Effective Date: 08-11-2026
We are committed to protecting Your privacy. This Privacy Policy describes how We collect, use, store, share and protect the information collected through Capitally (mycapitally.com and related websites, media, applications and services, collectively the “Service”).
The Personal Data Administrator is CAPITALLY p.s.a. ul. Kłopot 4/59, 01-066 Warsaw Poland, operator of Capitally ("We", "Us", and "Our").
If you have questions or concerns regarding this policy or if you need to make a request please contact us at: contact@mycapitally.com.
This Privacy Policy is incorporated into and subject to Our Terms of Service. Capitalized words used but not defined in this Privacy Policy have the meaning given to them in the Terms of Service.
Please be advised that the practices described in this Privacy Policy apply only to information gathered online through the Service. This Privacy Policy applies where We are acting as a data controller with respect to the Personal Data of visitors, users, clients and customers (“You” or “Your”); in other words, where We determine the purposes and means of the processing of that Personal Data.
PLEASE READ THIS PRIVACY POLICY CAREFULLY because it affects Your rights under the law. You confirm that You have read and agreed to be bound by this Privacy Policy. If You do not agree with this Privacy Policy, You cannot use, access, create or publish in the Service. This Privacy Policy may change as We continuously improve the Service, so please check it periodically.
We reserve the right to modify or amend the Privacy Policy from time to time without notice. Your continued use of the Service following the posting of changes to these terms will mean You accept those changes. If We intend to apply the modifications or amendments to this Privacy Policy retroactively or to Personal Data already in Our possession, We will provide You with notice of the modifications or amendments.
We strive to provide you with the best possible service. In order to provide this service we may need to collect information from you from time to time. At all times we try to only collect the information we need for the particular function or activity we are carrying out and use it in accordance with this privacy policy.
We collect two basic types of information from You from Your use of the Service: Personal Data and Non-Personal Data.
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
As a general matter, You can browse the Service without submitting Your Personal Data to Us. However, there are a number of circumstances in which You may supply Us with Your Personal Data.
We collect the following Personal Data from You:
The following are the most common ways in which You give Your Personal Data:
When You interact with the Service or Your Account through a social media platform, such as Facebook, Twitter, Tumblr, LinkedIn, YouTube, or Pinterest, We may collect the Personal Data that You make available to Us on that page including Your account ID or handle. We will comply with the privacy policies of the corresponding social media platform and We will only collect and store such Personal Data that We are permitted to collect by these social media platforms.
If You choose to sign in to Your Account with Google, Google shares Your name, e-mail address and account identifier with Us, and learns that You signed in to Capitally. With Your consent, We also may share information about You and Your activities, including what Your name, town, what You view on the Service, with that social network's users.
Please do NOT supply any other person's Personal Data to Us, unless We prompt You to do so.
We do NOT sell or license Your Personal Data to any third party.
We may process any of Your Personal Data identified in this Privacy Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, Your legal rights and the legal rights of others.
In addition to the specific purposes for which We may process Your Personal Data set out in this clause, We may also process any of Your Personal Data where such processing is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
Specifically, We use Your Personal Data for the following:
We may share your Personal Data with the following:
Payment Services Providers. Financial transactions relating to Our Service and Services are OR may be handled by Our payment services providers. We will share Transaction Data with Our payment services providers only to the extent necessary for the purposes of processing Your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Our Payment Service Providers are:
Third-Party Suppliers. We may disclose Your Personal Data to the third-party suppliers below for the purpose of providing You the Service. Each one receives only what its purpose needs. "Location" is where the supplier stores or processes the data for Us.
Hosting and infrastructure
Communication
Analytics and error reporting
AI
Advertising services – Google Ads and Reddit Ads, on this website only and only with Your consent; see section 15.4.
Other recipients
Other Purposes. In addition to the specific disclosures of Personal Data set out in this Section, We may disclose Your Personal Data where such disclosure is necessary for compliance with a legal obligation to which We are subject, or in order to protect Our vital interests, Your vital interests, or the vital interests of another natural person. We may also disclose Your Personal Data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Personal Data that We process for any purpose shall not be kept for longer than is necessary for that purpose or those purposes. These are the periods that apply:
In other cases it is not possible for Us to specify in advance the periods for which Your Personal Data will be retained. In such cases, We will determine the period of retention based on our legitimate interests, namely the proper administration of Our Service and business.
Notwithstanding the other provisions of this Section, We may retain Your Personal Data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.
We do not use AI on the data in Your projects. The application never sends Your transactions, holdings, amounts or notes to an AI model, and We do not use Your data to train AI models.
