Privacy policy
Effective date: 1 June 2026 · Last updated: 3 November 2026
Summary: We store your email address, a salted hash of your password, the portfolio data you enter and a record of which features you use. We do not sell your data, share it for marketing or connect to your brokerage. No analytics or advertising cookies are set. You can download your data or delete your account from the Help page at any time.
1. Who we are
Divisio Capital is operated by George Mason, a sole trader in the United Kingdom, at www.divisiocapital.com. References to "we", "our" or "Divisio" in this policy mean the operator. For anything about your data, contact support@divisiocapital.com.
2. Data we collect
Account data: your email address and a password. Passwords are stored only as salted PBKDF2-HMAC-SHA256 hashes (200,000 iterations), so we cannot read them. We also record when your account was created and when it was last used.
Portfolio data: the ticker symbols, share counts, buy and sell prices, dates, notes, custom columns, cash balances and watchlist entries you enter, each portfolio's account type (such as an ISA or a SIPP), any dividend you correct on the Dividends page, plus settings such as your display currency. A broker export you import is read on our server to show you the preview and is not kept; only the holdings and sales you confirm are saved.
Cookies: a session token in an HTTP-only cookie (ec_session) keeps you signed in for 30 days or until you sign out. When you create an account, a second HTTP-only cookie (ec_pending) lets the verification link sign in the browser you signed up from without asking for your password again; it lasts at most 24 hours. These are the only cookies we set.
Usage data: while you are signed in we record which pages of the app you open and which features you use (for example "forecast run") against your account, with a timestamp, so we can see what is used and how many people are active. This is first-party logging on our own server and never includes portfolio contents or free text. We do not use Google Analytics or any other third-party analytics, advertising pixels or tracking scripts, and no analytics or advertising cookies are set.
Server log: to keep the service secure and to find faults, our server writes a line for each request with its method, its path (never the query string), the result, the time it took and your IP address. To slow down password guessing and abuse it also counts recent sign-in, sign-up and email requests per email address and per IP address; those counts are held in memory only, never written to disk, and stop counting after at most an hour.
Xenia AI: if you use Xenia, your Xenia profile (its settings, which start from defaults until you change them, and a copy of your Divisio holdings and cash), the sources you choose, your journal and her recent answers are stored against your account so you can come back to them. A recent answer is kept with your question as you typed it, and a kept evaluation keeps the figures it was written from for as long as it is kept. Your questions go to Anthropic in Xenia's own words for what they are about, never in yours, and your holdings and cash go only with an evaluation of your portfolio that you ask for (section 4). For each of her answers we record the model, the number of tokens and what it cost us, which is how her daily allowance is counted.
Xenia's memory is offered to some accounts only; on those it has its own section in Xenia's Settings. On such an account the copy of your Divisio holdings and cash goes when you delete them in Divisio, and recent answers are deleted after 90 days, or sooner if you delete them in Xenia's Settings. Words in a question or follow-up about your money, age, income or work, family, health, beliefs, politics or identity are kept only in Xenia's own wording, and on an account given Xenia's own views rather than facts and figures, so is a question that said anything else about you or asked what to do. If you turn on Xenia's memory, we also keep what she remembers: how you like answers, the stocks and topics you follow, filters you set, what you asked about in the last 90 days with her general view that day, and the figures of your last portfolio check. Memory never holds amounts of money, your goals, age, income, tax position or accounts, how much risk you would take, your health or your beliefs, and it never reads what you type in your Xenia Profile. You can see, change, download or delete all of it on Xenia's What Xenia remembers page, and pause it at any time.
Your browser's local storage holds conveniences such as the last portfolio you opened, cached exchange rates, your table and display options and whether you have seen the welcome tour, and the income and other details you type on the Capital gains page. That stays on your device and is not sent to us.
3. How we use your data
- To sign you in and keep your session.
- To store and show your portfolios, performance, dividends, watchlist and analytics.
- To fetch market data for the tickers you hold or watch.
- To answer your questions in Xenia AI.
- To remember, if you turn Xenia's memory on, how you like her answers and what you follow, so she can write in your style, show what you asked about first and say what has changed since you last looked.
- To send account emails: verification links, password resets and security notices, such as when your password is changed or your account is deleted.
- To respond to your support requests and to understand which features are used.
We do not use your data to train machine learning models, build advertising profiles or sell to anyone. Our lawful bases under UK GDPR are performance of our contract with you (providing the service) and our legitimate interests in keeping the service secure and understanding how it is used. For Xenia's memory our lawful basis is your consent, which you give by turning it on. Turning memory off stops it being used at once and keeps what she remembers, for at most 12 months, in case you turn it back on. You withdraw your consent at any time by deleting what she remembers, which Xenia offers whenever you turn memory off.
