How AirCapital handles information on the website and in the iOS and Android apps, and how you can exercise your rights.
1. Who is responsible
Tymofii Shkabrov, Norway.
AirCapital is the product name. The operator above is responsible for the processing described here. Contact: timofii.shkabrov@gmail.com. This policy covers aircapital.app and the AirCapital apps (package tim.AirCapital). Exchanges and app stores have their own responsibilities and privacy policies.
2. Your exchange data stays under your control
The apps store connected account labels, balances, asset allocations, portfolio history, deposits, withdrawals and related preferences locally. The trading journal also reads and stores executions, order and execution identifiers, open positions, realised profit and loss, fees, funding, import progress, and notes and tags you enter. The journal database uses SQLCipher with its encryption key held in secure storage only on this device. API credentials are also held in secure storage; other financial records are encrypted locally. We do not operate an AirCapital server that receives your exchange credentials or portfolio records.
When the app synchronises, it sends authenticated HTTPS requests directly to the exchange you selected using read-only access. The exchange receives the authentication information required by its API and your network IP address. Public Coinbase and Binance price endpoints may also receive requests and your IP address for currency conversion and historical valuation. Opening a trade price chart requests public candles from the contract’s exchange, or Binance spot as a USDT reference for spot inventory. These requests identify an asset pair or contract, a rounded time range and a candle interval; they do not include your quantities, account identifiers, notes or API credentials. These services process requests under their own policies.
The operating system may run journal synchronisation in the background. On iOS, credentials and local encryption keys remain tied to this device and can be accessed after its first unlock following a restart, so scheduled imports can run while the screen is locked. If notification permission is granted, the app schedules a local reminder to preserve trade history; it contains no amounts, account labels or transaction details. You can disable the reminder in the journal import settings. No remote push token or reminder server is used.
The operating system performs optional biometric authentication. AirCapital receives the authentication result, not your fingerprint, face image or biometric template. The website demo uses fictional portfolio data and does not accept exchange API keys.
3. What we process and why
App functionality: the local processing and direct exchange requests described above provide the monitoring service you request (Article 6(1)(b) GDPR). Connecting an exchange is optional; without it, you can use the demo. We do not use portfolio data for advertising or automated decisions about you.
Website delivery and security: our hosting provider Railway processes connection information such as IP address, request time, requested URL, browser information and response status to deliver pages, diagnose failures and protect the service. Our legal basis is our legitimate interest in providing a reliable and secure website (Article 6(1)(f)).
Support and privacy requests: if you email us, we receive your email address, message and anything you choose to attach, through our email provider Google. We use this to respond to your request, on the basis of providing requested support, our legitimate interest in resolving enquiries, or compliance with legal obligations for rights requests (Articles 6(1)(b), (f) or (c), as applicable). Please do not send API secrets, identity documents or complete portfolio exports unless a specific, necessary and secure process has first been agreed.
Optional analytics: only if you agree, Google Analytics on the website and Google Analytics for Firebase in the apps process pseudonymous browser or app-instance identifiers, visits or screen views, session and engagement events, device/browser/OS information, language and approximate location derived from network information. Website demo interactions and store-button clicks are also measured. App journal analytics records opening the journal and trade cards, saving a note, completed imports and reconciliation warnings. A completed import includes only a range for the number of closed trades stored for the account: 0, 1–9, 10–49, 50–199, 200–999 or 1,000+. It does not include the account identity or an exact count. Successful Pro purchases also include only their starting point: the journal or another screen. Purchase prices, plans, product identifiers and receipts are not sent with this event. Cancelled or pending checkouts and restored subscriptions are not counted as completed purchases. This uses consent (Article 6(1)(a)). Precise GPS location is not requested. We do not send account labels, balances, amounts, instrument names, individual transaction records, notes, tags, API keys, email addresses or a developer-assigned user ID to Analytics. Advertising identifiers and Google signals are disabled in our configuration.
Subscription processing
Versions with Pro subscriptions use RevenueCat to verify store purchases and provide paid access. It receives a pseudonymous app user identifier, product identifiers, purchase tokens or receipts, transaction and renewal dates, and subscription, cancellation, refund and billing status. The SDK also communicates technical information needed to process requests, including platform, app/SDK versions, locale and network connection information. We do not send RevenueCat your exchange keys, portfolio balances, account labels, email address or advertising identifiers. Apple or Google processes your payment details; AirCapital and RevenueCat do not receive your card details.
Purchase verification and entitlement management are needed to provide the plan you request (Article 6(1)(b) GDPR). Fraud prevention and aggregate subscription reporting support our legitimate interest in operating the service (Article 6(1)(f)). This billing processing is separate from optional Google/Firebase usage analytics consent; declining usage analytics does not disable purchases or restoration. We do not connect RevenueCat to advertising or cross-app tracking integrations.
