Privacy Notice

Last Updated: [Dec 1, 2025]

Dimitropoulos Nikitas SP (“we,” “us,” or “our”) operates the pocketfolios.com website (the “Service”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

We collect several different types of information for various purposes to provide and improve our Service to you.

  • Personal Data: While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include, but is not limited to:

    • Email address

    • First name and last name

    • Payment information (processed directly by our secure payment processor; we do not store full credit card details)

    • Cookies and Usage Data

  • Usage Data: We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

2. How We Use Your Information

Dimitropoulos Nikitas SP uses the collected data for various purposes:

  • To provide and maintain the Service, including member-only access to portfolio allocation data.

  • To process your subscription payments.

  • To notify you about changes to our Service, including updates to model portfolios or disclaimers.

  • To provide customer support.

  • To gather analysis or valuable information so that we can improve our Service.

  • To monitor the usage of the Service.

  • To detect, prevent, and address technical issues.

  • To comply with legal obligations.

3. Legal Basis for Processing (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Notice depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:

  • We need to perform a contract with you (e.g., to provide the subscription Service you purchased).

  • You have given us permission to do so.

  • The processing is in our legitimate interests (to operate, improve, and secure our Service) and is not overridden by your rights.

  • To comply with the law.

4. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

5. Data Transfer & Disclosure

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.

  • To protect and defend the rights or property of Dimitropoulos Nikitas SP.

  • To prevent or investigate possible wrongdoing in connection with the Service.

  • To protect the personal safety of users of the Service or the public.

  • To protect against legal liability.

6. Your Data Protection Rights (GDPR & CCPA)

Depending on your location, you have certain data protection rights.

For EEA/UK Users (GDPR): You have the right to access, rectify, erase, restrict processing of, object to processing of, and request data portability for your Personal Data. Contact us to exercise these rights.

For California Residents (CCPA/CPRA): You have the right to know what personal information we collect, use, disclose, and sell. You have the right to request deletion of your personal information and to opt-out of the “sale” or “sharing” of your personal information. We do not sell your personal information. You also have the right to non-discrimination for exercising your CCPA rights.

To exercise any of these rights, please contact us using the details at the end of this notice.

7. “Do Not Track” Signals

We do not support Do Not Track (“DNT”). You can enable or disable DNT through your browser preferences.

8. Cookies

We use cookies and similar tracking technologies to track activity on our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

9. Service Providers

We employ third-party companies to facilitate our Service (e.g., payment processing, hosting, analytics). These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  • Payment Processors: We use Paddle to process subscription payments. Their use of your personal information is governed by their own Privacy Policy: [Link to Payment Processor’s Privacy Policy].

  • Analytics: We may use Google Analytics to understand usage trends. You can opt-out of Google Analytics.

10. Links to Other Sites

Our Service may contain links to other sites (e.g., financial news, broker websites). We are not responsible for the content or privacy practices of those sites.

11. Children’s Privacy

Our Service is not intended for anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under 18.

12. Changes to This Privacy Notice

We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page and updating the “Last Updated” date.

13. Contact Us

If you have any questions about this Privacy Notice, your data, or your rights, please contact us:

  • By email: info@pocketfolios.com

  • Through our website