1.Who is responsible
The service is operated under the name Finmind (finmind.uz) by "BE-Certified Services Limited" LLC, TIN 311 737 555, which decides how your personal data is processed. The address and the person responsible for personal data are shown at the bottom of this page and of every public page once set; you can reach us through the channels in the contact section.
2.The data we collect
Finmind account data. Your email address, your name if you give it, your preferred language and settings, and the dates your Finmind account was created and verified. You may add your taxpayer number (STIR) for the tax declaration. You may also add one mobile phone number, verified with a code sent by SMS, and one backup email address, verified with a code; both are optional and are used only for sign-in and security codes. The interface is offered in English, Uzbek and Russian.
Consents. The date you confirmed that you are 18 or older, and each answer you gave to a consent question (the terms and this policy, product news, discount offers) or to "Tell me when this ships" when you stop a plan, with the version of the documents in force at the time and where you answered (the registration form, a Google or Telegram sign-up, the question asked once at sign-in, Settings, the flow for stopping a plan, or the unsubscribe link in a message). A change of mind is recorded as a new answer; nothing is overwritten. The consent history also holds the date a remembered choice ends, a row when that choice is cancelled and a row when a notice about a changed document is dismissed. These rows are kept as long as your Finmind account exists and are never deleted automatically.
Sign-in and security data. Your password is stored only as a salted hash (PBKDF2), never in readable form. If you use an authenticator app, its secret is stored encrypted; recovery codes and one-time codes sent by email, Telegram or SMS are stored only as hashes and expire. We record sign-in events (success, failure, lockouts) without your IP address or device details, to protect Finmind accounts from attack. When we send you an email or an SMS, we keep a delivery record with the kind of message, a masked address or number, the provider's answer and, for an SMS, whether the gateway reported it delivered, never the text.
Passkeys. If you add a passkey to your Finmind account, we store its credential id, its public key (not a secret: the matching private key stays on your device or in your password manager and never reaches us), a signature counter, hints about the device (how it connects and its model identifier), whether the device checked you with a face, a finger or the screen lock, whether the passkey can be and is backed up to your password manager, the name you gave it, and when it was added, last used and ended, and why it ended. We never receive or see your face or fingerprint: your device checks it and only releases a signature. When you remove a passkey it stops working at once and its record is marked as ended. We also end a passkey whose counter goes backwards (a sign it may have been copied) and every passkey of an unconfirmed Finmind account when the confirmed owner of its email address takes it over. The record of an ended passkey is not deleted automatically: it is kept as long as your Finmind account exists and is deleted with it, after the review described under How long we keep it. Passkeys work on finmind.uz and www.finmind.uz only.
Face ID or fingerprint in the Telegram Mini App. Where this is switched on (it may not be yet) and you turn it on for a phone inside the Mini App, we store a record for that phone: a random identifier we made for it, a hash of a secret we made (never the secret itself), whether Telegram reported a face or a fingerprint, the phone's platform (such as ios or android), and when the record was made, last used, expires (180 days after it was made) and ended, and why it ended. Turning it on asks for the proof every sensitive change asks: your Finmind password and, when it is on, your two-factor code; a code alone when your Finmind account has no password (but only a recovery code when it has no password and uses Telegram for two-factor authentication); or a fresh proof from your Google, Telegram or OneID sign-in when it has neither. You can have it on for up to 3 phones. We never receive or see your face or fingerprint: your phone checks it, and only then does Telegram release the secret from the phone's secure storage; our server checks that secret. It confirms only an approval to create or arm a stop-loss or take-profit, an autopilot plan or an AI trading strategy, or to approve an AI trading signal, inside the Mini App, and it can be the second step of a Mini App sign-in. It cannot confirm a change of your password, your email address or your two-factor settings, end a session, turn on live trading, connect a brokerage account, download or delete your data, or replace your password or code on finmind.uz. It is not available to Finmind accounts of staff, or where your role in an organisation's Finmind account requires a two-factor code. Turning it off ends the record at once; so do Sign out everywhere and changing your password, your email address or your two-factor settings. The record of an ended phone is not deleted automatically: it is kept as long as your Finmind account exists and is deleted with it, after the review described under How long we keep it. The records are also in your data download (Settings, then Privacy and data, then Download my data), without the secret.
