Vengyr

Privacy notice

Your data, in plain words.

What personal data Vengyr holds, why, and what you can do about it. It covers this website and the Vengyr app.

Draft · not reviewed by a lawyer · not in forceVersion privacy-0.1-draft · Updated 25 October 2026

The short version

Who is responsible

The controller is António João Lopes Silvestre, founder of Vengyr, Luxembourg. Once the Vengyr company is formed, it takes over this role and we will update this notice. Contact: hello@vengyr.eu.

We have not appointed a data protection officer, because we do not monitor people at scale.

This website

This site sets no cookies, runs no analytics and loads nothing from other companies: fonts and images come from our own server. Our host keeps standard server logs (address, time, page requested) for security, for up to 30 days.

If you write to us for an invite, we keep your email and message only to reply and to send your invite, and delete them when the beta opens or when you ask.

What we hold in the app, and why

Your account

BasisContract

Sign-in id, email, base currency, chosen markets, your own limits and notes

Why
Run your account
Kept
Until you delete your account

Read-only keys

BasisContract

Exchange and broker keys that can’t trade or withdraw, sealed so no person can read them

Why
Read your balances and trades
Kept
Until you remove the key or delete your account

Your trading record

BasisContract

Trades read from your accounts, costs you type, price alerts, practice bots

Why
Show your holdings and gains, run practice tests, prepare tax exports for your own filing
Kept
Until you delete them or your account

Activity log

BasisContractLegitimate interest

What you did, in plain words

Why
Show you your own history; security; proof of what you accepted
Kept
Account life; after deletion only a bare event with no user id, for 5 years

Consent records

BasisLegal obligationLegitimate interest

Which text you saw, its version and your answers. No IP or device data

Why
Prove what you were told and accepted
Kept
The life of your account, then 5 years

Proof stamps

BasisLegitimate interest

Hashes only, never your data

Why
Prove when a setting or consent was recorded
Kept
5 years

Beta invites

BasisLegitimate interest

Email, who invited you, when you joined

Why
Limit sign-up to invited testers
Kept
Until the beta opens

Feedback

BasisLegitimate interest

What you send us from the app

Why
Fix what testers report
Kept
Until you delete your account

Balances and trades are not a special category under the GDPR, but they reveal wealth and behaviour, so we treat them as high risk: keys are sealed, each account is kept apart from every other, and no outside analytics run in the app.

What we never receive

  • Your trading key. It goes from your device straight into your own cloud account.

  • Your cloud project’s contents, except the health and trade receipts your bot sends back so the app can show them to you.

  • Card or bank details for trading. No money for trading passes through us.

Google sign-in and your bot

When you choose “Deploy my bot”, Vengyr asks you to sign in with Google and grant it permission on your own Google Cloud account. We use that permission for one purpose only: to create one project for your bot in your Google Cloud account and install the Vengyr runner there.

What we use

The permission you grant, only while setup runs. We don’t read your Gmail, Drive, contacts or any other Google data.

What we store

No Google data. The access token stays in your browser during setup and is never saved on our servers. We keep only the name of the project that was created, so the app can show your bot’s health.

When it ends

When setup finishes, Vengyr gives the access back by revoking the token. You can check this in your Google Account under “Third-party apps and services”, and remove it there yourself.

Sharing

We don’t share, sell or transfer any data received from Google, use it for ads, or use it to train AI models.

Vengyr’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Your bot runs in your own cloud account under your own contract with Google, and Google processes its data as your provider. Vengyr is not the controller of that data.

AI agents

The app’s agents are AI systems, and everything they write is marked as AI-generated. When you ask an agent something, we send your question and the figures needed to answer it to our AI provider, Anthropic (Claude), under terms that forbid it from training its models on your data. Anthropic processes it in the United States and keeps it for at most 30 days, unless its abuse checks flag a request or the law requires longer.

Who else receives data

Google Cloud

WhereEU (Belgium)

Hosting, database, key sealing

Receives
The data above

Zitadel

WhereEU

Sign-in

Receives
Sign-in id, email, two-factor

Anthropic

WhereUnited States

AI provider: answers to questions you ask agents

Receives
Your question and the figures needed

OpenTimestamps

WherePublic calendars

Public time-stamping

Receives
One hash, never your data

Exchanges, brokers and data providers receive nothing from us: your own keys call them, under your own agreement with them.

Transfers outside the EU

One: questions you ask an agent go to Anthropic in the United States. The safeguard is the EU Standard Contractual Clauses in Anthropic’s data processing terms. Everything else stays in the EU. If we add another transfer, we will list it here with its safeguard before it starts.

Optional uses

Product usage statistics, if we add them, will be off by default, under their own switch in Settings. Turning a switch off is as easy as turning it on, and withdrawing consent does not affect anything else in your account.

No automated decisions about you

Vengyr makes no automated decision with legal or similar effect about you. The app runs your own rules, with the limits you set.

Your rights

You can access, download, correct and delete your data, object to or restrict some uses, and withdraw consent at any time.

Download all my dataSettings, one file with everything we hold about you.

Delete my accountSettings. Removes every row that carries your user id in one step; only the bare activity events and proof hashes described above remain.

You can also write to hello@vengyr.eu. We answer within one month.

Complaints

You can complain to the Luxembourg data protection authority, the CNPD (cnpd.public.lu), or to the authority in your own country.

Changes

Each version of this notice carries a number and a date. If a change matters, we tell you in the app before it applies, and where it involves consent, we ask again.