access all my data even when I’m away from home. Perfect!"

Frank
France
"I'm really impressed by the quality and versatility of the app. I like that I can customize almost anything. I wanted to have a view of all of my family's assets in one place and the possibility to filter and organize data in any way I want, which is fantastic with the tags. The features that I love the most are the tags, the IRR data, the filtering capabilities and the X-Ray graph."

Boris
Canada
"Once I got used to it, it's a great app! Especially as it handles all my assets - I've tested a few and they didn't have NewConnect for example"

Mateusz
Poland
"As a finance director at a non-profit foundation, I needed a solution that could handle our complex investment mix - from managed funds to real estate. Capitally's flexible import options made it simple to track everything in one place. The affordable price means more of our budget goes to our mission. It's exactly what we needed to get our investment tracking in order."

Jiří Kulík
Nadace Open Society Foundation Prague
"I just wanted to share how brilliant your tool is for managing investments. It is so comprehensively thought-through and the ease with which it can be used is admirable. I used to actively manage my investments via Excel, but this helps to save a lot of time and effort. I'm very impressed!"

Kunal Parwani
Singapore
"Love love LOVE Capitally! I work in Product and I really really appreciate your approach and just what an amazing product it is 😊 "

Li T
Australia
"I bought the subscription for a couple of reasons: 1) your support of the product...I liked that you care about it; 2) the product has good bones and I know it will get better in the future; 3) I like the security aspect of my data"

Drew
USA
"Capitally is an absolutely great tool that allows you to grasp all your investments at a glance, thanks to its clear and well-designed appearance. At the same time, it provides practically unlimited possibilities for exploring data. The whole thing works equally well on a computer and a phone. As a user, I can count on excellent support (thank you!). I also like the pace of development and the features being added - since I purchased the license, the ability to calculate tax liabilities has been introduced, and I also have an early version of options support - something no other solution I know of offers. I definitely recommend it!"

Michał Szafrański
Bestselling author of "Finansowy Ninja"
"The X-Ray feature is “unbelievably good” - you are fantastic and really understand what users need."

Hemanth
India
"I've been using Capitally since November 2024 and have enjoyed it every day since!"

Frank P.
France
"Capitally is an excellent tool that provides a complete overview of all our assets, including real-time stocks, real estate, and private equity. It saves us a lot of time and effort compared to manually keeping track of everything. It's user-friendly and intuitive, with a fantastic support team that is always ready to assist. We highly recommend it to anyone looking for an efficient way to manage their investments."

F3 Capital
Investment Fund
"I started building something similar for myself as a combination of Python + Excel and I came to the conclusion that it would be more economical to choose a ready-made option"

Tomasz Onyszko
@tonyszko
"I am already impressed by the product as it is now, while it is still in the early stages"
Maarten Bremer
"I like the simple UI, the DeGiro import worked pretty well, and I can track everything in my portfolio properly. Dividends and broker cost tracking work well, too."

Jamie Schembri
Netherlands
"It's the first app that was able to import history from all my accounts across multiple brokers. Now I can finally see the full picture for the first time. I highly recommend it!"

sebawo
@sebawo
"I had no idea how many poor investing choices I made before Capitally. Tax filing is so much easier now - saves me hours, and the tax-loss harvesting alone covers the subscription. What I love is how the app pushed me to learn more about metrics. This helped me make smarter money decisions. The tool is fantastic, and the customer support is even better!"

Paweł
Poland
"My only requirement was client-side encryption. That pushed most of your competitors away, so I decided to try with you and never looked back."

Dubravko Flis
Head of IT, Croatia
"Not only does it provide a real value-add through tax reporting (others charge a monthly fee for only having pre-made portfolio analyses without the ability to customize while requiring the user to still use another way to do taxes), but it also excels at the various kinds of integrations of accounts, assets and currencies."

