Privacy notice
Updated 24 October 2026 · Pre-launch version. This notice describes the current service. Controller identity/contact disclosures, provider transfer arrangements and parts of the retention and deletion process remain incomplete; live purchases are not open.
1. Who is responsible for your information
Portfolio Score is operated by a sole trader trading as Portfolio Score. That operator is the data controller for personal information used to run this website and its account, analysis, support and billing services. This notice is not the privacy policy of a creator who promotes the site or of a website reached through an external link.
For a privacy question, rights request or complaint, contact us through the Contact page. You do not need a paid plan to make a request. If the Contact page says sending is unavailable, the contact service has not been enabled; a working privacy contact must be available before launch.
2. Information we use and why
What we receive depends on whether you browse, create an account, analyse a portfolio, contact us or make a purchase. The table identifies the purpose and UK data-protection basis for each activity; a purchase does not give us unrestricted permission to use your information.
| Information | Purpose | Lawful basis |
|---|---|---|
| Account identifier, email and necessary profile/sign-in details | Create your account, recognise you and provide requested account features | Contract, including steps you request before entering a contract |
| Portfolio names, tickers, weights, entered values, benchmarks, score methods and settings | Run the analysis you request, restore your workspace and keep your saved portfolios | Contract |
| Analysis results, proposals, Builder and Manual tests, score history, data dates and coverage | Show results and changes over time, support verified saves and investigate calculation errors | Contract; legitimate interests in reliability and preventing misuse |
| Portfolio Check PDF, verified primary account email and report delivery records | When report email is enabled, send your completed Check to you and prevent duplicate deliveries. Delivery records include the Check reference, attempt dates and email-provider message reference. | Contract for requested report delivery; legitimate interests in reliable delivery and preventing duplicates |
| Order, billing details, plan, credits, offers, payment status, invoices, refunds and disputes | Provide purchased access and resolve billing requests; keep records required for accounting and tax; investigate fraud | Contract for delivery; legal obligation for required records; legitimate interests in preventing fraud |
| Guest purchase reference, payment email, checkout-security token digest and eventual verified account link | Let you pay before signing in, automatically create an unverified account using the confirmed payment email if needed, send its verification code, recover your purchase and securely link access after verification. A checkout email alone does not authenticate an account. | Contract for the requested purchase; legitimate interests in security and preventing unauthorised claims |
| Chosen creator referral, purchase reference, qualifying amounts and commission adjustments | Apply your offer and reconcile partner commissions without sharing your private portfolio | Contract for the requested offer; legitimate interests in accurate partner accounting and abuse prevention |
| Session, technical request and error information, which may include IP address and device/browser details; security counters | Protect sign-in, investigate errors, prevent spam and control excessive or unauthorised use | Legitimate interests in security, availability and fault diagnosis |
| Blocked custom-score PDF download attempts: pseudonymous account identifier, date, score type and a random attempt identifier | Understand demand for custom-score reports and prioritise product development. This log contains no portfolio holdings, names, values, email addresses or IP addresses. | Legitimate interests in understanding use of requested features and improving the service |
| Public page and journey-stage statistics through Vercel Web Analytics, including product/referral information and provider-derived visitor, referrer, approximate location and browser/device statistics | Understand interest in our public Home, guides, demo, pricing and checkout experience. We remove page-URL queries/fragments and exclude private destinations; we do not send portfolio inputs, account identifiers or emails through this integration. These statistics do not verify that a particular visitor purchased. | Legitimate interests in understanding service demand and improving the public experience |
| Contact messages, reply details and complaint/request records | Answer enquiries and service complaints; handle privacy rights and legal claims | Contract for account/service help; legitimate interests in responding to other enquiries; legal obligation for data rights |
The contact form sends your email address, optional name, subject and message to our private support inbox using Resend. It does not automatically attach your account or portfolio. We use security counters based on keyed hashes of the submitting IP address and email to limit spam.
We use legitimate interests for the specific operational purposes listed above, not as permission to sell your holdings or send unwanted advertising. You can object to that processing; see section 9.
Account and portfolio inputs needed for a requested feature are necessary to provide it. If you do not provide them, we cannot supply that feature. A contact-form name is optional. Please limit messages to the information needed to answer your question.
3. Where the information comes from
You provide holdings, settings and support messages. Our sign-in provider gives us an account identifier and the profile details needed to recognise you; a chosen social sign-in provider may give it details under its own notice. Stripe gives us the payment and subscription status needed to deliver access and handle support. FMP supplies market and company data, not your submitted transaction history. Our systems generate scores, proposals, usage and history records from those inputs.
We do not ask for brokerage passwords or bank-login credentials to score a portfolio. Portfolio holdings may be personally sensitive to you even when they are not a special category of personal data under UK law. Please do not send passwords or full card details to support.
