Privacy Policy
Last updated: 1 October 2026 · Switzerland, Germany and Austria
1. Controller
PhinLabs Markus Egolf (sole proprietorship), Glärnischstrasse 52b, 8712 Stäfa, Switzerland, is responsible for processing your personal data under the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR). Email: [email protected]. UID: CHE-264.993.452.
2. In brief
InvestPhin is an app on your Mac. Your portfolio (holdings, transactions, accounts, retirement assets, notes) is stored on your device. If you switch on «Web and phone», you can also open it in the browser or on your phone; an end-to-end encrypted copy then sits in our mailbox, which we cannot read (see section 10). Otherwise only the licence check, Phin AI requests (only if you use Phin), waitlist sign-ups and, if you set it up, access without code by email and password (section 10) reach our servers. We do not sell data, use no advertising trackers and create no profiles.
3. This website
investphin.com runs on a server of Hetzner Online GmbH in Germany, behind Cloudflare, Inc. (USA) for protection and delivery. Both process technically necessary data such as IP address, time and requested page; Cloudflare may set short-lived, strictly necessary cookies (e.g. __cf_bm against bots). We use no analytics or advertising services. Fonts are served from our own server. Legal basis: legitimate interest in secure operation (Art. 6(1)(f) GDPR).
4. Waitlist
If you join the waitlist, we store your email address, language, time and two random links (confirm, unsubscribe) in our database in Germany. We send the confirmation email from [email protected] via Zoho (EU data centre). You are only on the list after clicking the link (double opt-in). Unconfirmed entries are deleted automatically after 30 days. Every email contains an unsubscribe link. We use your address only to tell you when InvestPhin launches. Legal basis: your consent (Art. 6(1)(a) GDPR), revocable at any time.
5. Licence check (desktop app)
To check your licence, the app talks to our licence server (api-licenses.investphin.com, Hetzner, Germany). On activation it sends the licence key, a device identifier (a non-reversible checksum of computer name, operating system and user name), your Mac's device name, the app version and the operating system. At every start it checks key and device identifier. We store your IP address only shortened (last block removed). Licence and registered devices are kept while the licence exists; the activation log (licence key as checksum only, IP shortened) is deleted after 90 days. Legal basis: contract (Art. 6(1)(b) GDPR). The free version without a licence performs no licence check.
6. Phin AI
Phin AI is optional; the app asks for your consent before the first use. With every question our licence server receives your question, the recent messages of the conversation, your saved Phin notes and a summary of your portfolio (values, holdings, dividends; accounts without names or IBAN). The server forwards this, without licence key or device identifier, to an AI model: usually Google Gemini (Google LLC, USA; processing may also take place outside the EU), for demanding questions Anthropic Claude via Amazon Web Services Bedrock in the EU (Frankfurt). According to the terms of Google for paid use and of AWS, your requests are not used for training; Google keeps them for a limited time to detect abuse. Per request we store time, device identifier, model, token count and cost, the licence key only as a secret keyed checksum; the first 40 characters of your question for 30 days, everything else for 13 months (quotas and cost control). Of the answers we keep only checksums, no text, for 180 days. Legal basis: consent (Art. 6(1)(a) GDPR); you can withdraw it in the settings at any time.
7. Crisis protection
If Phin detects signs of an acute crisis (e.g. suicidal thoughts, gambling addiction, debt emergency), the app replies only with contacts of official support services and calls no AI model. We only log that this happened (without the content of your message) and delete the entry after 30 days.
8. Prices and market data
Your Mac fetches prices, exchange rates and company information directly from the providers, not via our server. The providers see your IP address and the requested security (ticker, ISIN), but no quantities, values or your name. Without consent the app only contacts OpenFIGI (ISIN to ticker), Frankfurter/European Central Bank (exchange rates), services for which you enter your own API key (e.g. Financial Modeling Prep, Finnhub, Polygon, Twelve Data, Alpha Vantage) and company logos at Financial Modeling Prep and Finnhub. Further sources (e.g. Yahoo Finance, Investing.com, justETF) are used only after you explicitly switch them on; they are off by default.
