Privacy Policy

Tilo currently runs without user accounts. Everything you create in the app — portfolios, virtual trades, follows, your profile draft, your theme preference — is stored locally on your device and is never transmitted to us. We use no analytics, no advertising trackers, and no third-party embeds. The only personal data that reaches our infrastructure are the technical server logs that any website produces.

The controller for any processing described here is the operator of Tilo. Contact for all privacy matters: m.heitsch@mobydigg.de. Full legal-entity details (name, postal address) will be added before public launch.

a) Data that stays on your device

Portfolios you create, virtual trades you record, profiles and portfolios you follow, your profile draft, and your light/dark theme choice are stored in your browser’s local storage. This data never leaves your device and we have no access to it. Clearing your browser data deletes it permanently.

b) Server logs (hosting)

The site is hosted on Vercel. When you visit, standard web-server logs are produced: IP address, date and time of the request, requested URL, referrer, and browser/OS identifier (user agent). We use these logs solely to operate the site securely and diagnose faults (legal basis: Art. 6(1)(f) GDPR — legitimate interest in a secure, functioning service). Logs are retained only for a limited period and are not merged with any other data. Vercel acts as our hosting processor under a data processing agreement.

c) No cookies requiring consent, no trackers

We set no analytics or marketing cookies and use no tracking pixels. Fonts and other assets are self-hosted — no requests to third-party CDNs. Your theme preference is kept in local storage on your device only. Because only technically necessary storage is used, no consent banner is required (§ 25 TDDDG).

d) Public-figure data shown in the product

The platform descriptively tracks public statements and public regulatory filings (e.g. 13F filings, congressional trade disclosures, public posts) of investors and public figures. We process names and the content of those public sources to build virtual tracking portfolios (legal basis: Art. 6(1)(f) GDPR — legitimate interest in reporting on publicly disclosed financial activity of persons acting publicly). If you are such a person and want your profile removed, contact us at the address above and we will handle the request promptly.

We are preparing optional user accounts. None of the following processing happens today; this section describes what is planned so the picture is complete. Before accounts go live, this policy will be updated and the changes highlighted.

• Sign-in with Google: authentication via Google OAuth using only the basic scopes (account identifier, email address, profile name). Google is a recipient of the sign-in request; no access to Gmail, Drive, or other Google data is requested.
• Email sign-in and notifications: magic-link login and transactional emails sent via Resend as a processor. No marketing emails without a separate opt-in.
• Database: account data (profile, follows, published portfolios) stored with Neon in the EU (Frankfurt region) under a data processing agreement.
• Deletion: accounts will be self-service deletable, with hard deletion within a defined grace period and documented backup expiry.

You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection to processing based on legitimate interest (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future. You also have the right to lodge a complaint with a data protection supervisory authority.

To exercise any of these rights, email m.heitsch@mobydigg.de. Note that for data stored only on your device (section 2a) we hold no copy — you control and delete it directly in your browser.

We do not use your data for automated decision-making or profiling within the meaning of Art. 22 GDPR.

We will update this policy whenever the actual processing changes — in particular before accounts launch. The effective date at the top always reflects the current version.