Steffen Jahnke
"It's really fantastic. I've started investing this year, and with Capitally I can see all the information that I need, and it's super easy to use. I love the dashboard and everything. Excellent idea"

Renan Dias
USA
"I spent 4 years building my 16MB Excel spreadsheet for portfolio tracking. In just two evenings with Capitally, I replicated everything and got even better analytics! The data visualization is incredible - slice and dice however you want. But what really blew me away was when the developer fixed an issue before I even reported it. This is next-level software and support! 😂"

TomeK Karczewski
Poland
"Capitally allowed me to transition from overcomplicated spreadsheets that needed to be updated manually (but never was) I used for tracking my investments, to just seeing the data at a glance, automatically updated and ready for me to analyze. And that is just the tip of the iceberg of what it can offer"

Piotr Płaneta
@piotrplaneta
"The game changer that Capitally brings is that it has a very high degree of customization when it comes to selecting assets and recording transactions. For me the differentiator is the ability to record transactions in a currency that differs from the asset currency. My investment portfolio spans multiple global markets and accounts and normal portfolio tracking tools just don't recognize the fact that I may be purchasing a given equity in more than one currency in different accounts."

Stuart Davidson
USA
"I tried Portfolio Performance, but quit it multiple times because of errors in currency handling, importing is too clunky and error-prone in general and there’s a lack of automatic adjustments for dividends and splits. Capitally does all these things right and the reporting is visually nice and quick."

Andries Zwikstra
Netherlands
"I currently have an active subscription with another tool, but I already know that I won't be renewing it.
Capitally takes data exploration to a whole new level, despite lacking some functionalities that will probably appear over time. Both as a programmer and a user, I love tools where intuitiveness is a high priority."

Paweł Gajda
Poland
"Once I got used to it, it's a great app! Especially as it handles all my assets - I've tested a few and they didn't have NewConnect for example"

Mateusz
Poland
"Really pleased to be part of Capitally’s clients! Love the fact that it brings so many functionalities within an efficient interface. Every time I think of something I'd like to do or a piece of data I'd like to have, I always find a way to get it. It's amazing! I’ve also added a shortcut on my iPhone’s home screen, so I can easily access all my data even when I’m away from home. Perfect!"

Frank
France
"I'm really impressed by the quality and versatility of the app. I like that I can customize almost anything. I wanted to have a view of all of my family's assets in one place and the possibility to filter and organize data in any way I want, which is fantastic with the tags. The features that I love the most are the tags, the IRR data, the filtering capabilities and the X-Ray graph."

Boris
Canada
"Love love LOVE Capitally! I work in Product and I really really appreciate your approach and just what an amazing product it is 😊 "

Li T
Australia
"As a finance director at a non-profit foundation, I needed a solution that could handle our complex investment mix - from managed funds to real estate. Capitally's flexible import options made it simple to track everything in one place. The affordable price means more of our budget goes to our mission. It's exactly what we needed to get our investment tracking in order."

Jiří Kulík
Nadace Open Society Foundation Prague
"I just wanted to share how brilliant your tool is for managing investments. It is so comprehensively thought-through and the ease with which it can be used is admirable. I used to actively manage my investments via Excel, but this helps to save a lot of time and effort. I'm very impressed!"

Kunal Parwani
Singapore
"The X-Ray feature is “unbelievably good” - you are fantastic and really understand what users need."

Hemanth
India
"I bought the subscription for a couple of reasons: 1) your support of the product...I liked that you care about it; 2) the product has good bones and I know it will get better in the future; 3) I like the security aspect of my data"

Drew
USA
"Capitally is an absolutely great tool that allows you to grasp all your investments at a glance, thanks to its clear and well-designed appearance. At the same time, it provides practically unlimited possibilities for exploring data. The whole thing works equally well on a computer and a phone. As a user, I can count on excellent support (thank you!). I also like the pace of development and the features being added - since I purchased the license, the ability to calculate tax liabilities has been introduced, and I also have an early version of options support - something no other solution I know of offers. I definitely recommend it!"

