Privacy policy

1. Data controller

The data controller and website operator is Individual Entrepreneur Bakurov Pavel Andreevich (OGRNIP 321508100472902, INN 503623289407), doing business under the My Portfolio and Farious brands. Privacy requests, personal-data claims, and legally significant electronic notices may be sent to support@my-portfolio.ru. The person responsible for organizing the processing of personal data is the Individual Entrepreneur identified above; you can reach this person at support@my-portfolio.ru.

The Vendor's registered address for legally significant notices is 142105, Podolsk, Podolskikh Kursantov St. 2, apt. 34; the consumer support phone is +7 916 650-96-53; and consumer support business hours are Mon-Fri, 10:00-19:00 MSK. The Vendor was registered by the Interdistrict Inspectorate of the Federal Tax Service No. 23 for the Moscow Region. The Individual Entrepreneur is a personal-data operator. Details of inclusion in the Roskomnadzor register of personal-data operators and the registration number are published on the Requisites page.

2. What we collect

We collect only the data that is needed to operate the service. The categories are:

Account data: your email address, a salted hash of your password, your display name (if you set one), your interface language, and the timestamp of account creation and last login. When you sign in with Google, we receive from Google your Google account identifier, email address, its verification status, and display name; your Google password is never shared with us.

Billing records: Credit top-ups, balance, reservations, charges and their purposes, payment status, invoice identifiers, and paid cloud periods. Records of previously purchased subscriptions are also retained. Card numbers and bank details are handled exclusively by our payment processor and never reach our servers.

Cloud strategy records: if you choose to upload a private strategy, strategy version, assignment metadata, or publication request to My Portfolio cloud features, we store the content you submit, the related account id, timestamps, moderation status, and publication-review history. Cloud strategy storage is optional for private storage convenience and publication review. Paid cloud automation, under which we run your trading node on our servers, is offered under the current Terms of Service; the data we process when you run a portfolio under cloud automation is described in the portfolio-statistics section below. Do not include broker credentials, broker tokens, passwords, or secrets in strategy content.

Security telemetry: the IP address and User-Agent header of requests to our website, the time of each request, outcomes of authentication events, and a device fingerprint used to verify session ownership - browser language, platform, time zone, and screen parameters. The IP address and User-Agent are kept only in server logs. This data is used to detect abuse and to investigate security incidents.

Functional cookies: a first-party __Host-pm_user HttpOnly session cookie and a first-party __Host-pm_csrf antiforgery cookie. After a Google sign-up creates an account, a client-readable first-party pm_google_registration_completed marker records only that completion fact, contains no identity or provider token, is deleted on the first application load, and expires after five minutes. These items are strictly necessary for the related website flows.

Optional analytics storage: if you accept analytics, the website loads Yandex Metrica to measure website and workspace page usage, selected CTA goals, product funnel behavior, and to measure and optimize Yandex Direct campaigns. Yandex Metrica may process standard browser identifiers and technical visit/session data through cookies, localStorage, and sessionStorage on the My Portfolio domain and, unless Restricted mode is enabled in the Yandex counter, on Yandex Metrica domains. For the analytics-consent goal, custom parameters contain only the goal name, language, and broad site area. We do not send Yandex account identifiers, broker data, portfolio data, order IDs, payment amounts, credentials, form values, or raw error details. Webvisor and session replay, click maps, automatic link tracking, form analysis, advertising retargeting, advanced matching, and ecommerce collection are disabled in every analytics mode.

Optional desktop or native-client telemetry: when enabled, the My Portfolio application may send diagnostic crash reports and aggregate uptime counters. Telemetry never includes broker credentials, broker tokens, order details, trade history, or portfolio composition. You can disable telemetry from the application's settings.

Support correspondence: messages you send to support@my-portfolio.ru, and the content of any tickets you open. We retain this material for as long as it is needed to resolve your request and to defend against later disputes.

Support tickets: when you submit a ticket from the "Support requests" profile section, from an assistant card, or through a connected AI agent, we process its category, title, and description, the source it was sent from, the page and app version, the related portfolio, strategy, or backtest if you gave one, its status, the operator's reply, and the creation and reply times. Operators read the ticket to answer it; the reply appears in the profile section and arrives in your Inbox. An assistant conversation is attached to a ticket only if you tick "Attach this conversation": a copy of the latest messages of the conversation is then stored with the ticket and read by operators. A ticket from a connected AI agent is sent by the agent on your behalf; no conversation is attached to it. Do not put tokens, passwords, or other secrets in a ticket.

