DonkyCapital

DonkyCapital Privacy Policy

Last Updated: March 16, 2026

This Privacy Policy describes how we collect, use, and disclose information about you when you use our Service, and explains your rights regarding personal data protection.

We use Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Policy.

Interpretation and Definitions

Interpretation

Capitalized words have the meanings defined in this Privacy Policy. Definitions apply to both singular and plural forms.

Definitions

  • Account: an account created to access our Service or parts of it.
  • Affiliate: an entity that controls, is controlled by, or is under common control with another party (ownership ≥ 50%).
  • Company ("the Company", "We", "Us" or "Our"): refers to DonkyCapital.
  • Cookies: small files stored on your device containing browsing information.
  • Country: Italy.
  • Device: any device that accesses the Service (computer, smartphone, tablet).
  • Personal Data: all information relating to an identified or identifiable individual.
  • Service: the website and services offered by DonkyCapital.
  • Service Provider: natural or legal persons who process data on behalf of the Company.
  • Usage Data: information collected automatically during use of the Service.
  • Website: DonkyCapital, accessible from www.donkycapital.com
  • You: the natural or legal person using the Service.

Collection and Use of Your Personal Data

Types of Data Collected

Personal Data

We may ask you to provide us with information useful to contact or identify you, including:

  • First and last name
  • Email address
  • Portfolio or financial transaction data
  • Usage Data

Usage Data

Collected automatically, may include:

  • IP address
  • Browser type and version
  • Pages visited
  • Date and duration of visit
  • Unique device identifiers
  • Diagnostic data
  • Mobile device information (operating system, device type, unique ID)

Tracking Technologies and Cookies

We use Cookies and similar technologies (web beacons, tags, and scripts) to analyze Service usage and improve the experience.

Types of Cookies Used

Necessary / Essential Cookies

  • Type: Session
  • Managed by: Us
  • Purpose: authentication and fraud prevention.

Policy Acceptance Cookies

  • Type: Persistent
  • Managed by: Us
  • Purpose: store Cookie consent.

Functionality Cookies

  • Type: Persistent
  • Managed by: Us
  • Purpose: remember preferences (language, login).

Use of Personal Data

The Company may use your data to:

  • Provide and maintain the Service
  • Manage your Account
  • Execute contracts and contractual obligations
  • Contact you via email or notifications
  • Provide news, updates, and offers
  • Manage your requests
  • Internal analysis and service improvement
  • Corporate operations (mergers, acquisitions, transfers)

Sharing Your Data

Your data may be shared:

  • With our Service Providers
  • In case of corporate operations (mergers, acquisitions)
  • With our Affiliates
  • With other users (public areas of the service)
  • With your explicit consent

Data Retention

We retain your Personal Data only for as long as necessary for the purposes described or required by law.

Data Transfer

Your data is not transferred outside the European Union. All processing takes place within the EU, in compliance with GDPR.

Data Deletion

You have the right to:

  • Access your data
  • Rectify it
  • Request deletion
  • Restrict processing
  • Request portability
  • Object to processing

You can manage some information directly from your Account or by contacting us.

Disclosure of Personal Data

We may disclose your data in case of:

Business Transactions

Mergers, acquisitions, or sales.

Law Enforcement

If required by legal obligations.

General Legal Obligations

To:

  • comply with regulations
  • defend our rights
  • prevent fraud
  • protect user security
  • manage legal liabilities

Data Security

We adopt adequate technical and organizational measures to protect your personal data and ensure its confidentiality, integrity, and availability, in accordance with current regulations.

Data Processing via AI Insight

The AI Insight feature processes an aggregated profile of your portfolio (percentage allocations, asset categories, currencies, summary metrics) to generate contextualised responses to your questions. To operate the feature, these aggregated data are transmitted to Google (acting as data processor and AI model provider). Google is contractually bound not to use such data for its own purposes, including AI model training. The transfer is carried out in compliance with GDPR safeguards (Standard Contractual Clauses).

What is transmitted:

  • Aggregated portfolio profile (allocations, asset classes, currencies, metrics)
  • The text of messages sent in the chat

What is NOT transmitted:

  • Individual transactions
  • Personal or directly identifying data

Conversation retention. AI Insight conversations are retained for 90 days from the date of the last interaction, after which they are automatically deleted. Users can delete their conversations independently at any time directly in the app.

Aggregated portfolio data transmitted to AI Insight is not used to train artificial intelligence models.

Links to Third Party Sites

We are not responsible for the content and policies of external sites linked to our Service.

Changes to Privacy Policy

We may update this Policy periodically.
We will inform you via email or notices on the Site.

Data Controller

The DonkyCapital project is currently managed by an individual controller operating on a personal basis, based in Verona (Italy).
The Data Controller can be identified via the address [email protected] which can be contacted for requests relating to access, modification, or deletion of Personal Data, as well as for exercising the rights provided by GDPR.

For questions: [email protected]