Your sessions. For each sign-in we keep a session record: the browser and platform names (not the full browser identifier), the first part of the IP address only (the /24 or /48 network, never the full address), the country and, where it is switched on, the approximate city given by Cloudflare, when the session started and was last used, whether you ticked "Remember me" and whether a second factor was used, and when and why the session ended. We use it to make an ended session unusable at once and to show you where you are signed in. The records are also in your data download (Settings, then Privacy and data, then Download my data).
Ending a session. In Settings, under Sessions and devices, you see your sessions (the device, the approximate place and when it was last active, never the IP address) and can end them. Signing out the session you are using needs nothing more. Ending another session first asks you to confirm it is you (your password and, when it is on, your two-factor code), and only your oldest session can do it: a newer session can ask the oldest one to approve, which it can do within 10 minutes, and we tell you about every such request by email, Telegram and in the app. A session opened in the Telegram Mini App cannot be ended on its own from this list; Sign out everywhere ends it too, and so does an approved request to end every other session. Sign out everywhere ends every other session at once, from any of your sessions, after the same check, and we then offer, never force, a password change. Changing your password, your email address or your two-factor settings also ends all your other sessions at once. The oldest-session rule protects you from someone who signed in recently; it cannot protect you from someone who has held your oldest session for a long time. If you suspect that, reset your password with Forgot password on the sign-in page: that ends every session and needs none of them. When a session is ended we record the kind of action and how you confirmed it, never the device or the place.
Remembered devices. Where the website offers it (it may not be switched on yet) and you tick "Remember this device for 30 days" while entering a two-factor code, we remember that browser: it keeps a random token in a cookie (fm_trusted_device, see the cookie policy), and we store only a hash of that token, the browser and platform names, and when the device was remembered, last used and removed. For 30 days a sign-in from that browser asks for your password (or your Google, Telegram or OneID sign-in) but not the two-factor code; every sensitive change still asks for the code. It never replaces the sign-in itself, and it is not used after a passkey that did not check you with your fingerprint, face or screen lock. It is never offered in the Telegram Mini App, to the Finmind accounts of staff, or where your role in an organisation's Finmind account requires two-factor authentication. You can remove a remembered device in Settings, under Sessions and devices; changing your password, your email address or your two-factor settings, and Sign out everywhere, remove every remembered device at once.
Identity verification (MyID). If you verify your identity with MyID, we store the outcome, the dates, MyID's references, your full name, your date of birth and your PINFL (encrypted, and shown masked). We never receive or store the face images or video: see Identity verification below.
Google sign-in. If you sign in with Google, we receive from Google your Google account identifier, your email address, whether Google has verified it, and your name. We do not receive or store your profile photo, contacts, files or any other Google data.
Telegram. If you sign in with Telegram, we receive your Telegram user ID, name and username. If you connect a chat to the Finmind bot, we store the chat ID and your Telegram username with your Finmind account. See Telegram below.
Brokerage connection. If you connect your fondbozori.uz brokerage account, we store its account ID, the broker member code and your broker password and inquiry PIN. The password and PIN are encrypted before they are stored, with a key kept separately from the database, and are never shown back to anyone. We store the holdings, cash, orders, trades and statements we read from your broker, and the orders you place through Finmind with their status and history. Finmind also keeps a record of the cancels you send through it for orders placed elsewhere, such as in your broker's own terminal.
Exchange and wallet connections. If you connect a Binance API key, a Telegram Wallet (TON) address or an Interactive Brokers (IBKR) connection, the key and secret (or the IBKR credentials) are encrypted before they are stored, with a key kept separately from the database, and are never shown back to anyone. We also store the permission flags Binance reports for your key (whether it can read, trade, transfer or withdraw, and whether it is limited to certain addresses) and nothing else from that report. For a Binance key we also store a coded form of your Binance account number, one that cannot be turned back into the number, so that the same Binance account is never counted twice. Finmind only reads: through these connections it never places an order and never moves money. About every hour, and when you open Connections, Finmind reads your balances and stores each reading: the time, and for each wallet and coin its quantity and its value in US dollars (or the reason it has none), with the total. A TON address is public and is stored as you entered it. We keep these readings for as long as your Finmind account exists, and they are never deleted automatically; when you disconnect a connection, the stored key is removed, Finmind stops reading it, and the earlier readings stay on record.