Assistant conversations: if you write to the assistant in the workspace, we process your messages, the assistant's replies, the cards it proposes - such as strategy and portfolio-setup drafts - the workspace page each message was sent from, and message timestamps. To answer, the assistant reads only the data of your account that the request needs: portfolios, strategies, broker connections without tokens, backtests, and Credit history. This data is processed by the assistant only when you send it a message. Do not paste tokens, passwords, or other secrets into messages: the assistant replaces secret-like strings with the marker [скрыто] (hidden), but it cannot reliably recognize every secret.

Connected AI agents: if you connect your own AI agent to My Portfolio through the consent page or a personal access token, we process the connection record: the agent client's name, its redirect address, the granted permissions, the daily Credit cap, and the dates of creation, last use, expiry, and revocation, together with hashes of the issued tokens; we do not keep the tokens themselves after issuing them. For every agent request we record the connection, the name of the tool called, and the time of the call. The agent receives only the account data it requested by calling a tool within the granted permissions; broker tokens are never sent to it.

Broker connections under cloud automation: we do not request broker passwords or broker session cookies. The broker API token you submit through the protected broker-connection flow is stored encrypted in a dedicated credentials service and used only to operate your trading node; it is deleted when you delete the broker connection or the account. Do not include tokens in support messages or strategy content. The platform processes connected cloud portfolio data, including NAV, cash balances, positions, commissions, and cash movements, as described in section 11. Statements that trading data stays only on your device do not apply to cloud automation.

Public, special-category, and biometric data: My Portfolio is not intended to collect special categories of personal data, biometric personal data, criminal-record data, or personal data permitted for distribution. Please do not upload any of that data. The same applies to third-party personal data, identity documents, medical information, photographs used for identification, broker secrets, and similar materials: do not put them into strategy content, support messages, or publication requests. If a future feature publishes your name, profile, strategy attribution, or other personal data to an unlimited audience, we will request separate consent for personal data permitted for distribution and let you define permitted categories, restrictions, and conditions before publication.

3. Analytics cookies and storage

Analytics are optional. Rejection is never delivered to Yandex and does not limit account, cloud automation, billing, workspace, or trading-related website functionality.

Analytics cookies and storage are set only after an affirmative analytics-consent action. Before consent, we do not load Yandex Metrica or set Yandex analytics identifiers. The browser stores a versioned record containing the decision, decision time, current policy version, and random consent-generation ID. Separately, our first-party endpoint increments an identity-free aggregate counter by server date, decision, locale, broad site area, and policy version; it receives no ClientID, account ID, cookie, or credentials. In addition, we store a record of every decision in a server-side consent log: the random consent-generation ID, the decision, the policy version, the date and time, the language, and the broad site area. That record contains no account ID, Yandex ClientID, IP address, cookie, or credentials and serves as evidence that consent was given or withdrawn.

You can accept, reject, or change analytics later from cookie settings.

Authenticated workspace analytics are optional pseudonymous usage analytics. They may include coarse section names and billing-intent goals, but never account identifiers, amounts, session replay, click maps, or form values.

When analytics consent and offline attribution are both enabled, a credit top-up checkout may temporarily store the Yandex Metrica ClientID and a random consent capability on our server. For an eligible first settled credit top-up, we send Yandex exactly three offline-conversion fields: the goal identifier subscription_bought_first_time, the occurrence date and time, and the ClientID. We do not send an account or order identifier, payment amount, currency, email, name, or payment-method data.

Withdrawing analytics before the conversion is claimed for external submission queues suppression of that consent generation and removes eligible local attribution. Once the claim has committed, a transfer may already be in flight and Yandex provides no per-conversion recall. A one-way hash of the random consent capability, containing no ClientID or account or order identity, is retained for at most 30 days to prevent a late request from reintroducing withdrawn attribution. The internal user-and-order uniqueness record follows the retention of its owning billing record and is never transmitted to Yandex.

pm_analytics_consent_guard: provider My Portfolio; purpose strictly necessary first-party cookie that binds the versioned browser record to persisted consent; content limited to the decision, current policy version, and current or displaced random consent ID; duration at most 400 days; never sent to Yandex; consent status not required because this guard stores the consent choice.

