Privacy policy

1. Data controller

Benasero LLC (see the legal notice) is the controller of the personal data collected through Wealth Smart Way (WSW).

Representative in the European Union (GDPR, Article 27): David Benasero, reachable at contact@wealthsmartway.co.

2. Data collected

WSW does not connect to any bank and never asks for banking credentials: every piece of data is entered manually by the user.

3. Purposes and legal bases

• Providing the service (tracking and projecting your wealth) and managing your account, including account-related e-mails (sign-up confirmation, password reset): performance of the contract concluded when the account is created (GDPR, Art. 6(1)(b)).
• Manage the Premium subscription (trial, access to modules, cancellation): performance of the contract (GDPR, Art. 6(1)(b)).
• Replying to messages received at the contact address: legitimate interest in answering users (GDPR, Art. 6(1)(f)).
• Operating and securing the site (hosting, technical logs): legitimate interest (GDPR, Art. 6(1)(f)).

WSW sends no promotional e-mails or newsletters. Your data is not sold, not passed on to third parties and not used for advertising.

4. Recipients and processors

5. Transfers outside the European Union

Vercel Inc. and Plus Five Five, Inc. (Resend) are US companies and Supabase Pte. Ltd. is a Singapore company, even though WSW's data is hosted in the European Union. Users' e-mail addresses pass through Resend, whose main processing takes place in the United States. Benasero LLC is itself established in the United States.

These transfers rely on the standard contractual clauses adopted by the European Commission (Implementing Decision 2021/914) and, for Resend, on the EU–US Data Privacy Framework, as incorporated in these providers' data processing agreements.

For the Premium subscription, your e-mail address and an internal account identifier are sent to Paddle at the time of payment. Paddle is established in the United Kingdom and the United States and frames its own data transfers in its terms and privacy policy.

6. Retention periods

• Account and data you entered: as long as the account exists. You can delete it at any time from the application (Settings → Delete my account): deletion is immediate and permanent, and erases all associated data. It may remain for a few days in the hosting provider's technical backups before being fully purged.
• Sending logs of account-related e-mails: 30 days at the sending provider.
• Subscription information: as long as the account exists. Payment and invoicing data is kept by the payment provider for the periods the law requires of it.
• Messages received at the contact address: kept only as long as needed to reply, then deleted.

7. Your rights

Under the GDPR, you have the right of access, rectification, erasure, restriction, objection and portability of your data.

• Access and portability: directly from the application (Settings → Export my data), in JSON or CSV format.
• Erasure: directly from the application (Settings → Delete my account).
• Rectification, restriction, objection: by editing your data in the application (we cannot read your encrypted data), or, for other data, by writing to contact@wealthsmartway.co.
• Complaints: you can lodge a complaint with the supervisory authority of your country (for example, in France the CNIL: cnil.fr; in Spain the AEPD: aepd.es; in Germany the data protection authority of your federal state, listed at bfdi.bund.de).

8. Security

Your financial data is encrypted in your browser before being sent to our servers (end-to-end encryption, AES-256). The encryption key is protected by your password and by your recovery key; your password never leaves your device, only a derived value is sent to sign in. We therefore cannot read your financial data, even on request.

What remains readable by us: your e-mail address, the creation date of your data and its structure (for example, the number of items per category).

Loss of the password and the recovery key: if you forget your password, the recovery key shown when your account was created lets you recover your data. If you lose both your password and this key, your encrypted data cannot be recovered, including by us: you can then start over with an empty account.

Access to data is also separated per account at the database level (row-level security), and connections to the site are encrypted (HTTPS).

9. Cookies and local storage

WSW uses no analytics, advertising or tracking cookies. Your browser keeps only:

• a session cookie, strictly necessary to sign in;
• display preferences (currency, hidden amounts) and a cache of financial prices, stored locally in your browser and never sent to a third party;
• a non-exportable decryption key, kept locally so that you are not asked for your password on every page; it is erased when you log out.

As these items are strictly necessary for the service to work, no consent banner is required.

10. Third-party data sources

Some information displayed by WSW comes from public datasets or third-party providers. To obtain a price or an estimate, our servers send these providers the symbols you follow (stocks, cryptocurrencies, metals) and, for a real estate estimate, the city or address entered, without your identity. This information is not recorded in our database.

Providers:

• Real estate estimates, France: DVF database (Demandes de valeurs foncières), French Directorate General of Public Finances, published under the Open Licence 2.0 (Etalab).
• Real estate estimates, United Kingdom: UK House Price Index. Contains HM Land Registry data © Crown copyright and database right 2026. This data is licensed under the Open Government Licence v3.0.
• Real estate estimates, Singapore: HDB resale flat prices (Housing & Development Board), data.gov.sg, under the Singapore Open Data Licence v1.0. This source does not endorse WSW.
• Real estate estimates, Finland: Statistics Finland (StatFin), under the CC BY 4.0 licence.
• Real estate estimates, Australia: Australian Bureau of Statistics (ABS), under the CC BY 4.0 licence. Based on ABS data: the values shown are calculated by WSW from this data.
• Real estate estimates, Hungary: Központi Statisztikai Hivatal (KSH, Hungarian Central Statistical Office), under the CC BY 4.0 licence. Forrás: KSH.
• Address autocompletion: Base Adresse Nationale (BAN) and, as a fallback, OpenStreetMap, © OpenStreetMap contributors.
• Stock and ETF prices: Marketstack, a service of APILayer.
• Cryptocurrency prices: CoinGecko. Data provided by CoinGecko.
• Precious metal prices: MetalpriceAPI.
• Exchange rates: reference rates of the European Central Bank (ECB), published each business day. Source: ECB. The UAE dirham (AED), pegged to the US dollar, is calculated at its official parity.

11. Changes to this policy

This policy may change. The date of the last update is shown at the top of the page.