Financial data you enter. Portfolios, transactions, accounting records, budgets, goals, alerts, watchlists, plans and similar records you create. If you use the card vault, the card number, PIN and CVV you enter are stored encrypted; the last four digits are stored in plain form to label the card.
Statement import and statement checks. A statement or export file you upload is read in memory and discarded when the request ends; the file itself is never stored. When you upload a statement to check how a brokerage account performed, we keep its rows in your Finmind account, apart from your portfolio: for a transaction history each trade and cash movement with its date, security, currency, quantity, price, amount, fee and tax, and for a custody statement or a daily securities balance the holdings and balances it lists. We keep them so that you can open the report again and, if you choose, add the trades to your portfolio later. A check changes nothing in your portfolio, net worth or tax figures until you add it, and only the rows you confirm are added to your records. Removing a check from your list hides it; it does not delete it. A PDF is read by a separate process that is stopped if it takes too long and that can write nothing to disk. The header of a statement holds your name, passport number, personal identification number (PINFL), tax number, address, bank details and full brokerage account number: we do not read these into your records, our logs or error messages, and keep and show at most the last four digits of the brokerage account number so you can tell which brokerage account the file is from.
Payout reminders. If you turn on payout reminders, your lead time and the reminders sent; if you subscribe to the personal payout calendar, a secret link token that lets a calendar app read it. You can revoke the token at any time in Payouts.
Payments. For each payment request: its reference, the features and period bought, the amount, the method, your email address at the time, any receipt number or note you give, the status and any refund. For Telegram Stars payments, also the Telegram user and chat that paid and Telegram's charge identifier. We never receive your card details: card payments are handled by the payment provider.
Discounts and referrals. Referral codes you create, who referred whom, discount codes you use and the credit you earn. The student discount is checked from the domain of your verified email address; we collect no documents.
Discount offers. If you turn on discount offers, a record of each offer we send you: the campaign, the title and text in your language, the channels it went through (Telegram, email) and when, or why it was not sent (for example because you had turned the offers off by then).
Stopping or pausing a plan. If you stop or pause a paid plan, we keep what you chose: the plan, whether it ends at its end date or at once, or, for a pause, its length (30, 60 or 90 days), the whole days set aside, when it started and the day it resumes at the latest. If you answer the short question about why you are stopping, we keep your answer (one of five reasons, or that you skipped it), the plan and billing period, and where in Finmind you started. If you choose "a feature is missing" or "another reason", we also keep the note you write in your own words (up to 2,000 characters); it is personal data, and the answer is never needed to stop a plan. A note about a missing feature is kept as a request with a status that a Finmind administrator sets (new, planned, shipped or declined). Administrators see counts, not your words: reading a note needs a fresh proof of who they are, and each read is recorded first. If you tick "Tell me when this ships", we record it as a consent (a separate, optional answer, off unless you tick it) and send you one notice when that feature ships, only while your latest answer is a yes; to withdraw it, write to finmind_support@protonmail.com. We also keep the offer shown to you after the question (a pause, a move to Premium, a 50% discount on the next period, or none), whether you took it, and when it expires; if you accept the discount, Finmind creates a discount campaign that applies to your Finmind account alone. If you ask for a reminder before a plan ends, we keep that choice and the plan end each reminder was sent for; reminders go 7 days and 1 day before a plan's last day, in the app, by Telegram and by email, and you can turn them off in Settings, then Notifications. A record of each change (what happened, when, the number of your Finmind account and who acted, never your note or your email address) is kept as an audit trail.
AI assistant. The messages you write to the assistant in the app and its replies, kept as your assistant history. Messages you send to the Telegram bot are answered but not added to that history; a trade you ask the bot to prepare is kept as a proposal with its outcome.
Support. Messages you send through Support or the contact form, with the name and email address you give, and our replies.
Shared features. If you use features that share information with other people, such as family and savings circles, the members you invite see what the feature shows them.
Copy trading. Only if you opt in to be listed and copied: the public alias you choose and your performance figures (such as return and profit or loss), which other users can see. Your email address is never shown.
