Privacy Policy
Summary: SimSwan uses accounts and secure cloud storage so your portfolio simulator data follows you across devices. This policy explains what we store, where it is stored, who processes it, and how you can access, export, or delete it.
SimSwan ("the Application", "we", "us") is an independent analytics and simulation tool for convex and tail-risk hedging research. This Privacy Policy explains how personal data is collected, used, stored, and shared when you use the Application.
1. Data Controller
The data controller responsible for your personal data is:
- Controller: AY, an individual developer trading as SimSwan
- Registered address:
[Registered address to be confirmed] - Contact:
support@simswan.com
A company may be registered in the future. If the controller changes, this policy will be updated before any data is processed under the new entity.
2. What We Collect
We collect only the data needed to operate your account and the simulator.
Account data
- Email address and password (the password is stored only as a secure hash by our authentication provider; we never see your plain password)
- Optional profile details such as display name and strategy label
Portfolio and simulator data
When you save or sync a portfolio, we store the position and trade records you enter or upload. This can include ticker, option type (put/call), strike, expiry, premium, contract quantity, action, trade date, closing price, calculated P&L, and any notes you add.
Settings and preferences
App settings and preferences you choose, so they can be restored when you sign in again.
Provider API keys (optional)
If you supply a third-party market-data API key (for example a Polygon key), it is stored server-side in an encrypted secrets vault. Keys are used only to perform the data requests you configure and are never displayed back in full.
Technical and diagnostic data
We do not run invasive tracking and we do not sell personal profiles. Standard technical data (such as anonymised crash reports or operating system version) may be collected by the Google Play Store or the hosting network solely to diagnose stability and security issues.
3. Local Processing
Some inputs and interactions are processed entirely on your device — for example on-screen simulation computations, local preference caching, and the cached dashboard snapshot used for fast startup. Session credentials are stored securely on your device so you can stay signed in; on supported Android devices you may optionally protect a remembered session with biometric unlock.
4. Why We Use Your Data (Lawful Bases under UK GDPR)
| Purpose | Lawful basis |
|---|---|
| Creating and managing your account; providing the simulator and cloud portfolio storage | Performance of a contract |
| Securing the service, preventing abuse, diagnosing faults, maintaining service integrity | Legitimate interests |
| Optional features you explicitly enable (for example biometric unlock, or supplying a provider API key) | Consent / performance of a contract |
| Complying with legal, tax, and regulatory obligations | Legal obligation |
5. Sub-Processors and Third Parties
We use the following service providers to operate the Application. They process data only on our instructions.
| Provider | Role | Data involved |
|---|---|---|
| Supabase | Cloud hosting, authentication, database, and encrypted secrets storage (sub-processor) | Account data, portfolio and trade records, settings, provider API keys, session tokens |
| Google Play | App distribution, store billing, and platform-level diagnostics | Distribution/technical data; payment data is handled by Google, not by us |
| Email provider | Support mailbox and transactional email routing | Your email address and the contents of messages you send us |
| Market-data providers | Market, chain, and pricing data used for analysis | Request parameters only; no personal account data is sent |
If you follow external links from within the Application, those third-party sites operate under their own privacy practices. We encourage you to review their policies.
6. International Transfers
Cloud infrastructure may store or process your data outside the United Kingdom. Where data is transferred internationally, we rely on appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to standard contractual clauses offered by our providers.
7. Data Retention
- Account and portfolio data is retained while your account is active.
- If you delete your account, your personal data and portfolio records are deleted from live systems, and removed from backups within the provider's standard backup rotation window.
- We may retain limited records where required by law (for example financial or tax records), for as long as the law requires.
8. Your Rights (UK GDPR)
You have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate or incomplete data;
- Erase your data ("right to be forgotten");
- Restrict or object to certain processing;
- Data portability — receive your data in a structured, commonly used format;
- Withdraw consent at any time where processing is based on consent.
To exercise any of these rights, contact support@simswan.com. If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.
9. Account and Data Deletion
You can delete your account and associated data directly in the Application from the account settings. You may also request deletion by emailing support@simswan.com. Deleting your account removes your profile, stored portfolio records, settings, and stored provider API keys. This action cannot be undone.
10. Security
Data is encrypted in transit using TLS. Access to your stored records is restricted to your account (row-level security), passwords are stored only as hashes, and provider API keys are held in an encrypted secrets vault. No method of transmission or storage is completely secure, but we apply industry-standard safeguards and fail-closed behaviour on authentication and storage paths.
11. Children
The Application is intended for adults aged 18 years or over. It is not designed for, and we do not knowingly collect data from, children. If you believe a child has provided us with personal data, contact us and we will delete it.
12. Changes to This Policy
We may update this policy as the Application evolves. Material changes will be reflected in the "Last updated" date above, and where appropriate you will be notified in-app or by email.
13. Contact
For any questions, requests, or feedback regarding this Privacy Policy or your data, contact:
Email: support@simswan.com