Privacy Policy

This Privacy Policy explains what personal information Vestro collects, why we collect it, who we share it with, and what you can ask us to do with it. It applies to the Vestro website, the Vestro mobile app and everything we provide through them. It sits alongside our Terms of Use.

We have written it in plain English on purpose. We handle information about what you own and what it is worth, so you should be able to tell exactly what happens to it.

What changed in version 1.0.11. The Vestro app now uses PostHog, a product analytics service, to see how the app is used and to make session recordings, so that we can find where people get stuck and fix problems. Money amounts, your holdings, names and anything you type are hidden in those recordings. Sections 2, 3, 4, 5, 6, 7 and 8 are updated to describe it. Our website still uses no analytics or tracking tools. We have also removed the note that importing by forwarding emails was planned: Vestro does not import by email (sections 3 and 7).

Version 1.0.10: every new account now starts with a 7-day free trial of Vestro Pro, with no card needed (Terms section 9). What we collect is unchanged: we keep a record of your trial with your account, as we already do for free months.

Version 1.0.9: the founder offer is now also made to people who have earned a free month by inviting someone, not only to people who joined through an invitation. What we collect is unchanged.

Version 1.0.8: the invitation programme now gives you a free month when the first and the third person you invite join, two at most, instead of one for each of the first three, and the founder offer now appears 3 days before your free months end. What we collect is unchanged; section 4 and section 7 are updated to match.

Version 1.0.7 removed the Reddit pixel from our website, the only advertising tool Vestro had used (section 8). We have also added our invitation programme and the offers that come with it (free months for you and a friend, a limited founder offer, and App Store offer codes), and the information we keep to run them (sections 2, 3, 4 and 7). Version 1.0.6 renamed Vestro AI to Vestro Intelligence. Version 1.0.5 made connecting your brokerage account through Akahu part of Vestro, and added Vestro Intelligence (questions you ask about your portfolio, answered by OpenAI) and investor levels. Version 1.0.4 added signing in with Apple or Google, paid subscriptions bought through the App Store, and push notifications. Each is described in the sections below.

1. Who we are, and how to contact us

Vestro is operated in New Zealand by its founders as an unincorporated business. Where this policy says "we", "us" or "our", it means that operator.

Privacy contact: [email protected]

Postal contact: Vestro, Dunedin, New Zealand.

We are the agency that collects and holds your personal information, and we are responsible for it under the Privacy Act 2020. Our privacy officer handles requests and complaints — please contact us first, using the details above.

2. What we collect

Information you give us when you create an account: your name, your email address, your password (we store it scrambled — we never keep it in a form we can read), and the date and version of the Terms of Use and Privacy Policy you accepted.

If you sign in with Apple or Google instead: Apple or Google tells us your name and your email address, and confirms that it is really you. If you choose Apple's "Hide My Email", the address we receive is a private relay address that Apple forwards to you. We never receive your Apple or Google password, and we do not receive anything else from your Apple or Google account.

Information about your portfolio, when you connect a brokerage account to Vestro through Akahu. Akahu is the connection service we use. It is a New Zealand company that links your brokerage account to Vestro after you approve it, and it is how the information described below reaches us. What we receive is: the holdings you own, being the ticker, company name, number of shares, price, market value, what you paid for them where your broker makes it available, currency, the account label and sector; your cash balance; your portfolio name; and the date and total value each time we read your account, which is what builds your portfolio history. To keep the connection open we hold an access credential from Akahu, stored in encrypted form. We ask you to connect only the investment accounts you want explained.

Your watchlist: the tickers and names you save, and any notes you write.

Your preferences and settings: your risk-sensitivity setting, the benchmark you compare against, your timezone, your avatar colour, and your notification and face-unlock preferences.

If you subscribe: your plan and whether your subscription is active, and, from Apple, the identifier of your subscription, which plan it is, the date it renews or ends, and whether it is a real purchase or a test. Apple takes the payment: we never receive your card or bank details. This includes the one-off founder purchase, if you make it. So that a purchase is matched to the right Vestro account, we give Apple a random identifier for your account, and Apple returns it with your purchases. If you use a free-access code instead, we record that your plan came from a code.

If you invite friends, or join through an invitation: your invitation code; who invited you, or whom you invited; when an invitation counted (when the person invited imported their first portfolio); the free months you were given and when they start and end; any App Store offer codes we give you; and the offers we have shown you (the founder offer or the discount), when they open and close, and whether you took them. The person who invited you sees only numbers: how many people joined with their code and how many of those have imported a portfolio. They never see your name, your email address or your portfolio.