Paper competitions. If you join a paper trading competition, we keep the player name you chose for it and the paper trades your team makes with virtual cash. No real money is involved. Other players see your team name and its return, never your trades or holdings. Your teammates see the player name you chose and your team's holdings.
Technical data. Our web server records each request (the IP address the request came from, the time, the address requested, the response and the browser's user agent) in an access log, with query parameters and password reset tokens removed.
3.How we use it
- to create and secure your Finmind account, sign you in and verify your email address;
- while your email address is not confirmed, to remind you to confirm it: in the app, by Telegram only if you turned Telegram notifications on, and by email at most five times (at most twice, by email only, for a new Finmind account that has not confirmed its address yet), whatever your email notification setting, because the reminder is about your Finmind account itself; we keep a record of which reminders were sent, when and by which channels, never their text;
- to provide the features you use, including synchronising your brokerage account and placing the orders you instruct;
- to process payments, switch on the access you bought, apply discounts and handle refunds;
- to let you stop or pause a plan, to ask why when you are willing to say, to show you one offer to stay and, if you asked, to remind you before a plan ends;
- to send the notifications you choose, sign-in codes and security notices, in the app, by Telegram or by email;
- to send you product news by email, only if you turned that on, and until you turn it off;
- to send you offers about Finmind's own discount campaigns by Telegram and email, only if you turned discount offers on, and until you turn them off;
- to answer your assistant questions and your support requests;
- to prevent fraud and abuse and to keep the service secure;
- to meet legal obligations, such as keeping payment records.
We do not use your data for advertising, we do not build marketing profiles, and we do not make decisions with legal effect about you by automated means. Automated orders run only on rules you set and switch on yourself.
4.Legal basis and consent
We process your personal data with your consent, which you give explicitly when you create a Finmind account: every sign-up path (the registration form, Google, Telegram) asks you to confirm that you are 18 or older and that you accept the terms of service and this policy, in two boxes that are never ticked in advance, and a Finmind account is not created without both. A Finmind account from before these questions existed is asked them once at its next sign-in. You also consent when you choose to connect a brokerage account, a Telegram chat or another service. We also process data where it is needed to provide the service you asked for, and where the law requires it.
Product news by email is a separate, optional consent, off unless you turn it on, in the registration form or in Settings, and you can turn it off there at any time. Discount offers are another separate, optional consent, off unless you turn it on in Settings, then Notifications. While it is on, an offer about one of Finmind's own discount campaigns may reach you by Telegram (if you connected a chat) and by email, even if you turned those channels off for other notifications, because turning on discount offers is your choice of those two channels for offers. Every offer carries an unsubscribe link (email) or button (Telegram) that turns the consent off at once, and you can turn it off in Settings at any time. "Tell me when this ships" is a third separate, optional consent, off unless you tick it in the flow for stopping a plan: it covers one notice about the feature you said was missing, and a later answer of no always wins. Each answer, including one given through the unsubscribe link, is recorded with its date as described under The data we collect. You can withdraw any other consent by disconnecting the service concerned or by deleting your Finmind account in Settings. Withdrawal does not affect processing that took place before it.
6.Google user data
Finmind's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
We request only basic sign-in information (your Google account identifier, email address and name) and use it only to create your Finmind account, sign you in and contact you about your Finmind account. We do not use it for advertising, we do not sell it, we do not use it to train AI models, and we do not share it with anyone except as required by law. You can remove Google sign-in from your Finmind account in Settings, and you can revoke Finmind's access in your Google account at any time.
7.Telegram
When you connect a Telegram chat to Finmind, the bot stores the chat ID and your Telegram username with your Finmind account, so it can send you notifications, sign-in codes and answers. The Mini App signs you in with the launch data Telegram gives it (your Telegram user ID, name and language). You can disconnect the chat at any time with /unlink or in Settings.
Messages you send to the bot are processed on our server to answer them and are not kept as a history; free-text questions from a chat connected to a Finmind account are answered by the AI assistant as described below. Telegram itself stores the conversation under Telegram's privacy policy.
