Spendtacle Privacy Policy
This Policy explains what personal data is processed when you use the Spendtacle app and its server side (the "Service"), why, on what legal basis, for how long, and what rights you have. This Policy forms part of the Terms of Use.
1. Summary
- Your financial records stay on your device. Transactions, categories, accounts, budgets and plans are stored only in the app on your iPhone. We do not receive or see them.
- Only what a specific feature needs is sent to our server: account data, a receipt photo when you recognize it, a monthly summary when you request a monthly review, your messages and a financial summary in the AI assistant chat, subscription data and your support requests.
- We do not sell personal data, show ads, use advertising identifiers or third-party analytics SDKs, or track you across other apps and websites.
- You can delete your account in the app and all data on your device at any time.
2. Who processes your data
Controller: Airat Baiburov, an individual entrepreneur registered in Georgia, identification number 306538155, address: Police Lane l5, Tbilisi, Georgia ("we").
For privacy questions, write to privacy@spendtacle.com or use Settings → Feedback with the topic "Personal data".
We process data in accordance with the Law of Georgia on Personal Data Protection and with the mandatory data protection rules of your country of residence to the extent they apply.
The full version of the Service (account, AI features, Premium) is offered only in the countries listed in section 4 of the Terms of Use. In other countries a local version works: it has no account, AI features, purchases or support requests through our server, all data is stored only on the device, and the app only gets exchange rates and the list of full-version countries from the server, anonymously (section 3). We therefore do not process personal data of local-version users. App Store notifications about purchases from such countries, if any arrive, are not applied, stored or logged by the server.
3. Data that stays on your device
The following data is stored only locally in the app and is not sent to us: transactions (amounts, dates, titles, notes, merchants), categories and budgets, accounts and transfers, planned payments, saved monthly reviews, AI assistant chat history, settings, selected currencies, and CSV files you import or export.
- Backups. iOS may include app data in iCloud or computer backups according to your Apple settings. Apple processes those backups; we have no access to them.
- Face ID and passcode. Verification is performed by iOS. The app receives only a "success" or "failure" result and never receives biometric data.
- Camera and photos. Access is requested only to take or choose a receipt photo. Images are sent to the server only when you start recognition yourself.
- Payment reminders are scheduled locally by iOS and do not pass through our server.
- Exchange rates and app settings. The app gets exchange rates and the list of full-version countries from our server anonymously: without signing in, without cookies or device or account identifiers, and with the same technical headers for all users. The IP address the request comes from is not passed to our API service and is not recorded in logs. The request contains only the currencies and dates for which rates are needed.
4. Data we process, why and on what basis
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account: internal ID, email (if provided by the sign-in provider or entered by you), name (if provided), identifier at the sign-in provider (Apple, Google), sign-in methods, creation date, a technical token linking App Store purchases | Creating the account, sign-in, linking the subscription, limits | Performance of contract (the Terms) | While the account exists, then deleted (section 7) |
| Email sign-in: address, hash of the one-time code, attempt and send counters | Verifying the address, protection against brute force and spam | Performance of contract; legitimate interest in security | Code valid for 10 minutes, counters up to 1 hour |
| Sessions: hash of the session token (the token itself is not stored), creation and expiry dates | Keeping you signed in | Performance of contract | Until sign-out, account deletion or expiry (up to 90 days) |
| Receipt photos (up to 5 images), language, your list of expense categories and subcategories, the current date on your device; the recognition result (merchant, date, amount, line items) | AI receipt recognition | Performance of contract | Photos are not stored on our server: they are processed in memory and sent to Anthropic. The recognition result is kept only in the server's memory for up to 24 hours so the app can retrieve it after a lost connection or restart; it is never written to disk and is deleted together with your account. Anthropic's retention is in section 5 |
| Monthly summary: income and expenses by category for the current and previous month, budgets, up to 10 largest expenses (date, title, category, amount), line items from recognized receipts | AI monthly review (Premium) | Performance of contract | Not stored on our server, sent to Anthropic |
| AI assistant chat: the text of your messages and earlier turns of the current conversation, language, and a financial summary from the app: income and expenses for the current and three previous months, spending by category and budgets, up to 10 largest expenses of the current month (date, title, category, amount), account names, types, currencies and balances, planned payments and income for the current and next month (name, date, amount, currency, recurrence, status). Transaction notes and receipt photos are not sent | AI assistant answers to your questions about your personal finances in the Service (Premium) | Performance of contract | Not stored on our server: processed in memory and sent to Anthropic. Chat history is stored only on your device |
| Usage counters: number of recognized receipts, reviews and AI assistant messages per day | Applying free and Premium limits | Performance of contract | Up to 8 days |
| Subscription: App Store transaction data (transaction and original transaction ID, product ID, purchase, expiry and revocation dates), App Store notifications about renewals and refunds | Providing Premium, verifying purchases, record-keeping | Performance of contract; legal obligation (accounting and tax) | While the account exists and thereafter for the period required by law for accounting records |
| Support requests: topic and text, reply email (if given), account ID and email (if signed in), app version, iOS version, device model, language (unless you turn their sending off) | Answering you, fixing bugs, improving the Service | Legitimate interest; performance of contract | Up to 24 months after the last message, longer if needed to defend against claims |
| Server logs: IP address, time, request method and path, response code, duration, user ID in error records. IP addresses are not recorded for exchange rate requests (section 3) | Security, abuse prevention, diagnostics | Legitimate interest | Deleted automatically within 14 days |
We do not process special categories of personal data and ask you not to submit any. A receipt may show what you bought, the store, place and time, and sometimes the last digits of a card: by sending a photo, you decide what it contains. Do not send identity documents, full card numbers or other people's data. The same applies to messages in the AI assistant chat: you write the message text yourself, so do not include health information, passwords, document or card numbers or other people's data in it.