AI touches Your Personal Data in two places only:
The application's Export for AI feature creates a file on Your device. It sends nothing to Us or to any AI provider; what You do with the file is up to You.
We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in Our possession. This includes, for example, firewalls, password protection, multi-factor authentication, encryption (in-transit and at-rest) and other access and authentication controls.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information You transmit to Us or store on the Service, and You do so at Your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards. If You believe Your Personal Data has been compromised, please contact Us at contact@mycapitally.com.
If We learn of a security systems breach, then We attempt to notify You electronically so that You can take appropriate protective steps. We may post a notice through the Service if a security breach occurs.
In the application, the contents of a project – transactions, assets, accounts, amounts and notes – are encrypted in Your browser with AES-256-GCM before they are sent to Us. The key is derived from a password with PBKDF2-SHA256. Who holds the key depends on the encryption mode You choose for each project:
If You lose the password of a project encrypted with Your User Password or a Project Password, We cannot recover its contents.
Some information stays readable to Us in every mode, because the Service needs it to work: Your account details, project names, the number of accounts, assets and transactions in a project, and the type and time of each change. Requests Your device makes for market data are logged for security purposes only, and those logs are deleted after a limited time.
Files You attach to a project, such as custom icons, are encrypted with their own key stored inside the encrypted project. Your profile photo is not encrypted.
Non-Personal Data includes information that does not personally identify You, but may include tracking and usage information about Your location, demographics, use of the Service and the internet.
When You interact with the Service, We may collect Non-Personal Data and Our servers may automatically keep an activity log of Your use of the Service.
We may disclose or share Non-Personal Data (or other information, other than Personal Data) in any other manner that We deem appropriate or necessary.
Among other things, We will disclose Non-Personal Data to third parties to help Us determine how users use parts of the Service so We can improve the Service.
We will also disclose Non-Personal Data to Our partners and other third parties about how Our users collectively use the Service.
We collect and store Your device’s source IP address which may disclose the location of Your device at the time You access the Service. Where You have not consented to analytics, We count visits with a short hash of Your IP address and browser identification instead of a cookie.
We may process Your Account Data ("Account Data"). The Account Data may include Your name and email address. The source of the Account Data is You. The Account Data may be processed for the purposes of operating Our Service, providing Our Services, ensuring the security of Our Service, maintaining back-ups of Our databases, usage analytics and communicating with You. The legal basis for this processing is a contract between user and you or taking steps at user request to enter a contract.
We may process information that You post for publication through Our Service ("User Content Data"). The User Content Data may be processed for the purposes of enabling such publication and administering Our Service. The legal basis for this processing is a contract between user and you or taking steps at user request to enter a contract.
We may process information contained in any enquiry You submit to Us regarding Our Goods and/or Services ("Enquiry Data"). The Enquiry Data may be processed for the purposes of offering, marketing and selling relevant Goods and/or Services to You. The legal basis for this processing is consent.
We may process information relating to Our customer relationships, including customer contact information ("Customer Relationship Data"). The Customer Relationship Data may include Your name, Your contact details, and information contained in communications between You and Us. You are the source of the Customer Relationship Data. The Customer Relationship Data may be processed for the purposes of managing Our relationships with customers, communicating with customers, keeping records of those communications and promoting Our Goods and Services to customers. The legal basis for this processing is Our legitimate interests, namely the proper management of Our customer relationships.
We may process information relating to transactions, including purchases of Goods and Services, that You enter into with Us and/or through Our Service (“Transaction Data”). The Transaction Data may include Your contact details, and/or the transaction details. The Transaction Data may be processed for the purpose of supplying the purchased Goods and Services and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the proper administration of Our Service and business and a contract between user and you or taking steps at user request to enter a contract.
We may process information that You provide to Us for the purpose of subscribing to Our email notifications and/or newsletters ("Notification Data"). The Notification Data may include Your name and email address. The Notification Data may be processed for the purposes of sending You the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.
We may process information contained in or relating to any communication that You send to Us ("Correspondence Data"). The Correspondence Data may include the communication content and metadata associated with the communication. Our Service will generate the metadata associated with communications made using the Service contact forms. The Correspondence Data may be processed for the purposes of communicating with You and record-keeping. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our Service and business and communications with users.
If You are a citizen of the EU, We have summarized the rights that You have under the General Data Protection Regulation (GDPR) in this Section. Some of the rights are complex, and not all of the details have been included in Our summaries. Accordingly, You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Right to Access. You have the right to confirmation as to whether or not We process Your Personal Data and, where We do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. Providing the rights and freedoms of others are not affected, We will supply to You a copy of Your Personal Data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
Right to Rectification. You have the right to have any inaccurate Personal Data about You rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about You completed.
