This policy explains what personal data Lemma Analysis collects, why we collect it, the legal basis for each purpose, who we share it with, how long we keep it, and the rights you have over it. It is written to meet Art. 13 of the EU General Data Protection Regulation.
Lemma Analysis is operated by a sole trader (OSVČ) established in the Czech Republic.
For any privacy question, or to exercise any of the rights described below, write to support@lemma-analysis.com. We have not appointed a Data Protection Officer, as we are not required to.
We name a specific legal basis for each purpose — never a blanket statement.
a) Account creation and authentication. We collect your email, a securely hashed password, and the profile details you provide: display name, short bio, country, investor type and avatar image. To keep your account secure we also store session records including your IP address and browser user-agent.
b) Portfolio and valuation analytics (the core service). The portfolios, holdings, transactions, watchlists, valuation scenarios, saved screens and free-text journal entries you create.
c) Subscription and billing. Your subscription status and the identifiers linking your account to our payment provider. We never see or store your card details — payment is handled by LemonSqueezy as Merchant of Record, see Who we share data with.
d) Transactional email. Your email address, used to send verification, password-reset, security and trial-related emails. We do not send marketing email and keep no marketing list.
e) Security, monitoring and error handling. Request logs (a numeric user id, request paths, timing) and the session data noted in (a). The website also uses Sentry for error tracking, hosted in the EU (Germany). An error report contains the technical fault and the page it happened on, your browser and operating system, the page that referred you, and a short trail of what led up to the error: the pages you moved between and the requests the page made. It does not record what you clicked or what you typed. Links are stripped of everything after the "?", so verification and password-reset tokens never travel with them, and no user identity is attached to the report.
f) Product analytics. Pageviews and a few product events — sign-up, trial start — associated with your user id, collected via PostHog on its EU cloud. Our analytics is cookieless: there is no persistent tracking cookie, and automatic capture of clicks and inputs is disabled.
g) Record of your privacy requests. When you exercise a privacy right in the app — downloading your data, or deleting your account — we record the type of request, your user id and email address, when it arrived, and when it was completed. When your account is finally erased, the identifying part of that record is erased with it: what remains is only that a request of that type was received and handled on those dates.
h) Connected broker accounts. If you connect a brokerage account so that your transactions arrive on their own, we store which broker it is, which of your portfolios it feeds, the access key you issued at the broker (encrypted — see below), the state of the connection (working, or rejected by the broker), and how each run ended: when it last ran, the date up to which it has read your history, how many transactions it brought in, and the broker’s reason if it did not succeed. The transactions themselves are imported into your portfolio and become part of (b), together with a note of which broker they came from and the broker’s own identifier for each trade.
Cookies. We use only strictly-necessary cookies — the access_token and refresh_token authentication cookies that keep you signed in. We set no advertising or tracking cookies: our analytics is cookieless and error tracking sets none. Because we use no non-essential cookies, no cookie-consent banner is required. The only thing product analytics writes to your device at all is a small flag recording that you completed sign-up, so that email verification — which usually opens in a new tab — can pick up where you left off. It is not written if you have opted out, and is deleted the moment you do.
Where we rely on Art. 6(1)(f), the specific interests are:
You can object to processing based on legitimate interests — see Your rights. If your browser sends a Global Privacy Control signal, we honour it as an objection to product analytics by default, even before you have made an explicit choice.
The current list, with roles and hosting regions, is on our Subprocessors page.
Your data is stored within the EU: our database is hosted on Aiven, an EU company, in an EU region; our backend runs on Railway in the EU; profile avatars are stored in Cloudflare's Eastern Europe region; transactional email is sent via Resend from Ireland; error reports go to Sentry's EU (Germany) project; and product analytics to PostHog's EU cloud. Some of these providers — Cloudflare, Resend, Railway, Sentry, PostHog — are headquartered in the United States and could in principle access data from there. For any such transfer or access we rely on an appropriate safeguard: the provider's Standard Contractual Clauses and/or its EU-US Data Privacy Framework certification. You can request a copy of the relevant safeguard by writing to us at the address in Who we are.
If you connect a brokerage account, the request carrying your key goes to wherever your broker operates, which may be outside the EU. You chose that broker and hold your account under its own terms; for a broker outside the EU the transfer is one necessary to perform the contract you asked us to perform (Art. 49(1)(b)). Nothing else about you travels with it — see Who we share data with.
You have the right to access your data; to rectify inaccurate data; to erase your data (the right to be forgotten); to restrict processing; to data portability; and to object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw it at any time without affecting prior processing. To exercise any right, contact us at support@lemma-analysis.com.
Objecting to product analytics. Your Art. 21 right to object to processing based on our legitimate interests is a single switch: a checkbox in Settings, and the same control at the bottom of this page for visitors who are not signed in. Turning it off stops analytics immediately and clears the one thing it had stored on your device.
Access and portability. You can download a complete export of everything we hold about you — profile, portfolios, transactions, watchlists, valuation scenarios, saved screens and account and session details — as a single file in a standard, machine-readable format. It is a self-service download in your account Settings, available to every account holder regardless of subscription plan or payment status, because access to your own data is not something we put behind a paywall. The one thing the export never contains is the access key of a connected broker account — see What we collect, item (h): it is a credential to a third party, and it leaves our systems only towards that third party.
Right to lodge a complaint. You have the right to lodge a complaint with the Czech supervisory authority:
Úřad pro ochranu osobních údajů (ÚOOÚ)
Pplk. Sochora 27, 170 00 Praha 7, Czech Republic
www.uoou.cz
Providing your email, a password and payment details is necessary to create an account and subscribe — without them we cannot provide the service, so the data is a contractual requirement. The optional profile fields — bio, avatar, country, investor type — are voluntary, and not providing them does not affect your access. Connecting a brokerage account is optional too: the same transactions can be entered by hand or imported from a file you exported.
Our valuation and analysis tools — including DCF, reverse DCF and the "In Buy Zone" heuristic — produce analytical, informational outputs about public companies. They are not automated decisions about you, and they do not produce legal effects or similarly significantly affect you within the meaning of Art. 22 GDPR. You remain solely responsible for your own investment decisions.
Lemma Analysis is intended for adults aged 18 or over. Although the Czech age of consent for information society services is 15, a financial-analytics product is restricted to adults, and you must be at least 18 to create an account. Registration requires you to confirm this explicitly, and the confirmation is recorded with your account; the same requirement is stated as a separate clause in our Terms of Use.
We update this policy as our processing changes; the date at the top of this page is the date of the current version. Changes to the third parties who process data for us are announced separately on our Subprocessors page, at least 30 days before they take effect.