If you turn on push notifications: your device's push notification token (a random identifier Apple gives your device for our app) and the type of device. We also keep the notifications we send you inside the app, and whether you have read or deleted each one.

Lessons you complete are remembered on your device only. They are not sent to us.

Reports and analysis we produce for you: the summary, scores, flags and written commentary generated for your portfolio, and the underlying figures they were generated from.

If you use Vestro Intelligence: the questions you ask and the answers you are given. We keep them in your account so you can look back at them.

Your investor level: we work out your level from how long you have had a Vestro account and your portfolio's health score over time, and we keep your level and the figures it was worked out from in your account. It is a measure of how you are using Vestro, not of your skill as an investor.

If you join our waitlist: your email address, and the date you joined it. If you join with Google on our website, Google also gives us your name and a link to your Google profile picture, and our sign-in provider keeps a record that you signed in with Google.

Security and technical information: your IP address and email address are used to detect and slow down repeated sign-in and sign-up attempts, and we record the time of sign-in attempts. We use a session cookie to keep you signed in (see section 8). Our servers keep ordinary technical records of requests made to them.

How you use the app: the Vestro app uses PostHog, a product analytics service, to record how the app is used: the screens you open and the buttons you tap, how long things take, any errors, your device model, operating system and app version, and your IP address, from which PostHog works out your approximate location (country and city). It also makes session recordings, a replay of what was on your screen while you used the app, so that we can see where people get stuck and fix problems. Money amounts, your holdings, names and anything you type are hidden in those recordings. Because a recording shows the screens you used, it can show other things you saw in the app, such as the goals you picked during onboarding. This information is linked to your Vestro account. Our website does not use PostHog or any other analytics tool.

Things we do not store. We never ask for your brokerage account password and we never receive it: when an account is connected, the sign-in happens with your broker or on Akahu's own connection screen, not inside Vestro. The goals you select and the experience level you choose during onboarding stay in your browser for that session only. They are not sent to us, not stored on our servers, and not used in the analysis we produce (though a session recording can show the screen where you picked them; see "How you use the app" above). Your risk-sensitivity setting is different: we do store that one, and the analysis uses it only to decide which thresholds are displayed against. It is not an assessment of what is right for you.

3. How we collect it

From you, when you join our waitlist — when you enter your email address on our website before you have an account.
From you, when you create an account, complete onboarding, or change your settings.
From Apple or Google, when you choose to sign in with them, or to join our waitlist with Google.
From Apple, when you buy or restore a subscription or the founder offer in the app, or redeem an App Store offer code, and from your device when you turn on push notifications.
From you, when you use someone's invitation code, which tells us who invited you.
From Akahu, when you connect a brokerage account to Vestro through it. You approve what Akahu may pass to us before anything reaches us, we receive only what you approve, and we hold the access credential for the connection in encrypted form. Your sign-in details are given to your broker, or to Akahu, as part of that approval — never to Vestro.
Automatically, when you use Vestro: the session cookie and the technical records described above, and, in the app, the usage information and session recordings that PostHog collects (section 2).
From our own analysis, when we calculate figures about your portfolio.

4. Why we collect it, and what we use it for

To provide Vestro to you: to store your portfolio information, analyse the structure of your portfolio, show you your holdings and history, and generate your reports and commentary.
To connect your brokerage account: when you authorise it, to ask Akahu to read your brokerage account and pass your portfolio information to us, and to keep that connection open until you disconnect it.
To run your account: to identify you when you sign in, to remember your settings, and to send you service messages (for example, sign-in or security notices, or notice of a change to these documents).
To answer your questions in Vestro Intelligence: to send your question, with the portfolio figures needed to answer it, to OpenAI, and to show you the answer.
To work out your investor level from how long you have had an account and your health score over time.
To provide your subscription: to check your purchase with Apple before we switch on what you paid for, and to know whether your subscription is active.
To run our invitation programme and offers: to give you and the person who invited you your free months, to keep to the limit of two free months for inviting people, given when the first and the third person you invite join, to show you an offer when it applies, to count honestly how many founder places are left, and to stop the programme being abused (for example, with accounts created only to collect free months).
To send you push notifications you have turned on: for example, that your daily summary is ready or that your portfolio has been imported. You can turn them off at any time in the app or in your device's settings.
To keep Vestro and your account safe: to detect and prevent unauthorised access, abuse and fraud, to apply rate limits, and to investigate security incidents.
To meet our legal obligations and enforce our Terms: for example, if we are required to keep or disclose information by law, or if we need to respond to a complaint or dispute.
To improve Vestro: to understand how the app is used, find where people get stuck and fix problems, using the usage information and session recordings described in section 2; and to look at aggregated and de-identified information about how the service is used and how it performs.
To email you before you have an account: if you join our waitlist, to tell you that you are on the list, and to send you occasional emails about Vestro — its launch and progress, product news, and educational content about investing. You can ask us to stop at any time, and every email tells you how.

