Last updated: June 17, 2025

About This Privacy Policy

This Privacy Policy explains how FRONTIERE BLEUE LTD ("we", "us", "our") collects, uses, protects, and shares your personal information when you use our Nestor mobile application ("App") and related services ("Services").

We are committed to protecting your privacy and being transparent about how we handle your personal data. This policy is designed to help you understand:

What personal information we collect and why
How we use your personal information
Your choices and rights regarding your personal information
How we protect your personal information

By using our App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with any part of this policy, please do not use our Services.

Who We Are

FRONTIERE BLEUE LTD is a UK company registered in England and Wales under company number 16508951.

Registered Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

We are the data controller for the personal information you provide to us or that we collect about you when you use our Services.

We are not regulated by the Financial Conduct Authority (FCA) and do not provide financial advice or regulated financial services.

Information We Collect

We collect different types of information to provide and improve our Services:

Information You Provide Directly

Account Information:

Email address (if you choose to provide it)
Name or username (if you choose to provide it)
Profile preferences and settings

Onboarding Information:

During your initial app setup, we collect generic information to help us improve our services:

Why you downloaded the app
What you hope to achieve with dividend tracking
The main challenges you face when tracking dividends
How you heard about our app

This information is used solely for analytics and understanding user needs - it does not include any personal financial data.

Communication Data:

Correspondence when you contact our support team
Feedback, reviews, or survey responses
Any other information you choose to provide

Important Note About Portfolio Data:

Your historical transaction data from Trading212 CSV files is stored locally on your device only
We do not collect, access, or store your portfolio information, trading history, or financial data
This data never leaves your device and is not transmitted to our servers

Information We Collect Automatically

Technical Information:

Device information (type, model, operating system, version)
App usage data (features used, time spent, frequency of use)
Performance and crash data
General location (country level only)

Analytics Data:

How you navigate through the App
Features you use most frequently
Time and date of App usage
Error logs and diagnostic information for bug fixes

This analytics information is generic and does not connect to individual user financial data or personal portfolios.

Information from Third Parties

Financial Market Data:

Real-time and historical stock prices
Dividend payment information
Company financial data
Market indices and sector information

This market data is sourced from financial data providers and does not involve sharing any user personal data.

Social Media:

We maintain social media pages but do not collect user data through these platforms

How We Use Your Information

We use your personal information for the following purposes:

Core App Functionality

Provide our Services: Enable core dividend tracking, portfolio management, and analytics features
App Performance: Monitor app functionality and fix bugs or errors
User Experience: Improve app navigation and feature usability

Service Improvement and Analytics

App Enhancement: Improve existing features and develop new ones based on usage patterns
User Research: Analyze onboarding responses to understand user needs and challenges
Performance Monitoring: Track app performance and identify areas for improvement

Communication and Support

Customer Support: Respond to your inquiries and provide technical assistance
Service Updates: Notify you about important changes, updates, or security alerts

Important: We do not process, analyze, or use any personal financial data, portfolio information, or trading history as this data remains on your device only.

Legal Basis for Processing

Under UK GDPR, we must have a legal basis for processing your personal data. We rely on the following legal bases:

Contractual Necessity (Article 6(1)(b)):

Providing our Services as outlined in our Terms and Conditions
Managing your account and user authentication (when implemented)

Legitimate Interests (Article 6(1)(f)):

Improving our Services and user experience
Analytics and performance monitoring
Security and fraud prevention
Understanding user needs through onboarding data

Consent (Article 6(1)(a)):

Marketing communications (where required)
Optional features or data collection
Future features requiring explicit consent

Legal Obligation (Article 6(1)(c)):

Compliance with applicable laws and regulations
Responding to lawful requests from authorities

You have the right to object to processing based on legitimate interests. Contact us to exercise this right.

