Privacy Statement

Data controller

The controller for the processing described in this statement is Finstri · Chamber of Commerce no. 82491224 · address: Willem de Zwijgerlaan 110-2, 1056 JV Amsterdam · info@finstri.nl. Use that email address for privacy questions and to exercise your rights. No data protection officer has been appointed.

Your calculation data stays on your own device

Income, Factor A, deposits, pension balances, Box 3 wealth, and the resulting projections are stored in your browser's local storage. This data is not sent to our analytics and is not kept in any database of ours. If you clear browser storage it is gone — we have nothing to restore either.

Uploaded documents

When you upload a document, your browser sends the file to our server, which extracts the relevant pension or tax values and returns the result. The server does not keep the document as a user record afterwards. During processing the file is submitted to the AI model — see 'Transfers outside the EEA'. With privacy mode switched on, the document is read by an AI model running inside your own browser and the file never leaves your device.

Account data

For protected access we store account metadata: email address, domain, organisation, role, accepted legal versions, sign-in timestamps, and session metadata. Passwords are stored only as salted hashes, never in readable form.

Microsoft sign-in

If you sign in with Microsoft, we validate an Azure Entra ID token and use claims from that token — email address, tenant ID, object ID, and display name — to create or update your access record.

Usage analytics

We collect limited metadata about usage: route, component, action, document type, status, organisation, domain, device category, browser, operating system, and viewport category. Fields that look like financial data are filtered out before storage. We set no tracking or advertising cookies and share nothing with ad networks.

Cookies and local storage

The tool uses no tracking or advertising cookies. It does use functional local storage for your language, theme, session, and your own calculation data. That storage is necessary to deliver the service and therefore does not require cookie consent. You can clear it at any time through your browser settings or via 'Clear data' in the tool.

Legal bases

We process personal data on the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR): account data, sign-in, and parsing of documents you submit yourself.
• Legitimate interest (Art. 6(1)(f) GDPR): security, abuse prevention, and aggregated usage analytics to improve the product. Our interest in a working, secure service outweighs the limited impact here, because the analytics contain metadata only.
• Legal obligation (Art. 6(1)(c) GDPR): retaining account data where legislation requires it.
• Consent (Art. 6(1)(a) GDPR): the optional AI pension guidance, which you switch on yourself each time. You can withdraw that consent at any time by no longer using the feature.

Processors and service providers

We use service providers that process data on our behalf: Microsoft Azure (hosting and identity), Google (Gemini, for document parsing and generated guidance), and an SMTP provider for email. Data processing agreements are in place with these parties.

Transfers outside the EEA

Processing by Google Gemini may take place outside the European Economic Area. For those transfers we rely on the European Commission's Standard Contractual Clauses and, where applicable, on the EU-US Data Privacy Framework. To avoid document processing outside the EEA, switch privacy mode on — reading documents and writing advice then happen in an AI model inside your own browser, with no transfer at all — or enter your data manually.

Privacy mode: models and licences

With privacy mode switched on, your browser downloads an AI model from Hugging Face once and keeps it on your own device. Hugging Face sees your IP address during that download; your documents and calculation data are not sent with it. We do not host or redistribute the model files. We only use openly licensed models and software:

• Qwen2.5-1.5B-Instruct — Alibaba Cloud — Apache License 2.0
• Phi-3.5-mini-instruct — Microsoft — MIT License
• WebLLM (MLC LLM) — MLC AI — Apache License 2.0
• PDF.js — Mozilla — Apache License 2.0

Retention

Calculation data stays on your own device and therefore has no retention period at our end. Account data is kept while your account is active and for 12 months afterwards, so you can restore access. Records of accepted legal versions are kept for 7 years as evidence of accountability. Usage analytics are kept for 24 months. Uploaded documents are not kept as a user record.

Security

Traffic runs over TLS, passwords are salted and hashed, access to the extended tool is limited to approved accounts, and calculation data in principle never leaves your device. If you find a vulnerability, please report it to the contact address rather than sharing it.

No automated decision-making

We do not take decisions producing legal effects or similarly significant effects based solely on automated processing, as referred to in Article 22 GDPR. The AI guidance is informational and does not result in a decision about you.

Minors

The tool is not directed at people under 16. We do not knowingly collect data from minors.

Your rights

You have the right of access, rectification, erasure, restriction, objection, and data portability. We respond within one month. If you disagree with how we handle your data, you can lodge a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).

Contact

Privacy questions can be sent to info@finstri.nl.