Purchase records are retained as needed to maintain access, restore purchases, handle refunds and disputes, prevent fraud, and meet applicable legal obligations. Deleting local app data does not erase store or RevenueCat purchase records or cancel billing. Contact support for a proportionately verified deletion request; we will explain any records that must be retained. RevenueCat may process information outside the EEA under the applicable data processing agreement and transfer safeguards.
4. Your choice about analytics
On the website, the Google tag is blocked until you accept analytics. Accept and reject are both available. You can change your choice through Cookie settings in the footer. On iOS and Android, analytics collection is disabled by default and can be changed in Settings. The journal version asks again if your previous analytics choice did not cover journal events and Pro purchase origins; a previous refusal remains in effect. Declining does not prevent monitoring, use of the journal or use of the demo.
Withdrawal stops future analytics collection and clears the relevant website analytics cookies or resets the local app analytics identifier. It does not automatically erase events already sent to Google. Withdrawal does not affect the lawfulness of processing before you withdrew. Contact us about deletion of identifiable historical data; we may need limited information to locate a pseudonymous record, and do not collect extra identity data solely to identify it.
5. How long information is kept
Local portfolio and trading history, notes, tags and credentials remain on the device until you remove the relevant connection or use the app’s Delete all data action. Removing a connection also removes its journal records and import state; Delete all data removes the journal database and its encryption key. Different deletion actions have different scope; see the deletion guide. Clearing browser storage removes website preferences. Uninstalling an app alone may not remove secure-storage entries or copies managed by the operating system.
Website analytics consent is valid for 180 days before we ask again. Language preferences remain until changed or browser storage is cleared. Google analytics cookies have a default expiry of up to two years, which Google may refresh on use. Browsers may shorten this period.
Our Google Analytics property is configured for two months of event-level retention and 14 months of user-level retention, with the user period renewed on new activity. Google’s scheduled deletion processes apply; these controls do not limit the lifetime of aggregate reports. Provider security, billing and legal records may follow separate periods described in the provider’s policy.
We keep support messages while needed to resolve the enquiry and handle a related dispute or legal requirement. We review retained correspondence and remove messages no longer needed. Hosting logs are retained for the provider’s applicable operational retention period and, where necessary, for investigating a specific security incident. You can ask us for the current retention details applicable to your request.
6. Providers and international processing
Railway provides website hosting. Google provides optional website/app analytics and the email service used for support. Apple and Google provide app distribution and process store-related information under their own terms. Connected exchanges independently process your direct API requests. We do not sell personal data or run an advertising network in the app.
Providers may process information outside the EEA, including in the United States. Their contractual documentation describes applicable transfer mechanisms, such as adequacy decisions or standard contractual clauses, depending on the service and recipient. Contact us for details of the safeguards applying to processing on our behalf and how to obtain a copy. We do not promise that all provider processing takes place in the EU.
7. Your rights
Depending on the applicable conditions, you can request access, correction, deletion, restriction, portability, or object to processing based on legitimate interests. You may withdraw consent at any time. Send requests to timofii.shkabrov@gmail.com; you do not need to create an account or pay a fee for an ordinary request. We normally respond within one month. If a lawful extension is needed because of complexity or number of requests, we will explain it within that first month.
We may request proportionate verification when necessary to avoid disclosing someone else’s data. We cannot retrieve records stored only on your device or erase records held independently by an exchange. You may complain to the supervisory authority in your EEA country of habitual residence, workplace or the place of the alleged infringement. This does not require contacting us first.
8. Backups and security
Export is an action you control. The exported JSON contains portfolio information, account labels, journal executions, account movements, saved position snapshots, import progress, notes and tags, but not API keys or secrets. A journal CSV export contains the selected trades, amounts, notes and tags. The Share trade action creates an image on your device containing only the instrument, direction, return percentage and duration. It does not contain monetary amounts, quantities, account labels, notes or tags. You choose its destination in the operating system sharing menu. Exported files are not encrypted by AirCapital. The temporary sharing file is removed when sharing finishes; copies you save or share remain under your control and the recipient’s rules. Protect those copies and delete them separately when no longer needed.
Device encryption, secure credential storage, HTTPS and optional biometric protection reduce risks but do not eliminate them. Protect your device, use read-only exchange keys, and revoke compromised keys at the exchange. No support request should require you to reveal an API secret.
9. Children, decisions and changes
AirCapital is a portfolio monitoring utility and is not directed specifically at children. Exchange account eligibility is governed by each exchange and applicable law. If you believe a child has sent us personal information without the required permission, contact us so we can assess and address it.
We do not make solely automated decisions producing legal or similarly significant effects about you. Changes to this policy will be dated on this page. We will seek new consent where a change to optional processing requires it.