Right to Erasure. In some circumstances You have the right to the erasure of Your Personal Data without undue delay. Those circumstances include: the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the Personal Data have been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
Right to Restrict Processing. In some circumstances You have the right to restrict the processing of Your Personal Data. Those circumstances are: You contest the accuracy of the Personal Data; processing is unlawful but You oppose erasure; We no longer need the Personal Data for the purposes of Our processing, but You require Personal Data for the establishment, exercise or defense of legal claims; and You have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, We may continue to store Your Personal Data. However, We will only otherwise process it: with Your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
Right to Object to Processing. You have the right to object to Our processing of Your Personal Data on grounds relating to Your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in Us; or the purposes of the legitimate interests pursued by Us or by a third party. If You make such an objection, We will cease to process the Personal Data unless We can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to Our processing of Your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If You make such an objection, We will cease to process Your Personal Data for this purpose.
You have the right to object to Our processing of Your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to Your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Right to Data Portability. To the extent that the legal basis for Our processing of Your Personal Data is consent, or that the processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means, You have the right to receive Your Personal Data from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
Right to Complain to a Supervisory Authority. If You consider that Our processing of Your Personal Data infringes data protection laws, You have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so at UODO - Polish Personal Data Protection Office.
Right to Withdraw Consent. To the extent that the legal basis for Our processing of Your Personal Data is consent, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of Your rights in relation to Your Personal Data through written notice to Us. See Our Contact Details at the beginning of this Policy.
If You are located in the European Economic Area, Your Personal Data will be processed by Us. We store and process it in the European Union. Only the suppliers listed in section 8 process some of it outside the European Economic Area, and such transfers will be completed in compliance with relevant Data Protection Legislation.
When We process Personal Data in the course of providing the Service, We will:
In this Section, We provide information about the circumstances in which Personal Data of citizens of the European Union may be transferred to countries outside the European Economic Area (EEA).
All Your financial data resides on European Union infrastructure. The servers and databases of the Service are located in the European Union: Google Cloud in Belgium, Railway in the Netherlands, MongoDB Atlas and Vercel in Germany, file storage in Cloudflare's EU jurisdiction, and analytics in PostHog's EU region.
The following suppliers may process some of Your Personal Data outside the EEA, in the United States or the United Kingdom:
Transfers to the United Kingdom rely on the European Commission's adequacy decision for the United Kingdom. Transfers to the United States rely on the European Commission's adequacy decision for companies certified under the EU-U.S. Data Privacy Framework or on standard data protection clauses adopted or approved by the European Commission. A copy of the standard protection clauses adopted or approved by the European Commission can be obtained through: ec.europa.eu
You acknowledge that Personal Data that You submit for publication through Our Service or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
The legal basis for this processing is Our legitimate interests, namely the proper administration of Our Service and business and communications with users.
In general, if You register on the Service, You may update the information You have provided to Us.
When You register on the Service, You may be able to indicate Your preferences regarding marketing communications. You may be able to change those preferences and select the categories of communications that interest You.
You will not be able to opt-out of receiving certain service-related or transactional communications relating to the Service unless You cancel Your registration or subscription.
Even after Your account is cancelled, We may retain Your information for the purposes and periods set forth in section 2.6.
We provide You with reasonable access to the Personal Data that You may provide through the Service.
At any time, You may legitimately object to the processing of Your Personal Data, except if otherwise provided by applicable law. You may decline to share certain Personal Data with Us, in which case We may not be able to provide to You some of the features and functionality of the Service.
You may update, correct, or delete Your Account Data and preferences at any time by accessing Your Account settings page on the Service. If You wish to access or amend any other Personal Data We hold about You, or to request that We delete any information about You that We have obtained from an Integrated Service, You may contact Us. Please note that while any changes You make will be reflected in active user databases instantly or within a reasonable period of time, We may retain information You submit for backups, prevention of fraud and abuse, and satisfaction of legal obligations, for the periods set forth in section 2.6.
We will however retain Your information needed for administrative and transactional communications.
If You are a California resident, California Civil Code Section 1798.83 permits You to request and obtain from We, information regarding the disclosure of Your Personal Data to the third parties for direct marketing purposes in the preceding calendar year, free of charge, once a year.
We do not share Your Personal Data with third parties for those parties' direct marketing use. For more information about Our privacy and data collection policies, You may wish to review Our Privacy Policy.