Telegram Stars payments are processed by Telegram. Finmind receives the payment confirmation (the amount in Stars, the invoice it pays and Telegram's charge identifier) and nothing about how you bought your Stars.
The bot's /privacy command summarises this section and links to this page.
8.Identity verification (MyID)
Identity verification is optional and is switched on only once Finmind holds a contract with UZINFOCOM; until then the Settings card says it is not available and nothing is sent to MyID. When you start a check, you enter your PINFL and date of birth, and your browser is taken to MyID's own page, where MyID scans your face, checks that it is a live person and matches it against the photo in the state passport register. The biometric processing is performed by MyID under its own terms and privacy policy; Finmind never receives, stores or sees the images or the video.
Once MyID confirms the match and you confirm the result in Finmind, we store the outcome, the date, MyID's session references, your full name, your date of birth and your PINFL. The PINFL is encrypted with a key kept outside the database and shown masked; one verified identity can belong to only one Finmind account. Everything else MyID's profile contains (passport data, address, contacts) is discarded before anything is stored.
You can remove the stored verification in Settings at any time, whether or not MyID is still enabled on the server.
9.AI assistant
The AI assistant is answered by Google's Gemini API. To answer about your own finances, each question is sent together with a summary of your finances: your net worth, assets and liabilities, portfolio value, cash and up to 20 of your holdings with quantity, price and value. Your name, email address and credentials are not sent. Google processes this data to generate the answer under its API terms.
Your assistant history in the app is kept until you clear it, which you can do at any time in the assistant, and for at most three years per message. Questions asked through the Telegram bot are not kept in that history.
If you prefer not to share this data with Google, do not use the assistant.
10.Organisation accounts
This section applies to organisation accounts for institutions, described in the terms for organisations, and to the people who apply for them or act for them. For an application and for each member's Finmind account, Finmind decides how personal data is processed, as elsewhere in this policy. For the content an organisation puts into its organisation account, the organisation decides how any personal data in it is processed, and Finmind processes it on the organisation's behalf under its contract.
What we collect from an applicant. The organisation's details typed in the application form (legal name, type, STIR, licence and regulator, website, registered address); the applicant's full name, position, work email and phone number; whether the applicant may sign for the organisation and, if not, the signatory's name, position and email; what the organisation wants to use, the expected number of users and any message. We also record the answers to the form's three consent questions with the version of the documents, the interface language, when the work email was confirmed, the first part of the IP address the form was sent from (the /24 or /48 network, never the full address), and the results of the automated checks, including whether a Finmind account already uses the applicant's email address. If the applicant is signed in when applying, the application is linked to their Finmind account and the consent is also recorded there.
What the review adds. For each verification check, the Finmind administrator records what was looked at, where and when, and the result: for example who confirmed the applicant's employment by a call-back, how the signatory's authority was confirmed, and the outcome of the sanctions screening of the organisation and the signatory. A power of attorney or board decision is received through a support conversation, never through the public form. Each step of the review is written to an audit record with the administrator's email address, the time and the first part of their IP address.
What we collect about members. When an organisation invites a person, the invited email address, the role, who invited them and when, and whether the invitation was accepted, revoked or expired. A member uses their own Finmind account, which the rest of this policy covers. The organisation's owners and admins see each member's name, email address and role, and actions in the organisation are recorded in its audit log with the member's email address at the time, the time and the first part of the IP address. Nothing from a member's personal Finmind account, such as their own portfolio, brokerage account, payments or assistant history, is visible to the organisation.
Why, and on what basis. We use this data to assess the application and verify the organisation, to contact the applicant about it, to prepare and perform the contract with the organisation, to run the organisation account and its members' access, and to keep a record of each decision. The applicant gives consent in the form, in a box that is never ticked in advance, and the application cannot be assessed without it. The checks, the contract and the members' access are also needed to take the steps the organisation asked for before a contract and to perform it, and the record of decisions is kept to meet our legal obligations and to defend legal claims.