_ym_uid: provider Yandex Metrica; purpose analytics browser identifier; duration 1 year; consent status set only after analytics consent.

_ym_d: provider Yandex Metrica; purpose first visit/date metadata; duration 1 year; consent status set only after analytics consent.

_ym_isad: provider Yandex Metrica; purpose ad-blocking or availability signal; duration 20 hours; consent status set only after analytics consent.

_ym_metrika_enabled: provider Yandex Metrica; purpose tag availability signal; duration 60 minutes; consent status set only after analytics consent.

gdpr: provider Yandex Metrica; purpose technical detection of visitors subject to GDPR; duration up to 2 years; consent status set only after analytics consent.

4. Lawful basis for processing

For users to whom the General Data Protection Regulation applies, we rely on the following lawful bases under Article 6 GDPR: performance of a contract (Art. 6(1)(b)) for everything required to deliver paid services, run the website, provide the desktop or native client, and operate optional cloud strategy features; legitimate interests (Art. 6(1)(f)) for security telemetry, fraud detection, abuse prevention, support, and enforcement of our terms, balanced against your rights and freedoms; legal obligation (Art. 6(1)(c)) for retention of billing records and responses to lawful authorities; and your consent (Art. 6(1)(a)) for optional analytics storage and any optional marketing channel, which you can withdraw at any time without affecting the lawfulness of past processing.

For users whose personal data is governed by Russian Federal Law No. 152-FZ "On Personal Data", we process personal data on the basis of contract performance for paid services and software delivery, on the basis of legal obligations, to protect lawful interests where permitted, and on the basis of consent where consent is required. Where we rely on consent under Federal Law No. 152-FZ, consent is requested separately from the Terms of Service, this Privacy Policy, and other confirmations; it must be specific, informed, conscious, unambiguous, and recorded in a form that allows us to prove receipt. Refusing or withdrawing optional consent, including analytics consent, does not affect strictly necessary account, cloud automation, billing, security, or software-delivery functions.

5. How we use your data

Account data is used to authenticate you and to associate your credit balance and service access with your sessions. Billing records are used to issue invoices, take payments through the payment processor, record Credit top-ups, charges, paid periods and cancellations, and meet tax and accounting obligations. Cloud strategy records are used to store your private strategies, support versioning, support publication review when you request it, moderate unlawful or abusive content, and operate any hosted-node workflow that requires a cloud strategy copy. Security telemetry is used to rate-limit abusive traffic, block credential-stuffing attempts, and investigate security incidents. Support correspondence is used to answer your questions and resolve disputes.

We may use and retain limited account, billing, security, support, and cloud strategy records where needed to enforce these terms, investigate fraud or market-abuse reports, comply with lawful requests from courts, regulators, tax authorities, payment providers, brokers, or exchanges, or defend legal claims.

We do not sell personal data. We do not share personal data with advertisers. We do not profile users for marketing purposes.

6. Sub-processors and third parties

We use a small set of sub-processors to operate the service. They process data on our instructions, under written agreements with confidentiality and security obligations:

Payment processor: payments are handled on our behalf by the regulated payment service provider OOO NKO YuMoney (brand YooKassa), INN 7750005725, OGRN 1127711000031, Bank of Russia licence No. 3510-K, address 115035, Moscow, Sadovnicheskaya St. 82, bldg. 2. We receive payment status and invoice identifiers; the payment processor receives the data needed to take the payment.

Email delivery: transactional messages - verification codes, password resets, receipts, service notices - are sent through the Selectel Mail Service operated by JSC Selectel (INN 7810962785, OGRN 1247800067790, address: 196006, Saint Petersburg, Tsvetochnaya St. 21, lit. A); the provider receives the email address and the message content.

Hosting and infrastructure: the website, APIs, and databases are hosted by the Russian hosting provider JSC Selectel (INN 7810962785, OGRN 1247800067790, address: 196006, Saint Petersburg, Tsvetochnaya St. 21, lit. A) in data centers located in the Russian Federation. The provider receives only the network traffic needed to serve requests.

Analytics provider: Yandex Metrica is loaded only after analytics consent to measure website and workspace page usage, selected CTA goals, and product funnel behavior and to measure and optimize Yandex Direct campaigns under the restrictions described in Section 3.

