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Millgrade — Privacy Policy

Last updated: 5 August 2026 · Effective: 5 August 2026

1. Who we are

This website and service (millgrade.com — "Millgrade", "we", "us", "our") is operated by Mill 97, s.r.o., a company incorporated in the Slovak Republic, with registered office at Severná ulica 195/27, 915 01 Nové Mesto nad Váhom, company ID (IČO) 55 872 841. Mill 97, s.r.o. is the controller of the personal data described in this policy.

We process personal data in accordance with the GDPR (Regulation (EU) 2016/679) and the Slovak Data Protection Act No. 18/2018 Z.z.

Privacy contact: support@millgrade.com.

2. What personal data we collect

  • Account data — your email address and authentication details, handled through our authentication provider (Clerk).
  • Portfolio holdings — the ticker symbols (and any notes) you choose to save to track your holdings. See section 4.
  • Usage data — the companies you validate, your validation history, your Credit balance and purchases, and your interactions with the product.
  • Payment data — Credit purchases are one-time payments handled by our payment processor (Stripe, including Apple Pay / Google Pay). We do not store full card details.
  • Technical data — IP address, device/browser information, and server logs, used for security, rate-limiting, and error monitoring.
  • Cookies — we currently use only strictly necessary cookies required for authentication and security. We do not use analytics or advertising cookies. If we introduce them, we will first add a consent banner and a separate Cookie Policy.

3. How we use your data, and our lawful bases (GDPR Art. 6)

  • To provide the service (scoring, validations, the Brief, your account) — performance of a contract, Art. 6(1)(b).
  • Security, abuse/fraud prevention, rate-limiting, error monitoring — our legitimate interests, Art. 6(1)(f).
  • To send the daily Brief and essential service emails — performance of a contract (for subscribers). Promotional emails, if any, are sent only with your consent (Art. 6(1)(a) GDPR) and every such email includes an unsubscribe link.
  • To meet legal, tax and accounting obligations — legal obligation, Art. 6(1)(c).
  • Analytics / non-essential cookies (when live) — consent, Art. 6(1)(a).

Where processing is based on your consent, it is voluntary and you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal. Where processing is necessary to perform a contract, not providing the data may mean the contract cannot be performed.

4. Portfolio holdings

When you save holdings, we store the tickers you enter so we can generate your personalised daily Brief (which flags when a company's news, price, or standing verdict has diverged from what our record says).

Your holdings can reveal information about your financial circumstances. They are not "special category" data under Art. 9 GDPR, but we treat them with care: we use them only to provide the Brief and related features, and we never sell them.

5. Automated processing

Millgrade's quality scores and verdicts are produced by an automated, rule-based model applied identically to every company. They are assessments of companies, not decisions about you, and they produce no legal or similarly significant effect on you within the meaning of Art. 22 GDPR.

6. Who we share your data with (processors and sub-processors)

We share personal data with service providers who process it on our behalf under data-processing agreements. We do not sell your personal data.

  • Clerk — authentication
  • Resend — transactional email
  • DigitalOcean — database & hosting
  • Upstash — caching & rate-limiting
  • Financial Modeling Prep (Utradea Inc.) — market/fundamentals data — Canada
  • NewsAPI — news data
  • Sentry — error monitoring
  • Stripe — payments (when live)

7. International transfers

Some providers are located outside the EEA (for example in the US and Canada). Where personal data is transferred outside the EEA, we rely on an adequacy decision or on Standard Contractual Clauses (or equivalent safeguards).

8. How long we keep your data

  • Account and holdings data — while your account is active, and for up to 30 days after you close it (backup rotation), after which they are deleted or irreversibly anonymised.
  • Validation history — the link between your account and the validations you ran is kept while your account is active and deleted with it. (The dated record of verdicts itself is product data about companies, retained as part of the service; it is not personal data.)
  • Server logs — up to 90 days, for security and troubleshooting.
  • Billing/tax records — as required by Slovak law.

9. Your rights

Under the GDPR you have the right to access, rectification and completion, erasure ("right to be forgotten"), restriction of processing, data portability, and objection, and to withdraw consent at any time (without affecting processing already carried out). To exercise these rights, contact support@millgrade.com. We may apply lawful restrictions — for example where we are obliged to retain certain data or need it to establish or defend legal claims.

You also have the right to lodge a complaint with the Slovak supervisory authority — the Office for Personal Data Protection of the Slovak Republic (Úrad na ochranu osobných údajov Slovenskej republiky), which publishes a sample complaint form at dataprotection.gov.sk.

10. Security

We protect your data with measures including encryption in transit, access controls, a managed database, error monitoring, and rate-limiting. No system is perfectly secure and we cannot guarantee absolute security.

11. Cookies

We currently use only strictly necessary cookies (authentication, security). A consent banner and a full Cookie Policy will be added before any analytics or non-essential cookies are introduced; non-essential cookies will be used only with your consent.

12. Children

Millgrade is not directed to children and is intended for users aged 16 and over. We do not knowingly collect personal data from children.

13. Changes to this policy

We may update this policy. We will post the updated version with a new "last updated" date and, for material changes, notify you.

14. Contact

Mill 97, s.r.o., Severná ulica 195/27, 915 01 Nové Mesto nad Váhom. Privacy contact: support@millgrade.com.