Who processes it. The same providers as for every Finmind account (see Who processes data for us): the hosting provider, Cloudflare, and the email delivery provider, which sends the confirmation link and the status emails to the applicant. Finmind administrators who review applications are told of a new application in the app and in their linked Telegram chat; that notice carries the organisation's name and STIR, not the applicant's personal details. No application or organisation data is sent to the AI assistant, with one exception: when a member attaches an organisation note to a question, the note's text is sent to Google's Gemini API with that question only; neither the question nor the answer is saved to the member's assistant history, and the attachment is recorded in the organisation's audit log. The data is stored in France, outside the Republic of Uzbekistan, as described under Where your data is stored; hosting in Uzbekistan is not offered today.
How long. An application, including one that was rejected or never completed, and its verification record are kept as the record of the decision; no deletion period has been set for them yet, and when one is set it will be stated here. The data of a closed organisation account, including its verification record and its audit log, is kept for 5 years after closure. As for all data, nothing is deleted automatically: a deletion happens only after a Finmind administrator reviews and approves it (see How long we keep it).
The applicant's rights. An applicant has the rights described under Your rights, whether or not they have a Finmind account. Details can be corrected when we ask for more information, or at any time by writing to finmind_support@protonmail.com, and we answer within 30 days. Withdrawing consent before a decision ends the review of the application; the record of what happened until then is kept as described above. A member's rights over their own Finmind account are unchanged. For personal data an organisation put into its organisation account, we pass the request to the organisation and help it answer.
11.People you add to your debt book
The debt book lets you keep a note of money you lent to or borrowed from someone. For each person you type a name or a nickname, and for each loan the amount, the currency, the dates, any interest or instalments you agreed, repayments and a note. This is your own record: you decide what to write, and you should write only what you need to keep track of the loan.
If you choose, you can also add the other person's email address and phone number, and a backup contact: a name, an email address and a phone number. Add them only if that person gave them to you. Only you see them; we keep the email addresses and phone numbers encrypted and never write them to our logs. When you choose Remind them, Finmind prepares a text and opens your own Telegram, WhatsApp, SMS or email app, with the recipient filled in if you saved their details, or copies the text; you send it yourself, and the text is not stored. The amount is in the text only if you turn it on.
Finmind writes to the other person or to the backup contact only after they agree. You send them an invitation link yourself; on that page they accept, say no or stop. If they accept, we send one email to the address you saved to check that it is theirs, and nothing more is sent until they confirm from that email. If you saved the borrower's mobile number, the borrower can also confirm by SMS: we send a 6-digit code to that number through our SMS gateway, Eskiz.uz, and reminders go by SMS only after they type the code on the page; a borrower with no email address confirms this way. After that, when you ask (a Premium feature), Finmind may send them a short reminder by email and, to a borrower who confirmed by SMS, by SMS: at most one in 3 days, never between 21:00 and 09:00 Tashkent time, with a link to stop them. A reminder to a backup contact does not name the borrower, and only a reminder email to the borrower carries the amount, if you turned it on; an SMS never carries the amount, because it can be read on a locked phone. We record their answer, when they gave it, their language and the version of this policy. A stop is final. A stop on the invitation page ends your messages to that address, and you cannot ask it again. To stop messages from every Finmind user, the person confirms it from an email we send to the address; then nobody can ask that address again through Finmind. To keep that stop, we hold only a coded fingerprint of the address, not the address itself, and we keep it also after your Finmind account is deleted. Every SMS ends with a short link to stop them: it ends your messages and, because it reached the phone itself, it can also stop every SMS from Finmind to that number at once; that stop is kept the same way, as a coded fingerprint of the number. For each SMS we keep a delivery record with the masked number, never the text, and for each code we keep a coded fingerprint of the number and when it was sent, so the limits on codes to one number hold. If you change the email address or the phone number, the person is asked again. They can write to finmind_support@protonmail.com about their data; their rights are described under Your rights.
Your own reminders about your loans go to you: in the app and, if you turned them on, by Telegram and email. You can switch them off under Settings, Notifications. The names and notes in your debt book are not sent to the AI assistant; your balance sheet shows the debt book's totals without names, one line per category.
We process this data to provide the debt book you asked for. It is kept like the rest of your data (see How long we keep it): nothing is deleted automatically, it is included when you download your data (the other person's email addresses and phone numbers appear masked there), and it is removed with your Finmind account after a Finmind administrator approves the deletion.
