Privacy Policy

Last updated: 30 September 2026

Version: 1.1

1. Introduction

This policy describes how balance collects, uses, stores and protects your personal data when you use our personal finance management app. We are committed to respecting your privacy and to protecting your data in accordance with the General Data Protection Regulation (GDPR) and applicable Italian law.

2. Data controller

The data controller is Vittorio D'Alfonso, sole trader operating the balance app, VAT number 06411680652.

For requests about your personal data: team@trybalance.eu

3. Personal Data We Collect

3.1 Identification Data

  • First and last name: To personalise your experience
  • Email address: For authentication and communications
  • Username: Your unique identifier in the app
  • Avatar/profile picture: Optional, for personalisation

3.2 Financial Data

  • Financial accounts: Name, type, opening balance, currency
  • Transactions: Amounts, descriptions, dates, categories, notes
  • Budgets: Amounts allocated to spending categories
  • Savings goals: Targets, deadlines, progress
  • Aggregated data: Statistics and analytics about your finances
  • Imported bank statements: If you import a PDF bank statement, the file is processed without being stored; the extracted transactions are saved as a draft for you to review
  • Onboarding questionnaire: Monthly income range, spending habits and financial situation you provide during onboarding

3.3 Authentication Data

  • Login credentials: Email and, if you sign in with a password on the website, your password stored only in hashed form
  • OAuth tokens: For signing in with Google and Apple
  • Sessions: Session tokens, expiry dates, IP address, user agent
  • Verification codes: Temporary one-time passwords (OTPs) for email verification
  • Biometric data: The Face ID/Touch ID lock is optional and the check is handled by your device's operating system: balance never receives or stores biometric data

3.4 Settings Data

  • Language preferences: Italian, English
  • Default currency: Euro, USD, other currencies
  • Notification settings: Times, types, permissions
  • Display preferences: Theme, balance blur
  • Onboarding status: Your progress through the app introduction

3.5 Technical Data

  • IP address: For security and access analysis
  • User agent: Information about your browser and device
  • Timestamps: Dates and times of operations
  • System logs: For debugging and improving the service
  • Cache data: To improve performance
  • Push notification token: To send you the notifications you have allowed
  • App usage data: Screens viewed, usage events and recordings of your sessions in the app (PostHog), linked to your account
  • Subscription data: Your account identifier and in-app purchase status (RevenueCat)
  • Advertising attribution events: Install, sign-up, sign-in and subscription start, with price and currency (TikTok)

4. Purposes of Processing

4.1 Main Purposes

  • Personal finance management: Providing tools to track expenses, income and budgets
  • Authentication: Verifying your identity and managing secure access
  • Personalisation: Tailoring the experience to your preferences
  • Financial analysis: Generating reports and insights from your data
  • Savings goals: Tracking your progress towards your goals
  • Bank statement import: Automatically extracting and categorising transactions from the PDFs you upload
  • Subscriptions: Managing access to paid features

4.2 Technical Purposes

  • Security: Preventing fraud and unauthorised access
  • Performance: Optimising the app’s speed and stability
  • Debugging: Identifying and fixing technical problems
  • Backup: Ensuring continuity of service
  • Usage analytics: Understanding how the app is used in order to improve it
  • Advertising measurement: Measuring the effectiveness of our TikTok advertising campaigns

4.3 Communication Purposes

  • Service notifications: Daily reminder, monthly report, recurring payments and instalments, bank statement import results
  • Verification codes: Sending sign-in codes by email
  • Customer support: Responding to your requests
  • Service updates: Information about new features

5. Legal Basis for Processing

5.1 Consent (Art. 6(1)(a) GDPR)

For processing data that is not strictly necessary, such as:

  • Push notifications (permission requested by the operating system)
  • TikTok advertising tracking on iOS, active only if you allow it through App Tracking Transparency
  • Marketing communications (if introduced)

5.2 Performance of a Contract (Art. 6(1)(b) GDPR)

To provide the services you request:

  • Account management and authentication
  • Storage and processing of financial data
  • Budgeting and tracking features
  • Importing the bank statements you upload
  • Subscription management

5.3 Legitimate Interest (Art. 6(1)(f) GDPR)

To improve the service and keep it secure:

  • IT security and fraud prevention
  • Performance optimisation
  • Debugging and troubleshooting
  • Usage statistics and recordings of your sessions in the app (PostHog)
  • Advertising campaign measurement (TikTok) on Android devices

6. How We Process Data

6.1 Data Collection

  • Direct: Data you enter in the app
  • Automatic: Technical data generated by your use of the app
  • OAuth: Profile data from external providers (Google, Apple)

6.2 Storage

  • PostgreSQL database: Structured data, on our hosting provider's servers
  • Redis cache: Temporary data for performance
  • Secure storage: Session token in the device Keychain (iOS) or Keystore (Android)
  • Local storage: Preferences and a temporary copy of your data for faster loading (on your device only)

6.3 Processing

  • Automated: Financial calculations and statistics
  • Batch processing: Processing of recurring transactions
  • Real-time: Instant updates and notifications
  • Artificial intelligence: For imported bank statements, the text extracted from the PDF and the transactions (description, merchant, amount, date) are sent to Mistral AI for extraction and categorisation

7. Data Sharing

7.1 Data sharing

We do not sell or rent your personal data. Data is shared only with the providers and in the cases described in the following sections.

