Privacy Policy

Draft — not yet legally reviewed. The substance is written from the app's actual code and database schema rather than boilerplate, so it should be factually accurate, but the bracketed placeholders must be filled in and a lawyer should review it before publication. This file is the single source of truth: it is bundled into the app and should also be the copy hosted at your public policy URL.

Effective date: [effective date]

Last updated: [last updated date]

This Privacy Policy explains how [Company/Developer name] ("Swivvy", "we", "us", "our") collects, uses, discloses and safeguards your information when you use the Swivvy mobile application and related services (together, the "Service").

Please read this policy carefully. By using the Service you agree to the collection and use of information in accordance with it. If you do not agree, please do not use the Service.

One point deserves emphasis up front, because it is unusual and central to how Swivvy works: Swivvy is collaborative by design. When you join a group or connect with another user, certain information about you — your display name, your picture, and the expenses and balances you are party to — becomes visible to those people. That is the function of the app, not an incidental disclosure.

1. Who we are and how to contact us

The data controller responsible for your personal information is [Company/Developer name], [registered address].

For any privacy question, request or complaint, contact us at [support email].

If you are in the EEA or the UK, you also have the right to lodge a complaint with your local supervisory authority.

2. Information you provide

• Account information. Your email address, a password, a username and a display name.

Passwords are stored only as salted hashes by our authentication provider; we never see or store your password in plain text.

• Profile information. An optional profile picture.
• Financial and group data. Group names and descriptions, expense descriptions, amounts,

currencies, split methods, payment dates, settlement records, and the balances derived from them.

• Payment handles. Optional usernames or handles for third-party payment apps, such as a

PayPal.Me name, a Venmo handle or a UPI id. These are identifiers only. We never collect card numbers, bank account numbers, or payment credentials of any kind.

• Receipt images. Photographs of receipts you scan or upload, and the text extracted from

them.

• Communications. The contents of bug reports and any correspondence you send us.

3. Information collected automatically

• Device and push identifiers. If you enable notifications, a token identifying your device

installation.

• Diagnostic data. Crash reports and error diagnostics, which do not include the contents

of your expenses or receipts. You can disable this in Settings, under Preferences.

• Advertising identifiers. The free version displays advertising, and our advertising

partner may access your device's advertising identifier. See section 8.

4. Information from other users

Other users may add you to a group, send you a request, or record an expense that includes you. Information about you may therefore reach the Service without you entering it — for example, a member of a group may add your name to it, or attach a picture to a name that has no account attached to it.

5. What we do not collect

• We do not access your device's address book or phone contacts. Connections in Swivvy are

made only by username or by scanning a QR code.

• We do not collect precise location data.
• We do not access your photo library beyond the specific images you choose to scan or

upload, and we do not access your microphone.

• We do not collect payment card or bank account details, because we never process

payments. See section 7.

6. How we use your information

• To create, secure and administer your account.
• To provide the core functions of the Service: recording expenses, calculating balances,

splitting bills and tracking settlements.

• To read receipts you scan, extracting merchant, date, total and line items.
• To let other users find and connect with you by username or QR code.
• To send you notifications about activity relevant to you, such as being added to a group

or having a payment recorded against you.

• To convert between currencies, by sending currency codes and dates — never information

about you — to our exchange-rate providers.

• To display advertising in the free version of the Service.
• To diagnose faults, prevent abuse and improve the Service.
• To comply with our legal obligations.

7. Swivvy does not move money

Swivvy is a record-keeping tool. We are not a bank, a payment processor, a money transmitter or an escrow service, and we never hold, transfer or take a cut of your money.

The "Settle up" feature opens a third-party payment app with details pre-filled from the handles you provided. Any payment happens entirely within that third party's app, under their terms and their privacy policy. We are not a party to it and receive no confirmation that it took place.

8. Advertising

The free version of the Service displays advertising supplied by Google AdMob. AdMob may use your device's advertising identifier to limit repetition, measure performance and, in some regions and subject to your consent, personalise the ads you see.

You can reset or clear your advertising identifier in your device settings: on Android, under Privacy and then Ads; on iOS, under Privacy and Security and then Tracking. Google's own practices are described at https://policies.google.com/technologies/ads.

