Privacy Policy

Introduction

Welcome to the “Saldo: Finance Management App” privacy policy. We respect your privacy and are committed to protecting your data. This privacy policy will inform you as to how we look after your data when you use our app and tell you about your privacy rights and how the law protects you.

Іmportant information and who we are. Purpose of this privacy notice

This privacy policy aims to give you information on how “Saldo: Finance Management App” collects and processes your data through your use of this app, including any data you may provide through our app when you sign up. By accepting this privacy policy, you further certify that you have full legal capacity and capacity and are of the age required by the laws of the State of Delaware, USA, or other state, country of which you are a citizen, to accept these terms. You will be required to read and accept this privacy policy before using the application. By using the application YOU MESSAGE TO US that: (i) YOU READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (ii) YOU ARE MORE than 14 years old (or EXCEED THAT YOUR PTA or guardian reads and AGREE TO THIS PRIVACY POLICY FOR YOU). If you don’t accept and agree to this Privacy Policy, you must immediately stop using our app. You must read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller and contact details

Saldo apps Inc., is the controller and responsible for your data (collectively referred to as “Сompany”, “we”, “us” or “our” in this privacy policy).

Our full details are: Company name: Saldo apps Inc. Email address: [email protected] legal address: 651 N Broad St. Suite 201, Middletown, New Castle, DE, postal code 19709

Changes to the privacy policy

We reserve the right to and may change this privacy policy from time to time. If we make any material changes, we will notify you through our app, or email, or by presenting you with a new version of this privacy policy for you to accept, if we, for example, add new processing activities or collect some additional personal data from you. Your continued use of the app after the effective date of an updated version of the privacy policy will indicate your acceptance of the privacy policy as modified. In some cases, you will have to accept changes to the privacy policy explicitly.

Types of data We collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We automatically collect, use, store and transfer different kinds of personal data about you which we have grouped as follows: Account registration. Username, (how a user refers to themselves. For example, their first name, last name, or nickname), email address, phone number, when you register an account. Data from third-party services. If you register through the account of other сervices such as Facebook, Apple, or Google you provide us with a user ID, email address, and a photo from the profile. Device data. Includes model, OS version, language. Usage Data. Includes information about how you use our app, user activity within the application, app event; Financial information. Includes information about merchant name, expense category, expense date, expense description, expense amount, report name, report currency, number of expenses in the report, report amount, expense receipt photo, purchase history. Added by the user independently. Information about subscription. Data on subscription fees, and purchase history. We also collect, use, and share Aggregated Data such as statistics or demographics. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific our app feature. However, if we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the privacy policy («data minimization principle»)

Lawful bases for processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Consent. You have given clear consent for you to process their personal data for a specific purpose.
Contract. The processing is necessary for a contract you have with us.
Legitimate interests. The processing is necessary for our legitimate interests or the legitimate interests of a third party.

We may process your data if you have given us specific consent to use your personal information for a specific purpose. If you share with us the personal data of a third party, you confirm that such a third party gave you consent on the collection and processing of his/her data by us. We in turn will take the same measures and procedures to ensure the safety of such information as we do in relation to your data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on you to process your data where more than one ground has been set out in the table below.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
For authorization users when registering an account. Communication with users.	Account registration. Username, (how a user refers to themselves. For example, their first name, last name, or nickname), email address, phone number, when you register an account.	Performance of a contract with you. Your agreement.
For authorization users when registering an account. Communication with users.	Data from third-party services. If you register through the account of other сervices such as Facebook, Apple, or Google you provide us with a user ID, email address, a photo from the profile.	Performance of a contract with you. Your agreement.
For marketing and analytical purposes. To provide, improve and develop the application.	Device data. Includes model, OS version, language.	Performance of a contract with you. Your agreement.
For marketing and analytical purposes. To provide, improve and develop the app.	Information about how you use our app, user activity within the application.	Performance of a contract with you. Your agreement. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).
To use the software functions and create reports.	Іnformation about merchant name, expense category, expense date, expense description, expense amount, report name, report currency, number of expenses in the report, report amount, expense receipt photo.	Performance of a contract with you. Your agreement.
To provide access to the application, identify the user, and track the subscription period.	Data on subscription fees, and purchase history.	Performance of a contract with you. Your agreement. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). Necessary to comply with a legal obligation.