The service is intended for adult retail investors and is not directed at children. If you believe a child has supplied personal information, contact us so we can investigate.
4. Providers and other recipients
- Clerk provides sign-in, email verification and account sessions. After a confirmed guest purchase, we send it the payment email to create an unverified account if one does not already exist; purchased access is linked only after verification.
- Vercel hosts the site and server functions and may hold operational request logs. When Web Analytics is enabled, it also processes the limited public-usage statistics described here.
- Neon stores account, portfolio, analysis and billing records.
- FMP receives server-side market-data requests, including security symbols, requested dates and our service credentials, to supply company and market information. Shared benchmark and market caches avoid repeating the same provider requests for each user.
- Stripe hosts checkout and processes payment and subscription information. We store payment identifiers and status, not your complete card number.
- Resend delivers contact form messages to our support inbox when the form is enabled. When Portfolio Check report email is enabled, it also receives your verified primary account email and completed PDF attachment to deliver the report to you.
Information is handled by the operator and service providers according to their role. Payment, authentication and other providers may also use information for their own security or legal obligations under their own notices. We may disclose necessary records to professional advisers, where required by law, or to establish or defend a legal claim.
A chosen creator offer is recorded with your purchase. Commission statements can include an order reference, product, date, amounts and refund adjustments; these are still transaction-related information even without your name. Creators are not given your account email, private portfolio or card details through the normal referral/statement flow. We do not sell customer portfolio data to creators or advertising brokers.
5. Cookies and information on your device
Clerk uses cookies or similar storage for authentication and account security. Stripe may use storage on its hosted checkout to complete a requested payment and prevent fraud. Our site uses browser storage for the active analysis, a short-lived saved-list cache, theme, benchmark, layout and device-local Builder preferences. Some of that locally stored information can reveal portfolio holdings to another person using the same browser profile. Use a private device and clear browser storage if you share a computer.
| Storage | Purpose and duration | Your control |
|---|---|---|
| Clerk session/security cookies and related storage | Sign-in and account security. Exact cookie names and lifetimes depend on the active Clerk configuration and have not yet been verified in the launch browser inventory. | Sign out or use browser cookie controls; blocking necessary storage can prevent sign-in. |
| Stripe hosted-checkout storage | Requested checkout and payment security. Stripe’s active storage inventory and lifetimes still need verification. | Browser controls and Stripe’s own privacy settings/notices; blocking storage can prevent payment. |
Guest checkout cookie (ps_guest_ followed by an order reference) | Essential security and recovery for a purchase made before sign-in. HttpOnly, SameSite=Lax, Secure on HTTPS; expires after 30 days. Only a token digest is stored on our server. Account access still requires a matching verified email. | Browser cookie controls. If removed, use your purchase link and verify the checkout email, or contact us for recovery; do not pay again. |
| Active analysis and pending/saved-portfolio browser caches | Restore your workspace without another calculation. The saved-list cache is reused for up to 60 seconds; that reuse limit does not itself erase the stored copy. Other workspace records can remain until replaced or cleared. | Clear this site’s browser storage. This removes local copies, not the separately saved server portfolio. |
| Unscored portfolio drafts and purchase-return markers | Keep entered stocks, allocations and optional transactions through sign-in and payment. Drafts are reusable for seven days and are cleared after successful scoring. Separate local markers prevent reopening a payment receipt from repeatedly starting a calculation; those markers contain no holdings. | Use Clear in the stock list or clear this site’s browser storage. These drafts do not synchronise across devices; expired local copies may remain until the next access or browser cleanup. |
| Theme, benchmark, sector basis, layout and Builder preferences | Remember your selected presentation and device-local workspace settings until replaced or cleared. | Change the setting or clear this site’s browser storage. |
A creator offer is carried in a link and associated with a purchase; the current referral design does not add a separate anonymous tracking cookie. This does not mean the website is cookie-free. Browser controls can remove cookies and local storage, but may sign you out or delete an unsaved workspace. Local copies can remain independently of account or server-record deletion.
When enabled, Vercel Web Analytics measures the limited public experience described above without tracking cookies. It derives a visitor hash from incoming requests rather than receiving our account identity, and its visitor session is discarded after 24 hours. It can report referrer, approximate location and browser/device information. Our integration honours Do Not Track and Global Privacy Control and does not send your private portfolio or purchase-recovery details. Hosting/security logs and necessary sign-in/payment storage are separate. See Vercel’s analytics privacy information.
Optional advertising or marketing trackers are not part of the processing described here. If non-exempt optional storage is introduced, its purpose and any legally required consent and withdrawal controls must be provided before it is used. The precise cookie inventory and classification of stored preferences remain a launch check; this notice is not a substitute for a required consent control.