Sign-in provider: if you choose to sign in with Google, your browser contacts Google LLC directly, and Google processes that request under its own privacy policy. We receive from Google only the data listed in section 2 and do not send Google your account, subscription, broker, or portfolio data.

Assistant: when you write to the assistant, your message, the earlier messages of that conversation, and the account data the assistant reads to answer are sent to RouterAI, a routing service for language-model requests provided by OOO Inter. RouterAI routes requests only to model providers that process the data in the Russian Federation. Replies are generated by the GigaChat language model provided by PJSC Sberbank. Until you write to the assistant, these services receive none of your data; broker tokens are never sent to them.

AI agents you connect yourself: we do not run a language model for an agent you connect, and we do not engage its provider as our processor. When the agent calls a tool, the account data it requested is transferred at your initiative to the agent provider you chose, for example Anthropic or OpenAI. That provider processes the data under its own terms and privacy policy and may process it outside the Russian Federation; we do not control that processing. Until you connect an agent, no such transfers take place. You can revoke an agent's access at any time in the Connected agents section of your profile: after revocation no new data is sent to the agent, while data already transferred stays with its provider under the provider's rules.

Broker and third-party services: when the desktop or native client connects to your broker directly, that connection is governed by the broker's own terms and privacy documents, and we do not receive broker credentials. Under cloud automation, the broker API token is stored by us as described in section 2 and used only for your trading node's calls to the broker API. If a feature later requires us to transmit data to a broker, exchange, identity provider, or compliance provider, we will disclose that feature-specific transfer before enabling it.

We will publish material changes to the list of sub-processors on this page before they take effect. The categorical list above is the current scope.

7. Data retention

Account data is retained for as long as the account exists. You can request account deletion from your profile settings or by writing to support@my-portfolio.ru from the email address associated with your account; once the request is confirmed, we delete or anonymize account data, cloud strategy records, broker connections, and portfolio statistics within 30 days. Billing documents and records needed for tax and accounting obligations, dispute resolution, and defense of legal claims are kept after account deletion for the period required by law.

Server logs containing the IP address and User-Agent are retained for 30 days and then deleted automatically. The account event log - sign-up, acceptance of legal documents, logins, billing changes, and consent records - is retained while the account exists and for no more than 3 years after its deletion to defend legal claims. Support correspondence, including tickets, operator replies, and an attached conversation copy, is retained for up to 3 years from last activity. Backups follow the same retention schedule and are rotated out on their own cycle.

Optional desktop or native-client telemetry, when enabled, is retained in aggregated form only; individual reports are processed and aggregated within 30 days.

Assistant conversations - messages, replies, and proposed cards - are retained for 30 days from each message and then deleted automatically. You can delete a conversation earlier; its content is deleted immediately.

Records of connected AI agents and personal access tokens are retained while the account exists and are deleted with it; revocation ends a connection or token immediately. The log of agent tool calls - connection, tool name, and call time - is retained for 30 days and then deleted automatically.

Raw offline-attribution ClientID and consent-capability values are deleted when they are transferred, suppressed, or reach the upload deadline, no later than 20 days and 22 hours after capture. The one-way anti-reintroduction hash is deleted within 30 days.

When a processing purpose is achieved, or when consent is withdrawn and no other legal basis requires retention, we stop processing and delete the relevant personal data, or ensure deletion by a processor, within 30 days unless a different period is required by law or by a contract with the data subject.

8. International data transfers

Russian data localization: when we collect personal data of citizens of the Russian Federation, including through the Internet, recording, systematization, accumulation, storage, clarification, and extraction of that data are performed using databases located in the Russian Federation. We do not perform those primary operations using databases located outside the Russian Federation except in cases expressly permitted by Federal Law No. 152-FZ. Any later cross-border transfer, if required, is performed only after Russian-localized collection and only under the cross-border-transfer procedure described in this section.

Cross-border transfers: if a feature or processor requires transfer of personal data from Russia to another country, we first identify the destination country, recipient, purposes, data categories, subject categories, and safeguards. Before starting such activity, where required by Federal Law No. 152-FZ, we notify Roskomnadzor separately of the intended cross-border transfer and obtain from the foreign recipient information about its confidentiality and security measures and conditions for terminating processing. For countries that are not recognized as providing adequate protection, we do not start the transfer until the statutory waiting period has expired and no prohibition or restriction has been issued. If Roskomnadzor prohibits or restricts a transfer, we stop the transfer and ensure destruction of previously transferred personal data by the foreign recipient where required by law.