Third-Party Services and disclosures of your data

We share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this privacy policy. We’ll not use the information gained through your use of our app for resell. We require all third parties to respect the security of your personal data and to treat it under the law. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section “Types of data We collect” of this privacy policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We disclose potentially personally-identifying information (i.e. Personal Data) among our employees, contractors and affiliated or other third party organizations that (i) need to know that information in order to process it on Company’s behalf or to provide services available at Company, and (ii) that have agreed not to disclose it to others. Cross-border transfer of personal data. Some of those employees, contractors and affiliated or other third party organizations may be located either within or outside of the USA, EU or the European Economic Area (EEA); by using the our app, you consent to the transfer of such information to them. We share your data with the parties set out below for the purposes set out in the table above. Internal Third Parties: companies inside our Group. External Third Parties: UserX LLC, Amplitude, Inc., UserX LLC, DigitalOcean, LLC. These parties analyze your data and show relevant information about the app to us or help us with the storage of Personal Data when you use the app, to understand how you use the app, engage with particular features and what you like or dislike the most to generate statistical reports. We store your data on the servers of our partner DigitalOcean (Digital Ocean, LLC). We transmit and store your data on the analytical services of our partners, namely Amplitude (Amplitude, Inc), and UserX (UserX LLC). We use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our app, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end-user privacy policy. In most cases, we provide our partners with aggregated and anonymous user data (so that it can no longer be associated with you). We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and under our instructions.

We may disclose User provided and automatically collected Information:

as required by law, such as to comply with a subpoena or similar legal process;
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules outlined in this privacy statement;
if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We don’t use user data for sale (or any other commercial activity) to other companies. User’s data is used solely to ensure the functionality of the software.

Opt-out options.

You can withdraw your consent or opt-out, whatever applies in your case, from sharing your Personal Data under this subsection anytime by using one of the following options:

By contacting us at [email protected].
By adjusting your device settings in iOS or Android.
Stop using our application.

Obtaining data from third parties

When a user buys a subscription, we receive transaction data, ID subscriptions, subscription terms, application statistics from the App store and Google play. We also receive information from third parties if you register through the account of other services such as Facebook, Apple, or Google. By registering in the app and gaining access to the service, you can use the mail, name, and passwords of accounts of other services such as Facebook, Apple, or Google. The collection, processing, and transmission of data on purchase via the Apple store are further regulated by the App Store, Google Play, Google, Facebook, and Apple, data processing policy. If you register through the account of other services such as Facebook, Apple, or Google you provide us with a user ID, email address.

Banking information

When you pay for a subscription to our app, you share your banking information with the App Store or Google Play. This relationship is further regulated between the user and privacy policy of the App store and Google Play. We do not collect or process your bank information when buying a subscription.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We also use technical data encryption tools such as SSL protocols to keep your data secure.

Data retention

How long will you use my personal data? We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements. We store your data while you use our application. In some circumstances, you can ask us to delete your data. To send an email to our address: [email protected]. In some circumstances, we anonymize your data (so that it can no longer be associated with you) for research or statistical purposes in which case we use this information indefinitely without further notice to you. We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and under our instructions. We do not use user data for sale (or any other commercial activity) to other companies. User data is used solely to ensure the functionality of the app.

Your legal rights

Under the legislation of the US and European Union, you have the right to:

receive information, namely, what personal data we process and why (disclosed by this policy);
Right to Erasure. You have the right to delete data under certain circumstances.
Right to Rectification/to be forgotten. You have the right to ask us to correct your inaccurate data, as well as the right to make additions to it.
Right to access. You can request a copy of your data.
Right to restriction of the processing. In certain cases, you have the right to request the termination of data processing by allowing the continued storage of data.
Right to data portability. You can request a copy of your data in a machine-readable form that can be transferred to another person who processes the personal data.
Right to object to marketing. Under certain circumstances, including when data is processed for legitimate interests or marketing purposes, you may object to such processing.
Rights related to automated decision-making, including profiling. In this area, there are several rights related to the fact that processing carried out exclusively on an automated basis can lead to a decision that has legal and other significant consequences for a person. In such circumstances, you have the right to human interference in the decision-making process.
Right to withdraw consent. For example, you can withdraw your consent to receive letters or phone calls
Right to complain to the relevant data protection authority

If you wish to exercise any of the rights set out above, please contact us. What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response. Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Glossary

In this Policy the following terms shall have the following meanings:

Lawful basis.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

California privacy rights

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States. For more details about the personal information we have collected, including the categories of sources, please see in section the “Types of data We collect”. We collect this information for purposes described in section “Purposes for which we will use your personal data” of this privacy policy. We may also share your information with certain categories of third parties as indicated in Section “Data retention”. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. California consumers may make a request under their rights under the CCPA by contacting us at [email protected]. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

Contacts

Email address: [email protected]