What we do not do. We do not sell your personal information, we do not share your account, your portfolio or your reports with anyone for their own marketing, and we do not use them for advertising or behavioural profiling. We do not disclose your portfolio information to your broker or to anyone else except as described in this policy. We use no advertising tools, on our website or in the app, and nothing that tracks you across other companies' apps or websites. The app's analytics (PostHog, section 5) are used only to understand and improve Vestro, and our website uses no analytics tool at all.

Providing your information is your choice, but some of it is needed for Vestro to work: we cannot create an account without your name and email address, and we cannot analyse a portfolio without the portfolio information you give us. If you choose not to provide it, you can still read our public education content and use the sample portfolio.

We use other companies to run Vestro. They can only use your information to provide their service to us, and the ones that matter are:

Akahu — the connection service you use to link your brokerage account, located in New Zealand (Akahu Technologies Limited). It reads your brokerage account when you authorise it and passes your portfolio information to us, and we hold an encrypted access credential from it until you disconnect. Akahu stores the information it holds in data centres in Australia.
Supabase — our database and sign-in provider, located in Sydney, Australia. It stores your account details, your portfolio information, your settings, your reports, and your email address if you have joined our waitlist.
Render — our hosting provider, located in the United States. It runs the Vestro application that processes your information.
OpenAI — used to generate the written commentary in your report and to answer the questions you ask Vestro Intelligence, located in the United States. For your report it receives your portfolio's total value, its structural risk score and risk band, the structural flags raised, and the tickers and names of your holdings together with a model indicator and confidence value for each. When you ask Vestro Intelligence a question, it receives your question together with the portfolio figures needed to answer it, such as your holdings, their values and your scores. It does not receive your name or your email address.
Our market-data providers (currently Yahoo Finance, located in the United States, and EOD Historical Data, located outside New Zealand) — receive the ticker symbols we look up in order to show prices and market information. Those tickers are the ones you hold or watch.
Apple Inc., located in the United States — if you sign in with Apple, it confirms who you are and tells us your name and email address; if you subscribe or buy the founder offer, it takes your payment and confirms the purchase to us, and it applies any App Store offer code we give you; and if you turn on push notifications, it delivers them, so it receives your device's push token and the text of each notification. Apple handles your Apple account under its own privacy policy.
Google LLC, located in the United States — if you sign in with Google, or join our waitlist with Google, it confirms who you are and tells us your name, email address and profile picture link. Google handles your Google account under its own privacy policy.
Resend — the company we send our emails through, located in the United States (Plus Five Five, Inc.). Our waitlist emails and launch emails go through it, and so do service messages about your account, such as the message that verifies your email address. What it receives is your email address and the contents of the emails we send you, together with its own record of each delivery. Resend keeps its copy of a message and its delivery record for a limited period (30 days on our current plan), and deletes what remains within 90 days of us closing our account with it.
PostHog — product analytics and session recordings, located in the European Union (PostHog's EU cloud, in Frankfurt, Germany; PostHog, Inc. is a United States company). When you use the app, it receives the usage information and session recordings described in section 2, with money amounts, your holdings, names and anything you type hidden, and an identifier that links them to your Vestro account. It does not receive your password or your brokerage connection. Some of PostHog's own staff and service providers, including some in the United States, can access what it holds in order to run its service (section 6).
Authorities, when the law requires it — for example in response to a valid legal request, or if we are legally required to report something.

One detail about Resend. For the records it keeps to run and secure its own service — its account records and its delivery logs, which show who a message went to — Resend acts on its own account rather than on our instructions. It is a narrow exception to the general promise above, and we have set it out here rather than leave it unsaid.

If we add or change a provider, we will update this policy and its version number before the change takes effect.

6. Your information is disclosed overseas

Using Vestro means your personal information is handled by recipients outside New Zealand — presently in Australia, the European Union and the United States — as set out in section 5, and those recipients may store, process and support your information there.

New Zealand's Privacy Act 2020 sets rules for sending personal information overseas (information privacy principle 12). Before we send your information to a recipient overseas, we have to be satisfied, on reasonable grounds, that it will be protected in a way that, overall, gives you comparable safeguards to the Act — or tell you plainly that it may not be, and get your authorisation.