Sharing Your Information

We do not sell, rent, or trade your personal information. We may share limited information in the following circumstances:

Service Providers

We work with trusted third-party service providers who help us operate our Services, but we do not share user personal data with them:

Financial Data Providers:

We source market data (stock prices, dividend information) from financial data providers
No user personal data or portfolio information is shared
These providers supply general market information only

Technology Partners:

App hosting and infrastructure services
Analytics and performance monitoring tools
Only generic, non-personal usage data is shared for app improvement purposes

App Distribution:

Apple App Store Connect for app hosting and distribution
Payment processing through Apple App Store (for future premium features)
We do not control or access payment information processed by Apple

Legal Requirements

We may disclose your information when required by law or to:

Comply with legal obligations, court orders, or regulatory requests
Protect our rights, property, or safety, or that of our users
Prevent fraud or security threats
Enforce our Terms and Conditions

Business Transfers

If we're involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We'll notify you before your information becomes subject to a different privacy policy.

Data Storage and Transfers

Current Data Storage

UK-Based Storage:

Personal data is primarily stored in UK data centers
We maintain redundancy in European data centers for backup purposes
Currently, we do not transfer data outside the UK/EU

Local Device Storage:

Your Trading212 transaction data and portfolio information is stored locally on your device only
This data is never transmitted to our servers or third parties
You maintain complete control over this data

Future Enhancements

We may introduce web access in the future, which could require additional data handling
Any changes to our data storage practices will be clearly communicated
We will update this Privacy Policy and seek appropriate consent before implementing changes

Data Security

We implement appropriate technical and organizational measures to protect your personal information:

Technical Measures

Local Data Protection: Your financial data stays on your device with your device's built-in security
Encrypted Transmission: Any data transmitted to our servers is encrypted using industry-standard protocols
Access Controls: Role-based access with multi-factor authentication for our team
Regular Security Testing: Penetration testing and vulnerability assessments
Secure Development: Security-by-design principles in our development process

Organizational Measures

Staff Training: Regular data protection and security training for all employees
Access Limitations: Personal data access limited to authorized personnel only
Data Processing Agreements: Contracts with all service providers ensuring data protection
Incident Response: Procedures for detecting, reporting, and responding to security incidents

Your Role in Security

Protecting Your Device:

Keep your device secure - your financial data security depends on your device security
Use strong device passwords or biometric locks
Keep your device and App updated
Don't share your device with unauthorized users
Store your device safely - loss of device could mean loss of your financial data

Account Security:

Use strong, unique passwords for any future authentication features
Don't share account credentials
Report any suspicious activity immediately

Please note: No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this policy:

Active Accounts

Account Information: Retained while your account is active
Onboarding Data: Retained for analytics and service improvement (typically 3 years)
Usage Analytics: Typically retained for 2-3 years for service improvement
Local Financial Data: Under your complete control - retained until you delete the app

Inactive Accounts

Account Deletion: Accounts inactive for 3 years may be deleted
Data Deletion: Personal data deleted within 30 days of account closure
Legal Retention: Some data may be retained longer if required by law

Specific Retention Periods

Support Communications: 3 years from last contact
Analytics Data: 3 years for service improvement
Security Logs: 1 year for security monitoring
Onboarding Responses: 3 years for user research

Your Local Data: Deleting the app removes all locally stored financial data from your device.

You can request deletion of your account and personal data at any time by contacting us.

Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

Right of Access (Article 15)

Request confirmation of what personal data we hold about you
Receive a copy of your personal data
Understand how and why we process your data

Right to Rectification (Article 16)

Correct inaccurate personal data
Complete incomplete personal data

Right to Erasure (Article 17) - "Right to be Forgotten"

Request deletion of your personal data in certain circumstances
Particularly when data is no longer necessary or consent is withdrawn

Right to Restrict Processing (Article 18)

Limit how we use your personal data in certain circumstances
Useful when disputing accuracy or lawfulness of processing

Right to Data Portability (Article 20)

Receive your personal data in a structured, machine-readable format
Transfer your data to another service provider

Right to Object (Article 21)

Object to processing based on legitimate interests
Object to direct marketing at any time

Rights Related to Automated Decision-Making (Article 22)

Not be subject to significant automated decisions without human oversight
Request review of automated decisions

How to Exercise Your Rights

Contact us using the details in the "Contact Us" section below.

