Polityka prywatności
Effective from: _______Obowiązujący dokument jest na razie dostępny tylko w języku angielskim. Polska wersja zostanie opublikowana po weryfikacji prawnej.
1. Who we are
1.1. This Privacy Policy explains how we process personal data when you use the InferMoney mobile application (the "App") and, to the limited extent described in section 10, our website at https://infermoney.com (the "Website").
1.2. The controller of your personal data is Stanislau Malchykau, an entrepreneur conducting business under the business name Stanislau Malchykau, address: ul. Pokorna 2 lok. 506, 00-199 Warsaw, Poland, NIP 5253064010, REGON 542930334 ("we", "us" or "our").
1.3. You can contact us about personal data at supportinfermoney@gmail.com or by post at the address above.
2. What data we process, why and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Creating and maintaining your account, including account emails | Email address, password (stored only as a hash), account settings | Performance of the contract (Art. 6(1)(b) GDPR) |
| Providing the App's functions and syncing them across your devices | Profile (name, language, default currency, avatar); accounts, transactions, categories, budgets, goals, emergency fund and investment positions; notes and journal entries with photos; unfinished journal drafts | Performance of the contract (Art. 6(1)(b) GDPR) |
| Account security | PIN code hash (if you turn the PIN on); device name, platform, operating system and App version, time of last sign-in; the first five characters of a hash of your password, checked against known data breaches when you register or change your password | Performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in protecting accounts (Art. 6(1)(f) GDPR) |
| AI Features (paid users only) | Data described in section 3; AI usage counter | Performance of the contract (Art. 6(1)(b) GDPR) |
| Managing your subscription | Internal user ID, purchase and subscription status received from the App Store or Google Play | Performance of the contract (Art. 6(1)(b) GDPR) |
| Answering support requests | Subject and text of your message, reply email, App version, device, language, screenshots you attach | Performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in handling enquiries (Art. 6(1)(f) GDPR) |
| Crash and error reports | Data described in section 4.2 | Our legitimate interest in keeping the App stable (Art. 6(1)(f) GDPR) |
| Usage statistics | Data described in section 4.1 | Your consent (Art. 6(1)(a) GDPR) |
| Accounting and tax obligations | Subscription transaction records | Legal obligation (Art. 6(1)(c) GDPR) |
| Establishing, exercising or defending legal claims | Data relevant to the claim | Our legitimate interest (Art. 6(1)(f) GDPR) |
Providing your data is voluntary, but without the data needed to create and maintain your account we cannot provide the App.
Sensitive data. We do not request special categories of personal data, such as data concerning your health. Please do not enter such data, or personal data about other people, in your notes, journal or support requests.
3. AI Features
3.1. The AI Features are available only with a paid subscription, and data is sent to our AI provider only when you use them.
3.2. Monthly report. For a completed month, we send a summary for each segment of your account, comprising income and expenses by category, planned and actual budget figures, the six-month trend, your accounts and their balances, investment positions, savings goals and your emergency fund.
3.3. Journal. We send the text you write or dictate in the journal chat.
3.4. AI provider. The AI Features are provided by Anthropic Ireland, Limited, acting as our processor, and the data may be processed by Anthropic, PBC in the United States. The provider does not use the data to train its models and deletes it within 30 days, unless longer retention is needed to enforce its usage policy or is required by law.
4. Usage statistics and crash reports
4.1. Usage statistics. With your consent, we use PostHog to record which App functions you use, linked to your internal user ID, in order to improve the App. Usage statistics remain switched off until you give your consent when you first open the App. You may withdraw your consent at any time in the App settings, without affecting the lawfulness of processing carried out before its withdrawal.
4.2. Crash reports. When the App crashes or an error occurs, we use Sentry to receive technical information about the error, the App and operating system version, the device model and your internal user ID, in order to fix the error. Your email address and access tokens are removed before the report is sent.
5. Who receives your data
5.1. We use the following service providers, who process personal data on our behalf and only on our instructions, namely Supabase (database, sign-in and account emails; servers in Frankfurt, Germany), Anthropic (AI Features; USA), Sentry (crash reports; servers in Germany), PostHog (usage statistics; servers in Germany), RevenueCat (subscription management; USA), Resend (sending support requests; USA) and Cloudflare (Website hosting; global network including the USA). Support requests are received in our mailbox provided by Google.
5.2. Apple and Google process subscription payments and, where you use voice input in the journal, your audio, as independent controllers under their own terms.
5.3. We may also disclose personal data to public authorities where the law requires it, and to our legal and accounting advisers bound by confidentiality.
6. Transfers outside the EEA
Some of our service providers are located in the United States or may access data from there. Such transfers are based on the EU–US Data Privacy Framework where the recipient is certified under it (Art. 45 GDPR), and otherwise on standard contractual clauses approved by the European Commission (Art. 46(2)(c) GDPR). You may obtain a copy of the applicable safeguards by contacting us at supportinfermoney@gmail.com.
7. How long we keep your data
7.1. We keep your account data and the content you enter in the App for as long as your account exists. If you request deletion of your account, it is deleted after a 30-day grace period, during which you may cancel the deletion by signing in again. If you reset all data in the App, the content is deleted immediately. Deleted data may remain in backups until they are overwritten in the regular backup cycle.
7.2. Our AI provider deletes the data it receives within 30 days, unless longer retention is needed to enforce its usage policy or is required by law. We keep crash reports until the error is fixed, usage statistics until they are no longer needed for analysis or until you withdraw your consent, and support requests until the request is resolved and any related claims are time-barred.
7.3. We keep subscription transaction records for as long as tax and accounting law requires, generally 5 years from the end of the calendar year in which the tax payment deadline expired. Website access logs are kept for the short period set by our hosting provider. Where data is needed for a legal claim, we keep it until the claim is resolved and time-barred.
8. Your rights
8.1. You have the right to access your personal data and obtain a copy of it, to have it rectified or erased, to restrict its processing, to receive the data you provided in a structured, commonly used and machine-readable format and have it transmitted to another controller, and to object to processing based on our legitimate interests (Articles 15 to 18, 20 and 21 GDPR). Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before its withdrawal.
8.2. You may exercise these rights by writing to us at supportinfermoney@gmail.com. You can also correct most of your data, export it and delete your account directly in the App.
8.3. You have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland, or with the data protection authority of the country where you live or work.
9. Risks of using online services
Using any online service involves risks such as phishing, malware on your device and interception of data on insecure networks. To reduce them, use a strong password, keep your device and the App updated and download the App only from the App Store or Google Play. We will never ask for your password by email or messenger.
10. Website
Our Website uses no cookies or trackers. Our hosting provider, Cloudflare, logs visitors' IP addresses for security purposes (Art. 6(1)(f) GDPR).
11. Users outside the European Economic Area
If the law of your country gives you rights regarding your personal data, you may exercise them by contacting us at supportinfermoney@gmail.com. We do not sell your personal information or share it for cross-context behavioural advertising.