Privacy Policy

Last updated: September 26, 2026

This Privacy Policy explains how LLC Swiftcode ("Assets.ge", "we", "us", or "our") collects, uses, discloses, and protects information when you use our website, dashboard, and related services (the "Service"). LLC Swiftcode is registered in Georgia under registration number 406499551, with a registered address at 13 Moscow Avenue. By creating an account or using the Service, you agree to the collection and use of information as described here. If you do not agree, please do not use the Service.

1. Who we are and how to contact us

Assets.ge is operated by LLC Swiftcode, registration number 406499551, registered address 13 Moscow Avenue, Georgia. For any question about this Privacy Policy or how we handle your data, contact us at info@assets.ge or through the contact form at /contact.

2. Information we collect

We collect the following categories of information:

  • Account information: name, email address, password (stored as a salted hash, never in plain text), and authentication metadata, managed through our authentication provider, Supabase.
  • Financial and portfolio data you enter: assets (real estate, vehicles, stocks, crypto, cash, deposits, private equity, jewelry, collectibles, industrial equipment, digital assets), liabilities and debts, transaction and accumulation history, comments, currencies, and portfolio membership and roles.
  • AI assistant content: messages you send to the in-app AI assistant and the portfolio context needed to answer them, for Pro users who opt to use that feature.
  • Payment and billing metadata: subscription plan, billing status, order identifiers, and payment outcome, received from our payment processor. We do not receive or store your full card number, CVV, or bank credentials - those are handled entirely by our payment processor.
  • Usage and device data: pages visited, features used, approximate location derived from IP address, browser and device type, and similar diagnostic data, collected through our analytics provider, PostHog.
  • Communications: messages you send us through the contact form or support channels.
  • Referral data: referral codes, invitations sent, and referral/influencer program activity, if you participate in that program.

3. How we use your information

We use the information we collect to:

  • Provide, operate, and maintain the Service, including calculating your net worth, asset allocation, and financial-health metrics from the data you enter.
  • Create and secure your account, authenticate you, and enforce portfolio-level access controls so only you and people you explicitly invite can see a given portfolio.
  • Process subscription payments, send billing-related notices, and manage upgrades, downgrades, and cancellations.
  • Provide the optional AI assistant feature, including sending the minimum necessary context to our AI infrastructure providers to generate a response.
  • Respond to support requests and communicate with you about the Service.
  • Monitor, analyze, and improve the Service, diagnose technical issues, and understand feature usage in aggregate.
  • Detect, investigate, and prevent fraud, abuse of the referral program, security incidents, and violations of our Terms of Service.
  • Comply with legal obligations, including tax, accounting, and consumer-protection requirements applicable in Georgia and, where relevant, the European Union.

4. Legal bases for processing

Where the Georgian Law on Personal Data Protection, the EU General Data Protection Regulation, or another applicable data-protection law requires a legal basis, we rely on one or more of the following: performance of the contract between you and us (providing the Service you signed up for), your consent (for example, for optional AI features or marketing communications, which you may withdraw at any time), our legitimate interests (such as securing the Service, preventing fraud, and improving our product, balanced against your rights), and compliance with a legal obligation.

5. The AI assistant and third-party AI providers

If you use the optional AI assistant, the portfolio data and messages needed to generate a response are sent to our AI infrastructure providers (currently OpenAI and Google) for processing. We configure these integrations, where the provider offers it, to exclude your data from being used to train their general-purpose models. We do not send your data to these providers for any purpose other than generating your requested response.

The AI assistant is a convenience feature that summarizes and reasons over the data already in your portfolio. It is not a financial advisor and its output should not be treated as financial, tax, or legal advice - see our Terms of Service for the full disclaimer.

6. How we share information

We do not sell your personal or financial data, and we do not share it with third parties for their own independent marketing purposes. We disclose information only in the following limited circumstances:

  • Service providers (subprocessors) who process data on our behalf under contractual confidentiality and security obligations: Supabase (authentication and application data hosting), Flitt (payment processing for subscriptions), PostHog (product analytics), and OpenAI and Google (AI assistant processing, only for users who use that feature).
  • Other members of a shared portfolio, limited to the data and role permissions (owner, admin, editor, viewer) you or another owner explicitly configure for that portfolio.
  • Professional advisors, such as auditors, lawyers, and accountants, bound by confidentiality obligations.
  • Authorities or third parties where disclosure is required to comply with a legal obligation, court order, or valid governmental request, or to protect the rights, property, or safety of Assets.ge, our users, or the public.
  • A successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to that entity continuing to honor the commitments in this Privacy Policy.

7. International data transfers

Some of our service providers process data outside Georgia, including in the European Union and the United States. Where we transfer personal data internationally, we take reasonable steps to ensure it receives an adequate level of protection, including through contractual safeguards such as standard contractual clauses or equivalent mechanisms offered by our providers.

8. Data security

We take the security of your financial data seriously. Data is stored on Supabase's managed infrastructure with encryption in transit (TLS) and at rest. Access to portfolio data is scoped server-side by portfolio membership, so a user can only read or write data for portfolios they belong to. Internal access by our staff is limited to what is necessary for support, debugging, and legal compliance, and is logged where technically feasible. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security, but we continuously work to protect your information against unauthorized access, alteration, disclosure, or destruction.

9. Data breach notification

If a breach of security is likely to result in a risk to your rights and freedoms - for example, unauthorized access to your financial or portfolio data - we will notify the competent supervisory authority without undue delay, and within 72 hours where required by applicable law, once we become aware of it. Where a breach is likely to result in a high risk to you, we will also notify affected users directly, without undue delay, describing the nature of the breach and the steps we are taking in response.

10. Data retention

We retain your account and portfolio data for as long as your account is active, so that the Service can function. If you delete your account, we delete or irreversibly anonymize your personal and portfolio data within 30 days of the request being processed, except where we are required or permitted to retain certain records for longer: billing and transaction records are retained for the period required by Georgian tax and accounting law (currently up to 6 years), and information needed to resolve an open dispute, enforce our agreements, or comply with a legal obligation is retained until that matter is resolved.

11. Your rights

Subject to applicable law, you have the right to: access the personal data we hold about you; request correction of inaccurate data; request deletion of your data; request that we restrict or object to certain processing; request a portable copy of your data in a structured, commonly used format; and withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal. You can exercise these rights by contacting us at info@assets.ge. If you are in the European Union, you also have the right to lodge a complaint with your local data-protection supervisory authority. If you are in Georgia, you may contact the Personal Data Protection Service of Georgia.

12. Account deletion

You can request deletion of your account from within the app. Deletion requests are processed as described on our account-deletion status page, and once completed, remove your personal and portfolio data from our active systems, subject to the retention exceptions described in Section 10.

13. Cookies and similar technologies

We use cookies and similar technologies for authentication, preferences, and analytics. See our Cookie Policy for details on what we use and how to control it.

14. Children's privacy

The Service is not directed to, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will take steps to delete it.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will update the "Last updated" date above and, for material changes, provide additional notice such as an in-app notification or email.

16. Contact us

If you have questions about this Privacy Policy or how we handle your data, contact us at info@assets.ge or through /contact.