Privacy Policy

Controller

The data controllers are Cedric Borgers and Massimiliano Nicol, operating finclearity as an unincorporated student prototype in Lugano, Switzerland. Contact:

admin@finclearity.ch

Data We Process

• Account data: name, email address, password hash, email verification status, profile image if supplied, user role, account creation and update times.
• Authentication data: session tokens, session expiry, IP address, user agent, and account security data.
• Learning data: lesson progress, exercise attempts, scores, XP, streaks, daily goal settings, achievements, gems, and review status.
• Simulator data: educational simulator positions, simulated trades, prices, gem transactions, and related timestamps.
• Waitlist data: email address, access status, invite email status, and related timestamps.
• Notification data: browser push endpoint and cryptographic subscription keys if you enable reminders.
• Technical data: request logs, device/browser information, language preference cookie, local app preferences, and security-relevant diagnostics.

Purposes

• To provide login, lessons, progress tracking, simulator features, reminders, and waitlist communication.
• To protect the service, prevent misuse, debug errors, and keep audit records.
• To respond to legal, privacy, support, and feedback requests.
• To improve educational content and prototype usability using aggregated or limited operational data.
• To comply with legal obligations and preserve or defend legal claims.

Cookies and Local Storage

finclearity uses necessary authentication/session cookies, a language preference cookie, and local storage for app preferences such as onboarding, lesson hints, swipe hints, and daily goals. We do not currently use advertising cookies or third-party analytics cookies.

Recipients

Personal data may be accessed by the operators and technical administrators. The application is hosted on a VPS provided by Hetzner in Germany, where hosting, database, authentication, logs, and related technical processing may take place. Personal data may also be processed through email or university infrastructure and browser push services. We do not sell personal data.

International Access

finclearity is operated from Switzerland. Hosting is provided on a Hetzner VPS in Germany, so service data may be processed in Switzerland and Germany. The service may be accessed from other countries; where processing or access involves another country, we rely on appropriate safeguards or statutory exceptions where required.

Retention

We keep account, learning, simulator, and waitlist data for as long as needed to operate the prototype, handle requests, meet legal obligations, and preserve evidence. We delete or anonymise data when it is no longer needed. You may request deletion unless we must retain data for legal or security reasons.

Your Rights

Subject to applicable law, you may request information about your personal data, correction, deletion, restriction or objection to processing, and a copy of data you provided. Contact admin@finclearity.ch. You may also contact the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch.

Children

finclearity is intended for users aged 18 or older. Do not use the service or join the waitlist if you are under 18.