Privacy Policy

1. Who we are

The data controller for your personal data is NovaHub B.V., registered with the Dutch Chamber of Commerce (KVK) under number 92194923, with its registered office in Eindhoven, the Netherlands. You can reach us at support@novahub.nl for any privacy question or to exercise your rights.

2. What data we process

We process the following categories of personal data:

We do not ask for, and do not want, any data we do not need to run the service. We do not knowingly collect special categories of data (such as health or biometric data).

3. Why we process it (legal bases)

We rely on two legal bases under Article 6 of the GDPR:

4. How AI is used

Volnar uses AI to help you understand your portfolio. When you ask a question or open an insight, the relevant portfolio context (such as your holdings and recent changes) is sent to our AI provider, Anthropic, so the model can read it and explain it in plain language. Data sent to Anthropic through the API is not used to train their models.

Importantly, the AI does not perform your calculations. All financial figures — totals, returns, allocations, FX conversions — are computed by deterministic code on our side. The AI only parses and explains; the numbers come from the maths, not the model.

5. Who we share data with (subprocessors)

We use a small number of trusted providers to run Volnar. Each only receives the data it needs for its specific purpose:

We do not sell your personal data, and we do not use it for advertising.

6. Where your data is stored

Your account and portfolio data are stored in the European Union (the Supabase EU region). Where a provider processes data outside the EU, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

7. How long we keep it

We keep your data for as long as your account exists. When you delete your account, we delete your associated personal and portfolio data. Limited records may be retained for a short period where we are legally required to, after which they are removed.

8. Cookies

We use only the cookies needed to keep you signed in (session and authentication cookies). Our analytics is cookieless — it does not set tracking cookies and does not build an advertising profile of you. We do not use third-party advertising or cross-site tracking cookies.

9. Your rights under the GDPR

You have the right to:

To exercise any of these rights, email support@novahub.nl. You also have the right to lodge a complaint with your local data protection authority. In the Netherlands this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority).

10. Changes to this policy

We may update this policy as the service evolves. When we make material changes, we will update the “last updated” date above and, where appropriate, notify you in the app.