We do not give advertisers your expenses, balances, receipts, contacts or account details.

9. Legal bases for processing (EEA and UK users)

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

• Performance of a contract, to provide the Service you signed up for, including syncing

your data between the members of your groups.

• Legitimate interests, to secure the Service, prevent abuse, diagnose faults and improve

the product, balanced against your rights and freedoms.

• Consent, for optional processing such as push notifications, crash reporting and

personalised advertising where required. You may withdraw consent at any time.

• Legal obligation, where we must retain or disclose information to comply with law.

10. How your information is shared with other users

This is the principal way your information is shared, and it is inherent to the Service:

• Members of a group can see that group's expenses, amounts, dates, categories, receipt

images, balances and settlement records, including those involving you.

• Members of your groups and your accepted contacts can see your display name, your

username and your profile picture.

• A user settling up with you can retrieve the payment handles you chose to save, so their

payment app can be pre-filled.

• Individual requests are visible to both parties to that request.

11. How your information is shared with service providers

We use a small number of processors, each handling data only on our instructions:

• Supabase, for database, authentication and file storage hosting.
• Google Firebase, for push notification delivery and crash reporting.
• Google AdMob, for advertising in the free version.
• Google ML Kit, for receipt text recognition. This runs on your device; receipt images are

not sent to Google for this purpose.

• Frankfurter, using European Central Bank data, and a fallback exchange-rate provider, for

currency conversion. Only currency codes and dates are sent.

12. Other disclosures

We may disclose information where we believe in good faith that it is necessary to comply with a law, regulation, legal process or enforceable governmental request; to enforce our Terms of Service; to detect or address fraud, security or technical issues; or to protect the rights, property or safety of Swivvy, our users or the public.

If we are involved in a merger, acquisition or sale of assets, your information may be transferred. We will give notice before your information becomes subject to a different privacy policy.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising as those terms are defined under applicable US state privacy laws.

13. Data retention

• Account and financial data is retained while your account exists.
• Receipt images are deleted automatically 15 days after upload. A per-user storage cap

also applies.

• Expenses recorded by others are retained after you delete your account where removing

them would corrupt another member's balances. The record remains but is no longer linked to your account.

• Diagnostic data is retained for the period set by our crash reporting provider.
• Bug reports are retained until resolved and for a reasonable period afterwards.

14. Deleting your account

You can delete your account at any time from Settings, under Account and Profile, then Delete account. Deleting your account:

• removes your profile, contacts, payment handles, profile picture and push tokens;
• deletes any group you solely own, and transfers ownership instead where other members

remain; and

• retains historical expense records in groups you shared, unlinked from your account, so

that other members' balances remain correct.

This action is irreversible.

15. Security

We protect your information with encrypted connections for all traffic, row-level security policies that restrict every record to the users entitled to see it, private storage for receipt images and pictures, and per-account separation of any data cached on your device.

No method of transmission or storage is completely secure and we cannot guarantee absolute security. You are responsible for keeping your password confidential.

16. International transfers

Our providers may process and store information in countries other than your own, including the United States. Where information is transferred out of the EEA or the UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

17. Your rights

Depending on where you live, you may have the right to:

• access the personal information we hold about you;
• correct inaccurate or incomplete information;
• delete your information, as described in section 14;
• object to or restrict certain processing;
• receive your information in a portable format;
• withdraw consent where processing is based on consent; and
• not be treated differently for exercising these rights.

To exercise any of these, contact [support email]. We may need to verify your identity before acting, and we will respond within the period required by applicable law.

Note that we cannot delete information from another user's records where doing so would misstate what they are owed.

18. Children

The Service is not directed to children under 13, or under 16 where local law sets a higher age, and we do not knowingly collect their personal information. If you believe a child has provided us information, contact [support email] and we will delete it.

19. Changes to this policy

We may update this policy from time to time. If we make material changes we will notify you in the app or by email before they take effect, and we will update the "Last updated" date above. Continued use of the Service after changes take effect constitutes acceptance.

20. Contact

[Company/Developer name]

[registered address]

[support email]