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Privacy Policy

Last Updated: 7 November 2025

1. Introduction

Tukhe is developed and operated by Tukhe, SAS (Simplified Joint-Stock Company) registered in France.

This Privacy Policy explains our data practices in accordance with the General Data Protection Regulation (GDPR) and French data protection laws.

Privacy is fundamental to Tukhe's architecture. The software operates entirely on your local machine. Your portfolio data, broker credentials, and financial information are processed and stored exclusively on your device and never transmitted to our servers.

2. Data Controller

The data controller for the limited data we process is:

Tukhe
49 rue de Ponthieu, 75008 Paris, France
Email: contact@tukhe.io

3. Data We Do Not Collect or Store

Due to Tukhe's local-first architecture, we do not collect, access, transmit, or store:

  • Your portfolio holdings, positions, or transactions
  • Your broker account credentials or API keys
  • Your financial information of any kind
  • Your broker account numbers or identifiers
  • Your name, email address, postal address, or phone number
  • Your personal identifying information
  • Your investment decisions or trading activity

All such data remains exclusively on your local device. We have no technical ability to access this data.

4. Data We Collect

4.1 Anonymous Usage Analytics

We collect limited, anonymized usage data that cannot identify you individually:

  • Application launch events and session duration
  • Aggregated feature usage patterns
  • Broker integrations being used without account identifiers
  • Software version and operating system type
  • Crash reports and error logs automatically stripped of personal and financial data

This data is collected solely to improve the software. You may disable analytics collection at any time in the application settings without affecting functionality.

Legal basis: Legitimate interest in improving our software pursuant to GDPR Article 6(1)(f).

4.2 Website Analytics

Our website collects anonymous analytics data including:

  • Pages visited and time spent
  • Click events on website elements
  • Referral sources
  • General geographic location at country or city level
  • Device type and browser information

This data is aggregated and used to understand website performance and user interest.

Legal basis: Legitimate interest in understanding website performance pursuant to GDPR Article 6(1)(f).

4.3 License Key Data

For premium subscribers, we store:

  • License key identifier
  • License status (active, cancelled, expired)
  • Subscription tier
  • Stripe customer identifier (internal reference only)
  • Subscription dates

We do not store your email address, payment information, name, or billing address.

Legal basis: Contract performance pursuant to GDPR Article 6(1)(b).

5. Third-Party Services

5.1 Stripe Payment Processing

Payment processing is handled by Stripe, Inc., an independent third-party service provider. Stripe collects and stores payment information including email addresses, payment card details, and billing addresses. Tukhe does not have access to your payment card information or billing address.

Stripe is an independent data controller for payment data. We cannot be held responsible for Stripe's data processing practices. For information on how Stripe processes your data, consult their privacy policy at https://stripe.com/privacy.

When you contact us for license recovery or subscription management, we may query Stripe's systems using your email address to retrieve your customer identifier and associated license key. This is the only circumstance in which we access data held by Stripe.

5.2 Broker API Connections

Tukhe establishes direct connections from your device to your broker's API servers. We do not intermediate, proxy, or have visibility into these connections. Your broker's privacy policy governs data accessed through their APIs. We are not responsible for your broker's data practices.

6. Data Usage

We use collected data exclusively for:

  • Improving software functionality and identifying technical issues
  • Understanding general usage patterns
  • Validating premium subscriptions
  • Providing customer support when you contact us
  • Complying with legal obligations

We do not sell data to third parties, use data for advertising purposes, or share data except as required by law.

7. Data Storage and Security

7.1 Local Device Storage

Your portfolio data and broker credentials are stored on your device using operating system secure credential storage and industry-standard encryption. You are responsible for securing your device.

7.2 Server Storage

Anonymous analytics and license key data are stored on secure servers located in the European Union with encrypted transmission, access controls, and regular security measures.

8. Data Retention

  • Anonymous analytics: Retained indefinitely in aggregated form
  • License keys for active subscriptions: Duration of subscription
  • License keys for cancelled subscriptions: Retained for accounting and legal compliance purposes for a period not exceeding statutory requirements under French law
  • Website analytics: Retained in anonymized, aggregated form

9. Your Rights Under GDPR

You have the following rights under GDPR:

9.1 Right of Access

You may request confirmation of what data we hold about you. Given our minimal data collection, this will be limited to your license key status if you are a premium subscriber.

9.2 Right to Rectification

You may request correction of inaccurate data.

9.3 Right to Erasure

You may request deletion of your data by contacting us at contact@tukhe.io with your license key. Note that we do not hold personal identifying information. For data stored on your local device, uninstall the application. We may retain certain records to comply with legal obligations under French law.

9.4 Right to Restrict Processing

You may request restriction of processing under certain circumstances.

9.5 Right to Data Portability

You may request your data in a structured format. This is limited to license key information.

9.6 Right to Object

You may object to processing based on legitimate interests. You may opt out of analytics collection in application settings.

9.7 Right to Lodge a Complaint

You may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the French data protection authority, at https://www.cnil.fr.

To exercise these rights, contact us at contact@tukhe.io.

10. International Data Transfers

Your portfolio data remains on your local device. Anonymous analytics may be transferred to our servers. Payment data is processed by Stripe according to their data transfer safeguards.

11. Children's Privacy

Tukhe is not directed at individuals under the age of 16. We do not knowingly collect data from children.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. The updated "Last Updated" date at the top of this document will reflect any changes. It is your responsibility to review this Privacy Policy periodically. Continued use of Tukhe after changes take effect constitutes acceptance of the updated Privacy Policy.

13. Contact

For questions regarding this Privacy Policy or to exercise your rights:

Tukhe
Email: contact@tukhe.io
Address: 49 rue de Ponthieu, 75008 Paris, France

For questions regarding payment data stored by Stripe, contact Stripe directly via their privacy contact methods.

14. Governing Law

This Privacy Policy is governed by French law and GDPR.

By using Tukhe, you acknowledge that you have read and understood this Privacy Policy.

Privacy Policy - Tukhe