12.Public company information
What is shown. On the stock pages and in company analysis Finmind may show information about listed companies that the law makes public. From the public disclosure portal (openinfo.uz) and the open-data portal (data.egov.uz) we read and store the names and positions of a listed issuer's officials, the names and holdings of its disclosed large shareholders (each with the date of the filing it comes from and a link to it) and the state's share. We do not store contact details, home addresses, identity numbers or signatures of these people: the reading drops them. They are not Finmind users, and we take nothing about them from anywhere but the issuer's own public filings.
Whose name is shown. The name of a person is shown only as a setting that a Finmind administrator controls allows. The setting starts at the most private choice: officials are shown by position only, and individual shareholders as "Individual shareholder 1", "Individual shareholder 2", with no name, holding, date or filing link. Companies and the state are always named, because they are not people. The pages follow the setting within 30 minutes of a change. The structured data of these pages, which search engines read, never carries the name of a person from this information.
How long and where. This information is stored with the rest of Finmind's data (see Where your data is stored) and is kept as the public record of the issuer's filings: a person who leaves the newest filing is marked as ended, not erased. Nothing here is deleted automatically.
Asking for a correction or removal. A person named in this information can write to finmind_support@protonmail.com to ask for a correction or for removal from Finmind's pages. We check the request and hide the person at every issuer where the name appears, under every spelling the filings use, with a recorded reason, and the person then stays hidden through every later reading of the filings. The record of the request (the reason, the staff member and the date, never the requester's contact details) goes into an audit log that cannot be edited. Hiding is not erasing: the rows stay stored but are not shown anywhere, so that a later reading cannot show them again. We answer within 30 days.
14.Where your data is stored
Finmind's server and database are hosted by Contabo GmbH in a data centre in France (European Union). Your personal data is therefore stored outside the Republic of Uzbekistan. Traffic passes through Cloudflare's global network, and the services listed under Who processes data for us process data in their own countries, including the United States.
By using the service you consent to this cross-border transfer. We transfer only the data each service needs, over encrypted connections.
15.How long we keep it
The periods below are when data becomes eligible for deletion. Nothing you store with us is deleted automatically: when data reaches the end of its period, or when you ask us to delete your Finmind account, a Finmind administrator first reviews what would be deleted and what would be kept, and the deletion happens only after they approve it. We aim to review within 3 days. Until then the data stays protected as described in this policy.
- Finmind account data and the data you create in the service are kept while your Finmind account exists and are deleted when it is deleted (see Your rights).
- Assistant history is kept until you clear it or your Finmind account is deleted. A message becomes eligible for deletion three years after it was written.
- Support conversations (support threads, the contact form and messages to the bot's support) are kept for as long as Finmind operates, so an earlier answer can be found again, and are deleted when your Finmind account is deleted.
- Tax declarations you never filed become eligible for deletion two years after the draft was created, together with the identity details you entered for them. Filed declarations are kept while your Finmind account exists.
- In-app notifications you have read become eligible for deletion one year after they were sent. Unread ones are kept.
- Web server access logs are kept for up to 30 days and then deleted automatically.
- Sessions are kept while they are active. A session that ended (you signed out, you or we ended it, or it expired) is deleted automatically 30 days after it ended, and one ended as suspicious after 90 days. Sessions are also deleted with your Finmind account.
- Remembered devices are kept while they skip the two-factor code (30 days at most). One that was removed or expired becomes eligible for deletion 30 days after it ended. Requests to end a session expire 10 minutes after they are made. They become eligible for deletion 30 days after that. Nothing here is deleted automatically: a Finmind administrator approves it first.
- Broker sessions are held encrypted for up to 6 hours. The broker credentials themselves are kept until you remove the connection or your Finmind account is deleted.
- One-time codes expire within minutes (5 minutes for Telegram and SMS codes, 10 minutes for email codes) and cannot be used after that.
- The MyID verification is kept until you remove it in Settings or your Finmind account is deleted.
- Telegram update records, used to avoid answering the same message twice, are deleted after 7 days.
- The assistant's question "which brokerage account?" while it waits for your answer (the names of the brokerage accounts it offered and your last command) is held for 10 minutes and then removed automatically. It is never written to the database.
- Consents are kept while your Finmind account exists and are deleted with it.