9. Data on your Mac
Your portfolio, settings, Phin conversations and API keys you enter are stored unencrypted in the app profile on your Mac and in the automatic backups (JSON files) the app creates there. Protect your Mac with a password and disk encryption (FileVault). If you copy a backup elsewhere, you decide who can see it.
10. Web and phone (mailbox) and cloud storage
You can optionally switch on «Web and phone» in the settings. You then open your portfolio at investphin.com/app in the browser or on your phone, and your Mac supplies the prices and data. For this, a mailbox runs on our server at Hetzner in Germany: it passes messages between your browser and your Mac and keeps the latest state of your data. Everything is end-to-end encrypted (AES-256-GCM) with a key that exists only on your devices; we cannot read or alter the contents. We only see a random-looking room number derived from the key, plus the size and time of messages. We do not log connections to the mailbox (no IP addresses). A stored state is deleted once nobody has accessed it for 180 days, or immediately on request. Pairing works via QR code or link; the key is only in the #-part of the link, which is not sent to servers, and is stored in the browser of the paired device. Your Mac fetches the prices itself, as described in section 8; our server does not fetch prices. Optionally the app also or instead places an encrypted copy in a folder of your own cloud (iCloud Drive, Dropbox, OneDrive); your cloud provider's terms then apply to that file. If no Mac is connected, the browser only fetches exchange rates, directly from Frankfurter/European Central Bank, with ExchangeRate-API and open.er-api.com as fallbacks; they see your IP address but no portfolio data. Phin AI works in the browser through your Mac: your questions travel encrypted through the mailbox to your Mac and from there as described in section 6. Access without code (optional): if you set up access with email and password on your Mac, we store your email address, a salt, a sign-in proof additionally protected with scrypt, the connection code encrypted with a key that can only be derived from your password, and the time of the last sign-in and failed attempts. Your password and the connection code never reach us in plain text; without your password we cannot decrypt the code or reset a password (only your Mac can). We send the confirmation email via Zoho (EU data centre). Legal basis: contract or your consent by switching it on (Art. 6(1)(a) and (b) GDPR); you can switch it off at any time in the settings.
11. Recipients and countries
We use these service providers: Hetzner Online GmbH (Germany, servers), Cloudflare, Inc. (USA, website protection and delivery), Zoho Corporation (EU data centre, email), Google LLC (USA, Phin AI) and Amazon Web Services EMEA SARL (Luxembourg, Phin AI in Frankfurt). Transfers to US providers rely on the EU-US and Swiss-US Data Privacy Frameworks where the provider is certified, otherwise on standard contractual clauses. We disclose no other data unless required by law.
12. Retention
Waitlist: until you unsubscribe (unconfirmed: 30 days). Licence and devices: while the licence exists. Activation log: 90 days. Phin AI log: 13 months; first 40 characters of the question: 30 days; answer checksums: 180 days. Mailbox (web and phone): encrypted latest state until 180 days after the last access. Access without code: until you delete it on your Mac (unconfirmed: 7 days). Crisis notes: 30 days. Accounting records once there are payments: 10 years (legal requirement).
13. Your rights
You can request access, correction or deletion, object to processing, withdraw consent and receive your data in a common format. Write to [email protected]; we reply within 30 days. You may also complain to a supervisory authority — in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in Germany the authority of your federal state, in Austria the Datenschutzbehörde.
14. Security
All connections to our servers are encrypted (TLS). Licence keys appear in our logs only as checksums, IP addresses only shortened. Access to our servers is limited to what is necessary; requests are rate-limited to prevent abuse.
15. Changes
If the way InvestPhin processes data changes, we update this policy. The version published here applies. We inform licence customers of material changes by email. In case of doubt, the German version prevails.
Privacy questions: [email protected]