4. Processors and third parties
These services handle data on our behalf so the site can run:
- Render hosts the application and its database.
- Cloudflare sits in front of the site for DNS, TLS and protection against abuse, and sees request metadata such as your IP address.
- Yahoo Finance (via the open-source yfinance library) receives the ticker symbols you hold, watch or look up so we can fetch prices and fundamentals. For some figures the same ticker symbols go to Seeking Alpha (analyst ratings), Stooq (a backup quote when Yahoo cannot answer) or Polygon (price history, where we have it switched on). Only ticker symbols are sent, never your identity.
- Anthropic generates Xenia AI replies. Each question goes to Anthropic's API through Divisio's server, in Xenia's own words for what it is about, never in yours, with her instructions and the market data she looks up to answer. The next four sentences are about Xenia's memory, which is offered to some accounts only, and are true of those alone. If you turn on Xenia's memory, the notes a question needs go with it, in Xenia's own words: how you like answers written and, for some written answers, the names of stocks and topics you follow. Your filters are applied by Divisio's server and are not sent. The figures of your last portfolio check go only with your next evaluation of the same portfolio. When your question asks for a style, such as short or simple, a note saying so goes in the same way. A stock's general view is written once a day for every reader and is sent with nothing about anyone. When you ask Xenia to evaluate your portfolio, your holdings with their share counts, purchase prices and dates, your cash and Divisio's return figures go with that question. Your personal circumstances (your pot, limits, risk appetite, goals, timescale, experience, income, tax status and accounts) are never sent, and nor are your email address and password. Anthropic processes what it receives as our processor, in the United States, under its commercial API terms and data processing addendum.
- Resend delivers our account emails and so processes your email address and the content of those emails.
- Stripe will handle payments once paid plans launch. Card details go directly to Stripe and we never see or store them; we keep your Stripe customer and subscription identifiers and, for each payment, its amount, currency, date and type. Nothing is charged during the beta.
- Google Fonts serves the interface typefaces, so your browser requests them from Google with standard request headers. jsDelivr serves the three.js library behind the animated cube on the home page and the animated graphics in the app, and the charting library if the copy bundled with the app fails to load. Both see your IP address and standard request headers when your browser fetches the files; no account data is sent.
Some of these providers are based outside the United Kingdom. Where that is the case, transfers rely on the UK's adequacy regulations or the providers' standard contractual safeguards.
5. Storage and security
Account and portfolio data live in an SQLite database on our application server's persistent disk. A compressed copy of the database is made every day and the last 7 copies are kept on the same disk. We use PBKDF2 password hashing, HTTP-only session cookies, HTTPS-only transport, rate limiting on sign-in and security headers (HSTS, a content security policy, X-Frame-Options and others) on every response.
No system is perfectly secure. Use a password you do not use anywhere else.
6. Retention and deletion
Your data is kept while your account exists. Deleting your account (Help page, "Delete my account") removes your account, credentials, portfolios, holdings, cash records, dividend corrections, watchlist, settings, usage records, Xenia conversations and sessions from our database straight away. Copies in our daily backups are gone within 7 days. Any payment records we hold once paid plans launch are kept for accounting purposes but detached from your identity. What Xenia remembers is kept until you delete it or close your account. Things she noticed fade and are deleted when unused, and things she has seen only once or twice go after 60 days; what you asked about is kept for 90 days; your last portfolio check for 12 months. If you turn memory off and keep what she remembers, it is deleted after 12 months. On an account Xenia's memory is offered to, her recent answers and their follow-ups are deleted 90 days after they were last saved; on any other account the twelve most recent are kept, and an older one is deleted when a newer one is kept.
7. Your rights
- Access and portability: the Help page has "Download my data", which gives you a JSON file of what we hold about you: your account details, portfolios, holdings, custom columns, cash records, dividend corrections, watchlist, settings, Xenia data, including what she remembers, usage records, payments and active sign-ins. Your password hash is never included.
- Correction: edit or remove any portfolio entry, watchlist item or setting in the app at any time.
- Deletion: use "Delete my account" on the Help page, or email support@divisiocapital.com.
- Objection and complaints: you can object to our use of your data by emailing us, and you have the right to complain to the Information Commissioner's Office at ico.org.uk.
8. Children
The service is for people aged 18 and over. We do not knowingly collect data from anyone under 18; if you believe a minor has registered, contact us and we will remove the account.
9. Changes to this policy
We may update this policy from time to time. The "last updated" date at the top shows the latest revision, and we will tell you about any change that materially affects how your data is used.
10. Contact
Privacy requests: support@divisiocapital.com