Michał Szafrański
Bestselling author of "Finansowy Ninja"
"I started building something similar for myself as a combination of Python + Excel and I came to the conclusion that it would be more economical to choose a ready-made option"

Tomasz Onyszko
@tonyszko
"I've been using Capitally since November 2024 and have enjoyed it every day since!"

Frank P.
France
"Capitally is an excellent tool that provides a complete overview of all our assets, including real-time stocks, real estate, and private equity. It saves us a lot of time and effort compared to manually keeping track of everything. It's user-friendly and intuitive, with a fantastic support team that is always ready to assist. We highly recommend it to anyone looking for an efficient way to manage their investments."

F3 Capital
Investment Fund
"It's the first app that was able to import history from all my accounts across multiple brokers. Now I can finally see the full picture for the first time. I highly recommend it!"

sebawo
@sebawo
"I am already impressed by the product as it is now, while it is still in the early stages"
Maarten Bremer
"I like the simple UI, the DeGiro import worked pretty well, and I can track everything in my portfolio properly. Dividends and broker cost tracking work well, too."

Jamie Schembri
Netherlands
"Not only does it provide a real value-add through tax reporting (others charge a monthly fee for only having pre-made portfolio analyses without the ability to customize while requiring the user to still use another way to do taxes), but it also excels at the various kinds of integrations of accounts, assets and currencies."

Steffen Jahnke
"I had no idea how many poor investing choices I made before Capitally. Tax filing is so much easier now - saves me hours, and the tax-loss harvesting alone covers the subscription. What I love is how the app pushed me to learn more about metrics. This helped me make smarter money decisions. The tool is fantastic, and the customer support is even better!"

Paweł
Poland
"My only requirement was client-side encryption. That pushed most of your competitors away, so I decided to try with you and never looked back."

Dubravko Flis
Head of IT, Croatia
"Capitally allowed me to transition from overcomplicated spreadsheets that needed to be updated manually (but never was) I used for tracking my investments, to just seeing the data at a glance, automatically updated and ready for me to analyze. And that is just the tip of the iceberg of what it can offer"

Piotr Płaneta
@piotrplaneta
"It's really fantastic. I've started investing this year, and with Capitally I can see all the information that I need, and it's super easy to use. I love the dashboard and everything. Excellent idea"

Renan Dias
USA
"I spent 4 years building my 16MB Excel spreadsheet for portfolio tracking. In just two evenings with Capitally, I replicated everything and got even better analytics! The data visualization is incredible - slice and dice however you want. But what really blew me away was when the developer fixed an issue before I even reported it. This is next-level software and support! 😂"

TomeK Karczewski
Poland
"I currently have an active subscription with another tool, but I already know that I won't be renewing it.
Capitally takes data exploration to a whole new level, despite lacking some functionalities that will probably appear over time. Both as a programmer and a user, I love tools where intuitiveness is a high priority."

Paweł Gajda
Poland
"The game changer that Capitally brings is that it has a very high degree of customization when it comes to selecting assets and recording transactions. For me the differentiator is the ability to record transactions in a currency that differs from the asset currency. My investment portfolio spans multiple global markets and accounts and normal portfolio tracking tools just don't recognize the fact that I may be purchasing a given equity in more than one currency in different accounts."

Stuart Davidson
USA
"I tried Portfolio Performance, but quit it multiple times because of errors in currency handling, importing is too clunky and error-prone in general and there’s a lack of automatic adjustments for dividends and splits. Capitally does all these things right and the reporting is visually nice and quick."

Andries Zwikstra
Netherlands
"I'm really impressed by the quality and versatility of the app. I like that I can customize almost anything. I wanted to have a view of all of my family's assets in one place and the possibility to filter and organize data in any way I want, which is fantastic with the tags. The features that I love the most are the tags, the IRR data, the filtering capabilities and the X-Ray graph."