7.2 Service Providers

  • Hosting provider: Servers, database and cache that run balance
  • Google: Signing in with a Google account
  • Apple: Signing in with an Apple ID; in-app purchases through the App Store
  • Google Play: In-app purchases on Android
  • Expo: Sending push notifications and app updates
  • RevenueCat: Subscription management. Payments are handled by Apple and Google: we never receive your card details
  • PostHog: Usage statistics and recordings of your sessions in the app (servers in the European Union)
  • TikTok: Advertising campaign measurement through install, sign-up, sign-in and subscription events
  • Mistral AI: Extracting and categorising transactions from imported bank statements
  • Resend: Sending service emails and communications about balance
  • Email provider (SMTP): Sending verification codes

7.3 Legal Obligations

We may share your data when required by:

  • Judicial or police authorities
  • Regulatory authorities
  • Other legal obligations

8. International Data Transfers

Some providers may process your data outside the European Economic Area, including in the United States:

  • Google OAuth: Authentication data processed by Google
  • Apple Sign-In: Authentication data processed by Apple
  • Expo Services: Notification and update services
  • RevenueCat: Subscription data
  • TikTok: Advertising attribution events
  • Resend: Email address and email content

For these transfers we rely on the safeguards provided for by the GDPR, such as adequacy decisions or standard contractual clauses approved by the European Commission.

9. Data Retention

9.1 Retention Criteria

  • Active account data: Until the account is deleted
  • Deleted account data: Immediately and irreversibly deleted from our database
  • Sessions: Expire automatically after 30 days without use
  • Verification codes: Expire after 5 minutes
  • Cache: Expires automatically (see 9.2)
  • System logs: Kept for as long as needed for debugging
  • Data held by third-party providers: Kept according to each provider's policies (section 7.2); you can ask us to have it deleted

9.2 Cache and Performance

  • Redis cache: Your account data expires automatically after a few minutes up to about one hour, depending on the type
  • Local cache: The copy on your device is discarded if older than 24 hours

10. Security Measures

10.1 Technical Security

  • Encryption: HTTPS for data in transit between the app and our servers
  • Authentication: One-time code by email, sign-in with Google or Apple, or email and password on the website
  • Isolation: Each request can only access the signed-in user's data

10.2 Organisational Security

  • Restricted access: Only the controller and people he has authorised

10.3 Mobile Security

  • Biometric authentication: Optional app lock with Face ID/Touch ID
  • Secure storage: Session token in the Keychain (iOS) or Keystore (Android)
  • Automatic lock: With the biometric lock on, the app asks for Face ID/Touch ID again after it has been in the background

11. Your Rights

11.1 Right of Access (Art. 15 GDPR)

You have the right to obtain confirmation as to whether your personal data is being processed and to access that data. You can view your data in the app or request a full copy by email.

11.2 Right to Rectification (Art. 16 GDPR)

You can correct or update your personal data at any time in the app settings.

11.3 Right to Erasure (Art. 17 GDPR)

You can delete your account from the app settings: your account and all associated data are immediately and irreversibly deleted from our database. For data held by third-party providers, you can write to us.

11.4 Right to Data Portability (Art. 20 GDPR)

You can request to receive your data in a structured, commonly used and machine-readable format.

11.5 Right to Object (Art. 21 GDPR)

You can object to the processing of your data for direct marketing purposes or on legitimate grounds.

11.6 Right to Restriction (Art. 18 GDPR)

You can request the restriction of processing in specific circumstances, such as while the accuracy of your data is being verified.

11.7 Withdrawal of Consent

Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

12. Exercising Your Rights

12.1 How to make a request

You can use the features available in the app settings or write toteam@trybalance.eu. To obtain a copy of your data, please send a request by email.

12.2 Response Times

We respond to requests without undue delay and in any event within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will let you know.

12.3 Complaints

You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or with the competent supervisory authority if you believe that the processing of your data infringes the GDPR.

13. Changes to this Policy

We may update this policy from time to time to reflect changes in our practices, technology or regulations. Material changes will be communicated through:

  • A notification in the app
  • An email to registered users
  • An update to the “last updated” date

We recommend checking this page periodically to stay informed about our commitment to protecting your privacy.

14. Children

balance is not intended for children under 16. We do not knowingly collect personal data from children under 16. If we become aware that a child under 16 has provided personal data, we will delete it immediately.

15. Contact

For questions about this policy or requests relating to your data, write toteam@trybalance.eu with the subject line “Privacy + reason for your request”. You can also contact us from the app settings.

16. Effective Date

This policy is effective from 30 September 2026 and supersedes all previous versions. Continued use of the app after changes are published constitutes acceptance of the updated policy.