We will respond to your request within one month. In complex cases, we may extend this by up to two months and will inform you of any delay.

Verification: We may need to verify your identity before responding to requests.

No Fee: Exercising your rights is generally free, though we may charge a reasonable fee for excessive or repetitive requests.

Cookies and Tracking Technologies

Current Implementation

We do not currently use cookies in our mobile app. The app functions without requiring cookies or similar tracking technologies.

Future Implementation

If we implement web access or other features requiring cookies in the future:

We will clearly notify you of any cookie usage
Provide options to manage cookie preferences
Update this Privacy Policy accordingly
Seek appropriate consent where required

Third-Party Analytics

Our analytics tools may use similar technologies to understand app usage, but this data is:

Anonymous and generic
Not linked to individual users
Used solely for app improvement purposes

Third-Party Services

Our App integrates with limited third-party services:

Financial Data Providers

Purpose: Real-time stock prices, dividend data, company information Data Shared: No user personal data shared Privacy: We source general market data only

App Distribution Platform

Purpose: App hosting and distribution through Apple App Store Data Shared: App usage statistics (generic, non-personal) Privacy: Subject to Apple's privacy policies for app distribution

Analytics Services

Purpose: App performance monitoring and improvement Data Shared: Anonymous usage data and technical information Privacy: Subject to strict data processing terms, no personal identification

Trading212 Relationship

Important: Trading212 is a data source only, not a data sharing partner:

Users voluntarily download their own data from Trading212
Users upload this data to our app for local processing
We do not have any direct integration or data sharing with Trading212
Any Trading212 data issues must be resolved directly with Trading212

Future Services

Authentication service (planned for future implementation)
Payment processing through Apple App Store
Any new integrations will be disclosed and require appropriate consent

Important: Third-party services have their own privacy policies. We encourage you to review these policies when accessing external services.

Children's Privacy

Our Services are not intended for children under 18 years of age.

We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

How We Notify You of Changes

In-App Notifications: Significant changes will be announced in the App
Email Notifications: We'll email you about material changes (if you've provided an email)
Updated Date: The "Last updated" date at the top will reflect recent changes
Version History: Previous versions available upon request

Types of Changes

Material Changes: Significant changes to how we collect, use, or share your data will require your consent or provide you with opt-out options.

Technical Updates: Minor changes for clarity or legal compliance may be implemented immediately.

Your Continued Use: Using our Services after changes are posted constitutes acceptance of the updated policy.

Contact Us

Data Protection Queries

For questions about this Privacy Policy or your personal data:

Email: privacy@frontierebleue.co.uk

Post: FRONTIERE BLEUE LTD, Data Protection Officer, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

General Support

For general questions about our Services:

Email: support@nestordividendtracker.co.uk

In-App: Use the support feature within the App

Complaints

If you have concerns about our privacy practices:

Contact us first using the details above - we'll work to resolve your concern
Information Commissioner's Office (ICO): If unsatisfied with our response, you can lodge a complaint with the UK's data protection authority:
- Website: https://ico.org.uk/make-a-complaint/
- Phone: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Additional Information

Regulatory Context

This Privacy Policy is designed to comply with:

UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Privacy and Electronic Communications Regulations (PECR)
Consumer Rights Act 2015

Financial Services Disclaimer

We are not regulated by the Financial Conduct Authority (FCA). Our App provides information and tracking tools only - not financial advice. For regulated financial advice, consult an FCA-authorized adviser.

Accessibility

This Privacy Policy is available in alternative formats upon request. Contact us if you need this information in a different format to make it accessible to you.

Thank you for trusting us with your personal information. We're committed to protecting your privacy and being transparent about our data practices.