Boris
Canada
"Once I got used to it, it's a great app! Especially as it handles all my assets - I've tested a few and they didn't have NewConnect for example"

Mateusz
Poland
"Really pleased to be part of Capitally’s clients! Love the fact that it brings so many functionalities within an efficient interface. Every time I think of something I'd like to do or a piece of data I'd like to have, I always find a way to get it. It's amazing! I’ve also added a shortcut on my iPhone’s home screen, so I can easily access all my data even when I’m away from home. Perfect!"

Frank
France
"I just wanted to share how brilliant your tool is for managing investments. It is so comprehensively thought-through and the ease with which it can be used is admirable. I used to actively manage my investments via Excel, but this helps to save a lot of time and effort. I'm very impressed!"

Kunal Parwani
Singapore
"Love love LOVE Capitally! I work in Product and I really really appreciate your approach and just what an amazing product it is 😊 "

Li T
Australia
"As a finance director at a non-profit foundation, I needed a solution that could handle our complex investment mix - from managed funds to real estate. Capitally's flexible import options made it simple to track everything in one place. The affordable price means more of our budget goes to our mission. It's exactly what we needed to get our investment tracking in order."

Jiří Kulík
Nadace Open Society Foundation Prague
"Capitally is an absolutely great tool that allows you to grasp all your investments at a glance, thanks to its clear and well-designed appearance. At the same time, it provides practically unlimited possibilities for exploring data. The whole thing works equally well on a computer and a phone. As a user, I can count on excellent support (thank you!). I also like the pace of development and the features being added - since I purchased the license, the ability to calculate tax liabilities has been introduced, and I also have an early version of options support - something no other solution I know of offers. I definitely recommend it!"

Michał Szafrański
Bestselling author of "Finansowy Ninja"
"The X-Ray feature is “unbelievably good” - you are fantastic and really understand what users need."

Hemanth
India
"I bought the subscription for a couple of reasons: 1) your support of the product...I liked that you care about it; 2) the product has good bones and I know it will get better in the future; 3) I like the security aspect of my data"

Drew
USA
"Capitally is an excellent tool that provides a complete overview of all our assets, including real-time stocks, real estate, and private equity. It saves us a lot of time and effort compared to manually keeping track of everything. It's user-friendly and intuitive, with a fantastic support team that is always ready to assist. We highly recommend it to anyone looking for an efficient way to manage their investments."

F3 Capital
Investment Fund
"I started building something similar for myself as a combination of Python + Excel and I came to the conclusion that it would be more economical to choose a ready-made option"

Tomasz Onyszko
@tonyszko
"I've been using Capitally since November 2024 and have enjoyed it every day since!"

Frank P.
France
"I like the simple UI, the DeGiro import worked pretty well, and I can track everything in my portfolio properly. Dividends and broker cost tracking work well, too."

Jamie Schembri
Netherlands
"It's the first app that was able to import history from all my accounts across multiple brokers. Now I can finally see the full picture for the first time. I highly recommend it!"

sebawo
@sebawo
"I am already impressed by the product as it is now, while it is still in the early stages"
Maarten Bremer
"My only requirement was client-side encryption. That pushed most of your competitors away, so I decided to try with you and never looked back."

Dubravko Flis
Head of IT, Croatia
"Not only does it provide a real value-add through tax reporting (others charge a monthly fee for only having pre-made portfolio analyses without the ability to customize while requiring the user to still use another way to do taxes), but it also excels at the various kinds of integrations of accounts, assets and currencies."

Steffen Jahnke
"I had no idea how many poor investing choices I made before Capitally. Tax filing is so much easier now - saves me hours, and the tax-loss harvesting alone covers the subscription. What I love is how the app pushed me to learn more about metrics. This helped me make smarter money decisions. The tool is fantastic, and the customer support is even better!"

