Privacy Policy

1. Who is responsible for your data

The data controller is Dinis Miguel da Silva Costa, tax ID (NIF): 176280340. For any privacy question: dinismiguelcosta@gmail.com.

2. What data we process

Account: name, email and a hash of your password (we never store the password itself). If you enable two-factor authentication we store the authenticator secret encrypted and only hashes of the recovery codes.

Financial data you enter: transactions, categories, groups and budgets, and your investment records. If you complete the investor-profile questionnaire, we store your answers.

Subscription: plan, status and payment references. Card, IBAN or MB WAY phone details are collected directly by EasyPay and never pass through our servers. For purchases made in the Android app, payment happens on Google Play: we only keep the purchase identifier, the product and the subscription status that Google sends us.

Preferences: interface language and, on Android, whether you enabled biometric lock (stored only on your phone; the app never receives your fingerprint or face).

Technical data: your IP address is used to infer your country (through a local database, without sending it to third parties) and to limit abusive attempts; we keep security logs (for example failed sign-in attempts) without passwords, codes or the content of your data.

3. Why we use the data and on what legal basis

To provide the service you asked for (managing finances, subscriptions, forecasts and statistics): performance of a contract.

Account security and abuse prevention (attempt limits, security logs, 2FA): legitimate interest.

Complying with applicable legal obligations, such as tax and invoicing: legal obligation.

Artificial-intelligence features only send data when you use them (see section 5).

4. Who we share data with (processors)

MongoDB Atlas — hosting of the database that stores your data.

Netlify — application hosting; processes the requests made to the app, including your IP address.

EasyPay — payment processing (card, direct debit, MB WAY, Multibanco).

Google (Google Play) — distribution of the Android app and payment of subscriptions bought inside it. Google handles those payments as the seller, under its own privacy policy; to link the purchase to your account we only send Google an encrypted account identifier (never your name, email or financial data from the app).

Anthropic — provider of the AI model used for the features described in section 5.

Twelve Data — market data and exchange rates. It only receives market symbols and currency pairs, never personal data or your amounts.

Sentry — technical error monitoring, configured not to send request content, cookies or headers.

Some of these providers may have subprocessors or infrastructure outside the European Economic Area; in that case the safeguards required by the GDPR apply, in particular the European Commission's Standard Contractual Clauses.

5. Artificial intelligence — what is sent

Statistics insights (Pro and Premium plans): we send aggregated figures (totals per month and category) and category names — never the descriptions of your transactions.

Investment tips (Premium plan): we send your investor-profile answers, an aggregated summary of your finances and the day’s market context. We do not currently send any data from your investment records (portfolio); if that changes, this policy is updated first.

Suggested budget (Premium plan): for each expense category we send its name and already-calculated monthly totals (average, minimum, maximum), your expected monthly income and the working-capital and savings percentages you choose — never the descriptions of your transactions. Only when you ask for a proposal, at most once a month.

Document scanning (Pro and Premium plans): the image or PDF you upload is sent to Anthropic to extract the fields, processed in memory and not stored by us. Avoid uploading documents with personal data that is not needed (for example tax ID or address on a payslip).

AI-generated content is for information only, may contain errors and is not financial advice.

6. How long we keep the data

As long as your account exists. When you delete your account (Settings → Privacy and data) we delete your data from the database. Backups may keep the data until 3 years before being overwritten.

We may retain only what is strictly necessary to meet legal obligations (for example invoicing records) for the period the law requires.

7. Your rights

Access and portability: in Settings → Privacy and data you can download all your data as JSON.

Erasure: in the same section you can delete your account and all associated data. If you have an auto-renewing subscription, it is cancelled first. If you no longer have access to the app, request deletion by email to dinismiguelcosta@gmail.com from the address linked to the account.

Deleting data without deleting your account: you can delete transactions, categories, groups and investments individually in the app at any time. To request deletion of other specific data without deleting your account, email dinismiguelcosta@gmail.com from the address linked to your account.

Rectification: you can correct your data directly in the app. You also have the right to restriction and objection; contact us at dinismiguelcosta@gmail.com.

You may lodge a complaint with the Portuguese data protection authority (CNPD), www.cnpd.pt, or your local authority.

8. Cookies and local storage

We only use strictly necessary cookies: "session" (keeps you signed in, up to 30 days), "pending_2fa" (10 minutes, only during two-factor verification) and "financeflow_locale" (your language). We also keep your biometric-lock preference in your phone’s local storage. We do not use advertising or behavioural analytics cookies.

9. Security

Passwords stored as hashes (scrypt), signed sessions, attempt limiting, optional two-factor authentication, 2FA secrets encrypted at rest and encrypted connections (HTTPS). No system is infallible; if a data breach affecting you occurs, we will notify you and the authority as required by law.

10. Changes

If we make material changes to this policy we will tell you in the app. Last updated: 2026-10-09.