Privacy Policy

Portfolio Thinking Limited is a company registered in England and Wales, company number 16925208, with its registered office at 66 Paul Street, London, EC2A 4NA, United Kingdom. We are the data controller for the personal data described in this policy. You can reach us at neil@portfolio-thinking.com.

We provide consultancy and technology services to professional intermediaries. We do not provide regulated financial advice and we do not sell products to consumers.

• Enquiry details. When you use our contact form we collect your name, firm, email address and the message you send.
• Account details. If your firm uses our platform, we hold the email address, name, firm and role of each user, together with authentication records needed to keep the account secure.
• Content you create or upload. Model portfolios, documents, branding settings and the outputs generated from them.
• Technical data. IP address, browser type, pages viewed and basic error and performance logs, used to keep the service available and secure.

We do not knowingly collect special category data, and we do not collect data from children.

• To respond to enquiries and provide the services requested — performance of a contract, or steps taken at your request before entering one.
• To operate, secure, support and improve the platform — our legitimate interest in running a reliable and safe service.
• To send service messages, and marketing where you have asked for it — consent, which you can withdraw at any time.
• To meet legal, accounting and regulatory obligations — legal obligation.

Our public website uses only the cookies needed to serve pages securely. When you sign in to the platform we store an authentication token in your browser so you stay signed in; this is strictly necessary for the service to work and cannot be switched off while you are signed in. We do not use advertising cookies or cross-site tracking.

Parts of the platform use large language models to draft and summarise content. Prompts and the documents you choose to include are sent to our model providers to produce that output. Our providers act on our instructions, do not use your content to train their public models, and retain it only briefly for abuse monitoring. All output is intended for review by a qualified professional before use.

When you are signed in, your assistant conversations and the work you save — drafts, decks, saved settings and records of the documents you generate — are stored against your account so you can return to them, and are kept for the periods set out below. Factsheets and screenshots you upload for analysis are processed for that request only and are not stored. Our public commentary builder stores nothing at all.

We share personal data only with service providers acting on our behalf: our cloud hosting and database provider, our email delivery provider, our document storage provider and our AI model providers. We may also disclose data where required by law. We never sell personal data.

Some of our providers process data outside the UK and the EEA. Where that happens we rely on UK adequacy regulations or the International Data Transfer Addendum to the EU Standard Contractual Clauses, together with appropriate technical safeguards.

Enquiry correspondence is kept for up to 24 months. Account data and the content you create are kept for the life of the account and for up to 12 months afterwards, unless you ask us to delete them sooner. Records we must keep for legal or accounting reasons are retained for the period the law requires.

Data is encrypted in transit and at rest, access is restricted to the people who need it, and platform accounts support multi-factor authentication. We review access and security controls regularly.

Under UK GDPR you have the right to access your personal data, to have it corrected or erased, to restrict or object to its processing, to data portability, and to withdraw consent where we rely on it. To exercise any of these, email neil@portfolio-thinking.com. You also have the right to complain to the Information Commissioner's Office at ico.org.uk.

We update this policy when our services or obligations change. The date at the top of the page shows when it was last revised.