Our main providers are required by contract to protect it. Supabase, Render and OpenAI hold and process your information on our instructions only, to run Vestro. Each has agreed in writing to:

process your information only to provide its service to us, and not for its own purposes;
keep it secure, including by encrypting it while stored and while moving between systems, limiting who inside the company can reach it, and testing those controls;
put the same obligations on anyone it subcontracts to, and stay responsible to us for what that subcontractor does;
tell us promptly if its security is breached, so that we can tell you and the Privacy Commissioner when the law requires it; and
delete your information when we ask, or return it to us.

The exact words differ between providers, but on the strength of those agreements we rely on information privacy principle 12(1)(f): we believe on reasonable grounds that each of Supabase, Render and OpenAI is required, under an agreement with us, to protect your information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020.

Resend sends our emails, and it rests on a contract too. Resend (Plus Five Five, Inc.) sends our emails from the United States and receives your email address and the contents of the emails we send you. Its data processing addendum applies to our account with it and, like the agreements above, requires it to process that information only to provide its service to us, to keep it secure, to put the same obligations on anyone it subcontracts to, to tell us if it is breached, and to delete the information when we ask. On the strength of that agreement we rely on information privacy principle 12(1)(f) for Resend as well: we believe on reasonable grounds that it is required, under an agreement with us, to protect your information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020. The one difference is the narrow exception described in section 5 — the account and delivery records Resend keeps to run and secure its own service.

PostHog runs the app's analytics, and it rests on a contract too. PostHog keeps the usage information and session recordings described in section 2 in its EU cloud in Germany. PostHog, Inc. is a United States company, and its staff and service providers, including some in the United States, may process that information to run its service. PostHog's data processing agreement applies to our account with it and requires it to process the information only on our instructions and only to provide its service to us, to put the same obligations on anyone it subcontracts to and stay responsible to us for them, to tell us without undue delay if it is breached, and to delete the information when we ask (unless the law requires it to keep it, or it needs it to resolve a dispute or to stop harmful use of its service). On the strength of that agreement we rely on information privacy principle 12(1)(f) for PostHog as well: we believe on reasonable grounds that it is required, under an agreement with us, to protect your information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020.

Akahu is a New Zealand company, so it is a different case again. The connection service we use to link your brokerage account, Akahu Technologies Limited, carries on business in New Zealand and is subject to this Act. Our disclosure of your portfolio information to Akahu therefore rests on information privacy principle 12(1)(b) — the limb that applies where the recipient is carrying on business in New Zealand and we believe on reasonable grounds that it is subject to this Act. Your authorisation is not needed for that limb, and we are not required to warn you that Akahu may not protect your information, because Akahu is directly subject to the same Act we are.

Akahu keeps the information it collects in data centres in Australia, and it handles that storage under its own privacy notice (https://www.akahu.nz/privacy-notice), not under ours. We do not control where Akahu keeps what it holds.

Our market-data providers rest on your authorisation instead. We do not have an agreement like that with our market-data providers (currently Yahoo Finance and EOD Historical Data), which receive the ticker symbols we look up. We send it as little as we can, but we cannot promise it is required to protect it in a way that, overall, provides comparable safeguards to the New Zealand Privacy Act 2020. That recipient may not be required to protect your information in a way that, overall, provides comparable safeguards to those in the Act. By accepting this policy and using Vestro, you authorise us to disclose your personal information to that recipient on that basis. That is the authorisation described in information privacy principle 12(1)(a), and we are required to tell you this plainly, which is what the paragraph above does.

Apple and Google also rest on your authorisation. You choose to use them: to sign in, to subscribe through the App Store, or to receive push notifications. They handle what they receive in the United States under their own terms and privacy policies, which are not written for the New Zealand Privacy Act 2020, and we cannot promise that either is required to protect it in a way that, overall, provides comparable safeguards to those in the Act. Those recipients may not be required to protect your information in a way that, overall, provides comparable safeguards to those in the Act. By accepting this policy and choosing to use Apple or Google with Vestro, you authorise us to disclose your personal information to them on that basis (information privacy principle 12(1)(a)). If you would rather not, create an account with your email address instead, and leave push notifications off.

If you do not want your information disclosed overseas on those bases, please do not use Vestro, or contact us at [email protected] to discuss it.