Where a particular processing requires your consent, we will ask for it separately. You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
5. Who we share data with
We share data only with providers the Service cannot work without, and only to the extent necessary. They process data on our behalf or as independent controllers under their own rules.
- Amazon Web Services (Amazon Lightsail): server hosting, Frankfurt region, Germany (EU).
- Anthropic PBC (USA): receipt recognition, monthly review and AI assistant chat answers by Claude models via the commercial API. Under Anthropic's terms as of this version, API data is not used to train models and is deleted on Anthropic's side within 30 days, except as provided in their policies (for example, usage policy enforcement or legal requirements).
- Apple: Sign in with Apple, the App Store (purchases and subscription notifications), iOS system features. Apple acts as an independent controller under its own privacy policy.
- Google: only if you choose to sign in with Google. With your permission they send us your identifier, email and name.
- Google LLC (USA), Google Workspace: email for the spendtacle.com and finsyapp.com domains, sending sign-in codes, delivering and storing support requests and our correspondence with you.
- Exchange rate sources: our server requests rates itself; your data is not shared with them. The app does not contact them directly.
- Authorities: where required by law or a court order, or to protect the rights, life and safety of people.
- Successor: if the Service or the business is transferred, data may pass to the new owner, who will be bound by this Policy.
6. International transfers
We are based in Georgia, the server is in the EU and Anthropic is in the USA. Transfers outside Georgia are made in accordance with the Law of Georgia on Personal Data Protection, in particular under agreements with providers containing appropriate data protection safeguards or other mechanisms provided by applicable law. You can request information about these safeguards using the contacts in section 2.
7. Deleting your account and data
- Account: Settings → Delete account. The account, sign-in methods, sessions and counters are deleted immediately. Transaction records are kept only where the law requires it.
- Data on your device: Settings → Delete all transactions (transactions, accounts and payments), Settings → Delete chat history (AI assistant conversations), or delete the app. We cannot delete or recover data on your device or in your backups.
- Your subscription is not cancelled by deleting your account: cancel it in your Apple ID settings.
- Data of a deleted account remains in server backups for no longer than 14 days, after which the backups are overwritten.
8. Your rights
To the extent provided by applicable law, you have the right to:
- be informed about processing and obtain a copy of your data;
- have inaccurate data corrected;
- have your data erased;
- restrict processing;
- receive your data in a machine-readable format and transmit it to another controller (you can export on-device data to CSV yourself);
- object to processing based on legitimate interest;
- withdraw consent where processing is based on it;
- lodge a complaint with a supervisory authority: in Georgia, the Personal Data Protection Service (personaldata.ge); in another country, the authority designated by the law of your country of residence, if there is one.
We will respond within one month. This period may be extended where the law allows, and we will tell you if so. To protect your data, we may ask you to confirm that the request comes from the account holder, for example by writing from the email address linked to the account.
9. Security
We use reasonable technical and organizational measures: encrypted connections (TLS), storing session tokens and one-time codes only as hashes, data minimization, rate limiting and restricted server access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. We will notify you and the supervisory authority of incidents affecting your data where the law requires it.
10. Children
The Service is not intended for persons under 16, and we do not knowingly collect their data. If you believe a child has provided us with data, contact us and we will delete it.
11. Automated processing
AI suggests receipt data and categories, generates a text monthly review and answers your questions in the AI assistant chat. These are suggestions that you review and accept yourself. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. We do not use your data for advertising profiling.
12. Changes to this Policy
We may update this Policy. The new version is published at spendtacle.com/legal/privacy with its effective date. We will notify you of material changes in advance in the app or by email. Where a change requires your consent, we will ask for it.
13. Language
This Policy is made in Russian and English. In case of discrepancy, the Russian version prevails, unless mandatory applicable law requires otherwise.