Paweł
Poland
"I spent 4 years building my 16MB Excel spreadsheet for portfolio tracking. In just two evenings with Capitally, I replicated everything and got even better analytics! The data visualization is incredible - slice and dice however you want. But what really blew me away was when the developer fixed an issue before I even reported it. This is next-level software and support! 😂"

TomeK Karczewski
Poland
"Capitally allowed me to transition from overcomplicated spreadsheets that needed to be updated manually (but never was) I used for tracking my investments, to just seeing the data at a glance, automatically updated and ready for me to analyze. And that is just the tip of the iceberg of what it can offer"

Piotr Płaneta
@piotrplaneta
"It's really fantastic. I've started investing this year, and with Capitally I can see all the information that I need, and it's super easy to use. I love the dashboard and everything. Excellent idea"

Renan Dias
USA
"I tried Portfolio Performance, but quit it multiple times because of errors in currency handling, importing is too clunky and error-prone in general and there’s a lack of automatic adjustments for dividends and splits. Capitally does all these things right and the reporting is visually nice and quick."

Andries Zwikstra
Netherlands
"I currently have an active subscription with another tool, but I already know that I won't be renewing it.
Capitally takes data exploration to a whole new level, despite lacking some functionalities that will probably appear over time. Both as a programmer and a user, I love tools where intuitiveness is a high priority."

Paweł Gajda
Poland
"The game changer that Capitally brings is that it has a very high degree of customization when it comes to selecting assets and recording transactions. For me the differentiator is the ability to record transactions in a currency that differs from the asset currency. My investment portfolio spans multiple global markets and accounts and normal portfolio tracking tools just don't recognize the fact that I may be purchasing a given equity in more than one currency in different accounts."