7. How long we keep it

Your account and portfolio information: for as long as you have an account.
Your brokerage connection: for as long as you keep it connected. When you disconnect in the app, we ask Akahu to end our access and we delete the access credential we stored. Akahu's own privacy notice says it deletes the data it holds within 24 hours of that access being revoked, and you can also revoke it, or ask Akahu to delete what it holds, in your Akahu account at https://my.akahu.nz.
Your reports and analysis: for as long as you have an account, so that you can look back at them. They are deleted when you delete your account.
Your Vestro Intelligence questions and answers, and your investor level: for as long as you have an account. They are deleted when you delete your account.
How you use the app (PostHog): under our current PostHog plan, session recordings are deleted after 30 days and the rest of the usage information after 1 year. If you delete your account and want this deleted sooner, email [email protected] and we will ask PostHog to delete it.
Security records such as failed sign-in attempts: only for as long as they are needed to protect accounts from abuse, and then deleted.
Your push notification token: until you turn notifications off, delete your account, or Apple tells us the token no longer works, whichever comes first.
Your subscription records: for as long as you have an account, and afterwards only for as long as New Zealand tax and accounting law requires us to keep business records (up to 7 years). If you delete your account, the record of an App Store purchase is kept for that period without anything that links it to you, so that the number of founder places sold stays accurate.
Your invitation records (your code, who invited you or whom you invited, your free months and offers): for as long as you have an account. When an account is deleted, its invitation records are deleted with it, except that the person who invited it keeps the record that they earned a free month, with nothing that identifies who it came from. Without that record, deleting accounts and signing up again could be used to earn the same free month twice.
Your waitlist email address: until you ask us to remove it, or 24 months after we last emailed you. If you create an account, it becomes part of your account information.
After you delete your account: we delete your account, your portfolio information, your reports and your settings. Deletion from our live systems is immediate; copies may remain in routine backups for a short period (up to 30 days) before being overwritten.

We keep your information only for as long as we need it for the purposes in section 4. If you ask us to delete your information, we will do so unless we are required by law to keep it.

Vestro does not import by email. There is no address to forward trade-confirmation emails to, and Vestro does not read your email.

8. Cookies

This section has changed. Until 23 October 2026 our public website offered the Reddit pixel, an advertising tool that ran only if you accepted it. We have removed it, and our website and app no longer load anything from Reddit. Our website uses no advertising, tracking or analytics tools of any kind.

The app's analytics. The Vestro app uses PostHog for product analytics and session recordings (sections 2 and 5). To tell one visit from the next, PostHog keeps a random identifier in the app's storage on your device. It is not used for advertising, and it is not shared with other apps.

If you accepted the pixel before then, our website now clears the cookie it left and your recorded choice the next time you visit. You can also clear the cookies and site data for our website in your browser at any time. Removing the pixel does not delete what Reddit had already received; Reddit holds that under its own privacy policy.

The session cookie. We use a single session cookie. It identifies your signed-in session so you stay logged in while you use Vestro, and it disappears when your session ends. If you block the session cookie, you will not be able to sign in.

9. How we protect your information

We treat the security of your information as a core part of Vestro, and we take steps including:

encrypting information in transit between your device and our servers;
storing passwords in a scrambled (hashed) form rather than as text;
encrypting any broker access credential we hold;
isolating accounts from each other at the database level, so that one user's records cannot be read by another user's session;
storing your information where it is reachable only through our backend, with no public access path;
applying security headers, rate limits and request validation to our API; and
avoiding the logging of personal information in our application logs.

If something goes wrong. If we become aware of a privacy breach that is likely to cause serious harm, we will notify the Privacy Commissioner and the people affected, as required by sections 114 and 115 of the Privacy Act 2020. We will tell you what happened, what information was involved, and what we are doing about it, so that you can take steps to protect yourself.

10. Your rights

You have the right to ask for access to the personal information we hold about you (information privacy principle 6), and you can ask us to correct it if it is wrong (information privacy principle 7). You can also ask us to delete it, and you can delete your own account in the app at any time, under Account.

To make a request, email [email protected]. We will answer within 20 working days, and we may ask you to confirm your identity first. If you ask for a copy of your information, we will provide it in a common, usable format. If you ask us to correct something we do not agree is wrong, we will tell you why and, if you ask us to, attach a note of your correction request to the information.

There is no charge for making a request.

11. Children

Vestro is not designed for, or offered to, anyone under 18. We do not knowingly collect information from anyone under 18. If you believe someone under 18 has created an account, please tell us at [email protected] and we will close the account and delete the information in it.

12. Changes to this policy

The version and the date this policy takes effect are shown at the top of the page. If we change the policy, we will publish the new version and update the version number, and we will tell you in the app before the change takes effect. We will ask you to accept the new version where the change is significant, and we do not assume that accepting an earlier version means accepting a new one.

13. Complaints

If you are unhappy about how we have handled your personal information, please contact us first at [email protected] so we can try to put it right.

If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner:

Website: https://www.privacy.org.nz
Email: [email protected]
Phone: 0800 803 909