Privacy Policy

Who we are

Russell Port trading as Portfolio is the controller of personal data processed through Portfolio, a habit and life progress tracking service.

Data categories we collect

• Account data, including name, email address, login credentials, and authentication status.
• Profile and service data, including habits, check-ins, progress records, pillar selections, and trial status.
• Technical and usage data, including device information, IP address, browser details, security logs, and product interaction events.
• Support communications, including messages, requests, and feedback you send to us.
• Payment and subscription identifiers needed to connect your Portfolio account with Paddle-managed billing records.

Legal basis and purposes

We process account, profile, habit, trial, and subscription data to perform our contract with you and provide Portfolio. We process technical, security, usage, and support data on the basis of legitimate interests, including keeping the service secure, improving reliability, preventing misuse, and responding to requests.

Data sharing

We share data with service providers that help us host, secure, maintain, and support Portfolio. Paddle receives payment and subscription-related data as our payment processor and Merchant of Record for purchases, subscription management, tax compliance, invoicing, and customer payment support. We may also share data with professional advisers or authorities where required by law.

Retention periods

Account and habit data is retained while your account is active. Subscription and transaction records are retained for up to seven years where needed for tax, accounting, dispute, and compliance obligations. Security logs are usually retained for up to 24 months. Support messages are usually retained for up to three years. We delete or anonymise personal data when it is no longer needed.

Your rights

You may request access to your personal data, deletion of your data, correction of inaccurate data, portability of data you provided, restriction or objection to certain processing, and withdrawal of consent where processing relies on consent. We may need to verify your identity before acting on a request.

Security and cookies

We use appropriate technical and organisational measures, including access controls and encryption in transit, to protect personal data. Portfolio uses essential cookies and similar technologies for authentication, security, and service operation.