- Records of the discount offers sent to you are kept while your Finmind account exists and are deleted with it.
- Records of stopping, pausing and renewal reminders (your answers and notes, the requests for missing features and the offers shown to you) are kept while your Finmind account exists. Nothing in them is deleted automatically: they are included when you download your data and are removed with your Finmind account after a Finmind administrator approves the deletion. The audit trail of these changes (the number of your Finmind account and what you chose, never your note or your email address) is kept as an audit record after your Finmind account is deleted.
- Payment records are kept after a Finmind account is deleted, with the email address recorded at the time of payment, because they are accounting documents we need for refunds, disputes and the accounting and tax law of the Republic of Uzbekistan, for as long as that law requires.
- Delivery logs of emails and SMS (a masked address or number, never the text) become eligible for deletion 90 days after they were written, and sign-in events after 400 days. Both are kept after a Finmind account is deleted, with the link to that Finmind account cleared.
- Statement checks (the rows of statements you uploaded to check their performance) are kept while your Finmind account exists and are deleted with it, after a Finmind administrator approves the deletion. Removing a check from your list hides it and does not delete it, and nothing deletes a check automatically. They are included when you download your data.
- Records of failed connections to your broker (that the broker could not be reached, nothing else) become eligible for deletion one day after they were written.
16.How we protect it
- all traffic is encrypted with HTTPS, with HSTS;
- passwords are hashed; broker credentials, card details and authenticator secrets are encrypted with keys kept outside the database;
- two-factor authentication by authenticator app or Telegram code, and recovery codes; codes by SMS only as a backup for the authenticator app, and only if you turn them on;
- rate limits and lockouts on sign-in, registration, password reset and code requests;
- sessions that expire and are ended everywhere when you change your password, email address or two-factor settings;
- a list of your sessions in Settings, where only your oldest session can end another one, after you confirm it is you, and Sign out everywhere is always open to every session after the same check;
- live orders only when live trading is enabled for your Finmind account.
No system is perfectly secure. If we learn of a breach that affects your personal data, we will notify you and the authorities as the law requires. To report a vulnerability, see the security page.
17.Your rights
Under the Law "On Personal Data" you have the right to know what personal data we hold about you and how we process it, to receive a copy, to have it corrected or completed, to withdraw your consent and to have your data deleted.
You can correct your profile, change your email address, disconnect Google, Telegram or your broker, clear your assistant history, download a copy of your data (Settings, then Privacy and data, then Download my data: one JSON file with your profile and every record linked to your Finmind account, including the login ID of each brokerage account; you confirm it is you first, with your password and, when it is on, your second factor; or, without a password, with your second factor or the sign-in you use) and delete your Finmind account yourself in the app. To exercise any other right, or if you cannot sign in, write to Support in the app (Settings, then Support), use the contact form, or email finmind_support@protonmail.com. We will answer within 30 days.
Deleting your Finmind account (Settings, then Privacy and data) asks you to confirm it is you and removes your broker credentials, calendar token and Telegram chat link at once. After 14 days, unless you cancel, the deletion goes to a Finmind administrator for review, and the Finmind account and the data linked to it are deleted once they approve it, normally within 3 days. You can cancel until the deletion has run. If the administrator does not approve it, for example because a payment or an order must be settled first, we tell you the reason in the app and by email. What is kept, and why, is described under How long we keep it and on the data deletion page. You may also complain to the authorised state body for personal data protection in the Republic of Uzbekistan.
18.Children
The service is for adults. You must be at least 18 to use it (the age of majority in Uzbekistan, and what a brokerage account requires), every sign-up asks you to confirm it, and we do not knowingly collect data from anyone younger. If we learn that a Finmind account belongs to someone under 18, we close it and delete its data without the 14-day period, as an urgent case reviewed and approved by a Finmind administrator. If you believe a child has created a Finmind account, contact us.
19.Changes to this policy
We may update this policy when the service or the law changes. The date at the top shows the latest version. When a change materially affects how we use your data, we will tell you in the app or by a notification before it takes effect.
20.Contact
For any question about your personal data, write to Support in the app (Settings, then Support), use the contact form on the home page, or email finmind_support@protonmail.com. In the Telegram bot, /privacy shows a summary of this policy.