Stuart Davidson
USA

No. Capitally never connects to your bank or broker through Plaid, Yodlee, or any other open-banking aggregator — brokerage and banking credentials stay with you. There's no shared password, no read-only API token, no third party in the data path. See data safety for the full encryption and hosting model.
Imports go through CSV, Excel, paste from a spreadsheet, or manual entry. Most major brokers — Interactive Brokers, Degiro, TastyTrade, Schwab, Coinbase, Kraken, XTB, and many others — have native CSV presets, so the first import is usually a single-file upload. For brokers without a preset, the flexible importer maps columns to Capitally's transaction model on the fly.
There's also a precision advantage. Aggregators typically expose only current balances, or transactions from the past ~3 months — they rarely surface the full account history. Broker CSV exports usually go back to the day the account was opened and include the events that move cost basis: corporate actions, dividend reinvestments (DRIP), deposits and withdrawals, FX conversions. With that detail intact, returns calculate correctly over the actual holding period, cost basis is auditable lot by lot, and the data is ready for tax filing — not just a dashboard. Manual entry preserves the same fidelity for assets that have no broker feed at all.
The tradeoff: there's no auto-sync, so importing a new month of activity is a deliberate action you take, not something that happens silently in the background. That's the right fit for advanced DIY and HNW investors who want privacy and the data depth a third-party feed can't deliver — not the right fit for someone who explicitly wants a one-click aggregator dashboard.
Yes. A single Capitally project can hold any number of accounts — each one a logical container for a broker account, bank account, pension, wrap account, or any other portfolio slice you want to keep separate. Name them however you like (Personal IBKR, Company Schwab, Trust Vanguard, Joint Saxo, IRA, ISA, IKE/IKZE, etc.). Reports filter by account, by asset class, by tag, or roll up into a single net-worth view across everything.
Liabilities (mortgages, margin loans, lines of credit) live in the same project as assets, so a true net-worth view nets debt against holdings. See Tracking Debt for the setup. Performance metrics — TWR, money-weighted return / IRR, FX attribution, cost basis — work at any level: per account, per filter, or for the entire portfolio.
When entities need to stay strictly separated (e.g. a personal portfolio and a company portfolio that must never mix in any report), use multiple projects and switch between them in the UI — same login, fully isolated data.
Time-weighted return (TWR) strips out the effect of when you added or withdrew money — useful when you want to judge your strategy and compare against a benchmark. Money-weighted return (MWR), also called IRR, includes the timing of your cashflows — useful when you want to judge your actual investor return, including whether you got the timing right.
A simple example: if you held an ETF that returned 10% on a $1,000 starting balance but added another $9,000 right before a 5% drawdown, your TWR is still positive (the strategy did fine), but your MWR is roughly negative (you lost money in absolute terms because of the timing). Both are correct; they answer different questions.
Capitally can compute both metrics, for every account, every asset class, and the whole portfolio. Use TWR to compare your strategy against the S&P 500, MSCI World, or any custom benchmark. Use MWR/IRR to see what the portfolio actually did for you, dollar in, dollar out. Switch between them right in the portfolio dashboard. For the full methodology breakdown, see measuring investment performance.
Both rates can also be discounted by a benchmark — that's a separate move from comparing side-by-side. Discount by a CPI series for your real (after-inflation) return; by S&P 500 or MSCI World for your alpha; by a 10Y government bond yield for your premium over a near-risk-free rate. The discount applies uniformly to TWR, IRR, and ROI, so all three move from "nominal" to "real" or "excess" together. See discounting by a benchmark for the mechanics.
Capitally supports six cost-basis methods: FIFO (first-in, first-out), LIFO (last-in, first-out), HICO (highest cost first), LOCO (lowest cost first), Manual specific-lot identification, and Average Cost Basis (ACB) with both Asset and Asset+Account pooling. You can configure the method per project, per account, per asset, or per position — the most specific setting wins. See cost basis methods for full details and worked examples.
Manual specific-lot identification is the basis for tax-loss harvesting: when you sell a partial position, Capitally lets you pick which lots to close, shows the realised gain or loss for each combination, and updates the remaining cost basis accordingly. The choice flows into the country-specific capital-gains report so the tax document reflects the actual lots you closed.
Multi-currency cost basis is preserved at the trade currency, so cross-border investors see both the local-currency realised gain (what the broker reports) and the base-currency realised gain (what their home tax authority cares about). Built-in tax presets for Canada, the UK, Germany and other jurisdictions wire the right method automatically — e.g. ACB with Section 104 same-day and 30-day matching for the UK.
Each transaction is recorded in the currency you paid in — USD trades stay in USD, EUR trades stay in EUR — and reconciled into your base currency at the FX rate of the trade date.
You can switch the viewing currency at any time, or make it depend on the section of portfolio you are viewing.
Returns are decomposed via FX attribution: the overall return splits into the capital gain of the underlying asset and the currency gain or loss from FX moves. A 12% USD-equity return translated to a 4% EUR-equity return is a different story than a 12% EUR-equity return — Capitally can show both halves separately so the FX impact isn't hidden inside the headline number.
Cash, dividends, and withholding tax all carry their original currency through, which makes life simpler at tax time for expats holding accounts in two or more countries. Native pricing covers 100+ currencies and exchanges across North America, Europe, APAC, South America, and beyond — see the supported markets and assets. You can change base currency later without losing the local-currency record.
Yes. Capitally is built and operated under GDPR. Servers and databases sit in EU data centres, and the underlying portfolio data is end-to-end encrypted on your device with AES-GCM — Capitally itself can't read it, so the GDPR data-minimisation and purpose-limitation principles are enforced at the cryptographic layer rather than just at the policy layer.
Export and permanent deletion are one-click operations inside the app, with no email or support ticket required. Export covers all your portfolio data - decrypted on your device, then saved as CSV, Excel, or JSON. Deletion permanently removes the encrypted store along with the surrounding metadata.
We don't transfer personal data outside the EU, don't sell or rent it, and don't run third-party advertising trackers on the app. See data safety for the encryption model, or the Privacy Policy for the full legal text.