California residents, who are under 18 and are registered users of We, are allowed to request and have removed, any content or information that they have posted publicly. However, in cases where the law does not require or allow the removal of information, this may not be applicable. This is under California Business and Professions Code Section 22581.
We do not knowingly collect Personal Data from children under 13 years of age in the USA or 16 years of age in the European Union. The Service is not directed to children under the age of 13 in the USA or 16 in the European Union. We will not knowingly allow children under 13 in the USA or 16 in the European Union to register for or become users of the Service.
If You are under 13 in the USA or 16 in the European Union years of age, You should not provide Personal Data to Us.
If We discover that a child under the age of 13 in the USA or 16 in the European Union has provided Us with Personal Data and We do not have parental consent, We will immediately delete that child’s information.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but Personal Data that We store about You may be linked to the information stored in and obtained from cookies.
This section covers cookies and similar technologies, such as local storage and scripts that send data to third parties. When You first visit, We ask You to choose which of the purposes in sections 15.2 to 15.4 You allow. You can change Your choice at any time in the cookie settings of the website or the application.
Essential cookies are necessary for Capitally to function properly. These cookies ensure basic functionalities and security features of the Service.
Due to their core role in enabling certain essential functions on Capitally, You may not disable these types of cookies. If You choose to do so, it may affect Your ability to access and use the Service properly.
Please note that your consent to the use of essential cookies is not required under GDPR law because these cookies are necessary for the legitimate interest pursued by Us, which is to ensure the proper functioning of Capitally.
Essential cookies are used for the following purposes:
Additionally, the projects you view within the application will be synced to your browser's local storage. If your project is encrypted, it will remain encrypted in your browser's local storage. If you choose to remember the encryption key, it will be stored in your browser's local storage as well.
Functionality cookies allow us to remember choices that have been made by you in order to create an experience that’s made to fit.
If you do not allow these cookies, we won't be able to persist your choices and some functionalities may not work the way You want them to.
In accordance with GDPR law, We request Your explicit consent before these types of cookies are placed on Your device. If you wish to withdraw or give Your consent at any time, you may do so by altering Your cookie settings on our Service.
Functionality cookies are used for the following purposes:
Analytical cookies allow us to collect information, such as the most used pages, typical user journeys or error messages, in order to understand how you use our Service and enable us to create a better user experience.
If you do not allow these cookies, we won't be able to collect information about how You use the Service and may have trouble assisting You in case of issues.
In the application, We use PostHog only:
On this website:
Analytical cookies are used for the following purposes:
Marketing cookies may be placed on your device by us or by our advertising partners when you visit our website. We use these cookies to promote our Service on other websites and to measure the effectiveness of our advertising campaigns.
Our use of marketing cookies involves the following:
Scope of Use
Your Consent and Control
In accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), we will request your explicit consent before placing these types of cookies on your device. The Google Ads tag and the Reddit Pixel load only after You allow marketing cookies. You have the right to withdraw your consent or update your cookie preferences at any time. This can be done by adjusting your cookie settings, typically available through a cookie management tool or banner on our Service.
Advertising Platforms We Partner With
Our website uses the tags of the following advertising platforms:
The Service may contain links to other sites operated by Our affiliates or third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these other sites. We are not responsible for the actions and privacy policies of third parties and other sites.
Please remember that any information You share in public areas, such as message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what You disclose and do not post any Personal Data that You expect to keep private. Please consult the applicable guidelines, if any, for use of Our chat rooms and other community areas for more information.
Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which We may update from time to time. If We modify the Privacy Policy, We will make it available through the Service, and indicate the date of the latest revision. Any material changes will be posted on this Service and will come into effect 30 Days after their posting.
In the event that the modifications materially alter Your rights or obligations hereunder, We will make reasonable efforts to notify You of the change. For example, We may send a message to Your email address, if We have one on file, or generate a pop-up or similar notification when You access the Service for the first time after such material changes are made. If You do not refuse the changes in writing before they become effective, this shall mean that You have consented to the Privacy Policy as changed. Your continued use of the Service after the revised Privacy Policy has become effective indicates that You have read, understood and agreed to the current version of the Privacy Policy.
We may change Our ownership or corporate organization while providing the Service and Services. We may also sell certain assets associated with the Service. As a result, please be aware that in such event, We may transfer some or all of Your information to a company acquiring all or part of Our assets or to another company with which We have merged. Under such circumstances We would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, We cannot promise that an acquiring company or the merged company will have the same privacy practices or treat Your information the same as described in this Privacy Policy.