Privacy Policy

Effective as of: 2025-01-01

Introduction

This privacy notice for Artem Egorov ('we', 'us', 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

Download and use our mobile application (Spendlr), or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events

If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@spendlr.online. This SERVICE is provided by Artem Egorov is intended for use as is.

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.

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.

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: email address, when you register an account.
Data from third-party services: if you register through the account of other services 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 events.
Information about in-app purchases and subscriptions: data on subscription fees, and purchase history.
User-generated content: We do not analyze or track it.

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.

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.

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.

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.

Purpose	Type of Data	Lawful Basis for Processing
For authorization users when registering an account. Communication with users.	Account registration. Email address.	Performance of a contract with you. Your consent.
For authorization users when registering an account. Communication with users.	Data from third-party services (Facebook, Apple, Google): user ID, email address, profile photo.	Performance of a contract with you. Your consent.
For marketing and analytical purposes. To provide, improve and develop the application.	Device data (model, OS version, language).	Performance of a contract with you. Your consent.
For marketing and analytical purposes. To provide, improve and develop the app.	Usage data (how you use our app, user activity).	Performance of a contract with you. Your consent. Necessary for our legitimate interests.
To provide access to the application, identify the user, and track the subscription period.	Information about in-app purchases and subscriptions.	Performance of a contract with you. Your consent. Necessary for our legitimate interests. Necessary to comply with a legal obligation.
To use the software functions.	User-generated content.	Performance of a contract with you. Your consent.

Third-Party Services and Disclosures of Your Data

We share some of your Personal Data with our service providers, strictly limited to the cases and purposes stipulated in this privacy policy. We require all third parties to respect the security of your personal data and to treat it under the law.

We share your data with the parties set out below for the purposes set out in the table above:

We store your data on the servers of Hostinger.
We transmit and store analytical data on the analytical services of Firebase.

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;

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.

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. We use technical data encryption tools such as SSL protocols to keep your data secure.

We use Firebase and Google Cloud services, which may involve data processing in the United States. Data transfers are carried out under Standard Contractual Clauses (SCC), ensuring compliance with GDPR requirements. For more details on Google Cloud GDPR compliance, please visit: Google Cloud GDPR Compliance.

Data Retention

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law.

Analytics data: Collected through Firebase Analytics and stored for 14 months.
User data: Stored as long as the account remains active. Deleted upon user request or account deletion.

Children’s Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers.

What Are Your Privacy Rights?

If you would at any time like to terminate your account, you can log in to your account and delete your user account or/and data, or contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@spendlr.online.