6. How long we keep information
- Account, saved portfolios and history: retained to supply your account and saved-result features. Removing an eligible portfolio removes it from the saved feature; it is not the same as erasing every operational record or backup. Fixed purchased Checks have different editing controls, but those controls do not remove your data-protection rights.
- Calculation and proposal records: kept to serve results, validate ownership, prevent duplicate use and investigate errors. Temporary non-Check calculation inputs stop being reusable after 30 days and are scheduled to be cleared from 40 days after calculation. Purchased Checks, saved results, generated proposals and active calculations are protected. The scheduled cleanup still requires live verification; backup retention can delay complete removal of old copies.
- Billing and commission records: retained as necessary for accounting, tax, refunds, disputes and legal claims, including after a subscription ends. The final statutory periods and automated retention schedule are not yet configured.
- Support messages and security records: needed to resolve the enquiry or incident and any follow-up dispute. Email-provider, mailbox, operational-log and backup periods still need verification; no fixed deletion period is represented as enforced.
- Portfolio Check report delivery: a small delivery record remains with the Check to prevent repeat emails. Temporary recipient and message-fingerprint fields are cleared after accepted delivery is recorded. Email-provider and mailbox copies are separate; their retention and the final delivery-record retention schedule still need verification.
- Custom-score report demand: raw attempts are kept for up to 180 days, with older entries removed on the next successful scheduled maintenance run. Local development and preview traffic are separated from live usage. The pseudonymous account identifier remains personal data and is included when handling an account-data request.
- Public-usage analytics: Vercel discards its request-derived visitor session after 24 hours; this is not a promise that all aggregate statistics disappear then. Analytics reporting retention depends on the active provider configuration and plan and still requires launch verification. We do not maintain a separate visitor-counter database or link these statistics to your portfolio.
- Retired-feature records: older transaction and email-preference records can remain in the database even though their features have been retired. They must be included when handling an account-data request.
We consider the purpose, continuing account use, legal recordkeeping, unresolved complaints and backup recovery when deciding what must be retained. There is not yet a verified, end-to-end self-service account-erasure process. Ask us about access or deletion; we must assess the request and explain any lawful retention, rather than assume a subscription cancellation deleted everything.
7. Processing outside the UK
Our providers can process or store information outside the UK, including in the United States. The application’s Neon database was last verified in the US East region on 29 September 2026. That observation does not establish the location of every provider, log, backup or subprocessor.
The active providers’ contractual transfer arrangements have not yet been fully verified for this service. We therefore do not claim that a particular adequacy decision or standard contract already covers every transfer. Before this notice can be treated as launch-complete, the applicable transfer safeguards and how to obtain information about them must be recorded. You can request the available location and safeguard information through the Contact page.
8. Security and automated analysis
We use account authentication, access checks, server-side market-data requests and owner-filtered saved records to protect the service. No internet service can promise absolute security. Tell us promptly if you suspect that your account or saved information has been accessed without permission.
We use deterministic formulas to combine available return, risk and diversification measures according to the selected scoring weights. Proposal and testing tools assess hypothetical allocations under that model. Missing inputs and coverage affect which measures can be used. These are automated analytical outputs for your review, not FMP-supplied scores or trades executed on your behalf. The tools do not assess creditworthiness, execute investment decisions or guarantee outcomes. See Custom Scores for the scoring explanation and Terms for the service limitations.
9. Your rights and choices
Subject to the conditions in applicable law, you can request access to personal information, correction, erasure, restriction of processing and a portable copy of eligible information. An erasure request may not cover records that must lawfully be retained; we will explain any exception. Account settings or a locked Check do not override these rights.
Right to object: you can object to processing based on legitimate interests because of your particular situation. We will consider your objection and stop the processing unless an applicable legal reason permits it to continue. If we rely on consent for a future optional purpose, you can withdraw it without affecting earlier lawful processing.
Send requests through the Contact page. No special form or paid account is required. We may ask for proportionate information where needed to confirm identity, but not for your password or complete payment-card details. We will respond without undue delay, normally within one calendar month for a data-rights request, and explain any legally permitted extension, fee or refusal. This is a manual request route, not a claim that automated account export or erasure is already available.
You can also complain about our handling of your information. We will acknowledge a data-protection complaint within 30 days, investigate, keep you informed and provide an outcome without unjustifiable delay. A complaint and a data-rights request have separate response rules. You can complain to the UK Information Commissioner’s Office at any time; contacting us first is not a condition of that right. Another country’s applicable privacy law may also give you access to its supervisory authority.
10. Changes to this notice
We will update this page when our data use or providers change and show the date of the new version. Material changes will be brought to account holders' attention where appropriate. These privacy details sit alongside the Terms of use; the Terms do not remove your data-protection rights.