Transfers at your initiative to an external AI agent: if you connect your own AI agent, the data it requests is transferred at your initiative to the agent provider you chose and may be processed outside the Russian Federation. Your choice of agent determines the recipient and the country of processing; we do not choose them, and we send the agent data only in answer to its requests within the access you granted. If you do not want the data processed outside the Russian Federation, do not connect such an agent, or revoke its access.

For transfers from the European Economic Area, we use the European Commission's Standard Contractual Clauses or another mechanism recognized under applicable law.

9. Security

We protect your data with TLS-encrypted transport, salted password hashing using a current industry-standard algorithm, key-rings managed under platform data-protection APIs, and strict access controls on production systems. Where the product encrypts any broker-related material for transport, we use a split-key architecture so that neither side alone can decrypt it.

No system is perfectly secure, and we describe our protections as a reasonable effort, not a guarantee. If you believe your account has been compromised, write to support@my-portfolio.ru and we will work with you to contain the incident.

If we discover unlawful or accidental transfer, disclosure, provision, or access to personal data that violates data-subject rights, we notify Roskomnadzor within 24 hours with the known circumstances, likely causes, likely harm, mitigation steps, and incident contact, and within 72 hours with the results of the internal investigation and information about responsible persons where available. Where the affected systems are connected to the Internet, we also notify the State System for Detecting, Preventing, and Eliminating the Consequences of Computer Attacks (GosSOPKA) as required by law.

10. Your rights

Subject to applicable law, you have the right to access the personal data we hold about you, to ask us to correct inaccurate data, to ask us to delete data we no longer need, to restrict or object to certain processing, to receive a copy of data you provided in a portable format, and to withdraw any consent you previously gave. To exercise any of these rights, write to support@my-portfolio.ru from the email address associated with your account.

Russian-law request procedure: for requests governed by Federal Law No. 152-FZ, we provide access information or a reasoned refusal within 10 working days after receiving the request. We may extend this period once by up to 5 working days by sending a reasoned notice. A request should identify the data subject or representative, confirm the relationship with My Portfolio or another fact of processing, and include a signature; an electronic request may be signed with an electronic signature under Russian law. If you provide evidence that personal data is incomplete, inaccurate, outdated, unlawfully obtained, or no longer needed for the stated purpose, we correct or delete it within 7 working days and notify you of the action taken.

If you believe we have processed your data unlawfully, you may complain to a competent supervisory authority. In the Russian Federation this is the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor). In the European Economic Area this is the data protection authority of your country of residence. We would prefer that you raise the issue with us first so we can address it.

11. Portfolio statistics for cloud-automated portfolios

If you run a portfolio under cloud automation, the platform collects data derived from that portfolio's state so that we can show statistics and charts back to you. This derived data covers portfolio net asset value (NAV), cash balance, per-instrument holdings, fees, and cash flows, pulled from the trading node operating your cloud-automated portfolio. We collect this data only to provide your own portfolio statistics and performance charts; we do not use it to build marketing profiles, and we do not sell or share it with advertisers.

This statistics data is owner-scoped: it is accessible only to you, the owner of the portfolio, and is never made available to other users. We protect it with the same transport encryption, access controls, and production-system safeguards described in the Security section.

Where we store it: portfolio statistics are kept in a dedicated statistics store separate from your account and billing records. Retention is purpose-based: short-interval (intraday) samples are retained for approximately 90 days to support recent detailed charts, while daily series are retained for as long as the portfolio and the account exist so that your long-term portfolio history remains available to you; they are deleted when the portfolio or the account is deleted.

Your rights over statistics data: the access, correction, and erasure rights described in the "Your rights" section apply to your portfolio statistics. A per-user erasure path exists for the dedicated statistics store, so you can request deletion of your statistics history. To exercise these rights, write to support@my-portfolio.ru from the email address associated with your account.

12. Children

My Portfolio is not intended for users under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has created an account, write to support@my-portfolio.ru and we will remove the account.

13. Changes to this policy

We may update this policy from time to time. Material changes will be announced on this page and, where the change affects users of paid services, by email. The effective date at the top of this document indicates when the current version took effect.