Privacy Policy
Effective Date: December 23, 2024
Finance Bay (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy outlines how we handle user data and comply with global privacy requirements, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant laws.
1. Anonymized Data We Collect
Finance Bay operates with a commitment to user privacy and minimal data collection, ensuring that all app functionality runs locally on your device without collecting, storing, or processing any personal data.
a. Types of Anonymized Usage and Diagnostic Data
To improve the app and its functionality, Finance Bay collects strictly anonymized usage and diagnostic data. We take measures to ensure that this data cannot be re-identified or linked to any individual user.
Specifically:
- No Personal Identifiers: We remove or exclude any personal identifiers, such as names, email addresses, IP addresses, or device IDs.
- Aggregated Data: The data we use is combined and aggregated so it cannot be traced back to any single device or user.
Examples of the types of anonymized data we may collect include:
- Feature usage frequency (e.g., how often certain app features are accessed)
- App performance metrics (e.g., load times, responsiveness)
- Crash logs and error reports to identify and fix technical issues
2. Data Usage and Retention
While using Finance Bay:
- No personal or identifiable information is tracked, analyzed, or stored.
- Anonymized diagnostic data is used solely for improving product quality, app stability, and enhancing user experience.
- Data Retention Practices: We retain anonymized diagnostic data only as long as necessary to analyze and improve our services. After this period, the data is either deleted or further aggregated so it cannot be linked back to any individual. As we do not collect personal data, no personal data retention periods apply.
3. Payment Processing and Refunds
Finance Bay integrates with RevenueCat for payment processing and subscription management.
In the event of a refund request:
- Consumption Data Sharing: RevenueCat may share certain consumption data with Apple to facilitate the process. This may include details such as the account’s age, the total amount of subscription fees paid, the number and amount of previous refunds issued, and the type of device platform on which the subscription was used.
- This data is subject to the privacy policies of Apple and RevenueCat, which govern its use.
- Finance Bay itself does not collect, store, or process this consumption data.
4. Links to Third-Party Websites
Finance Bay may contain links to third-party websites or services for your convenience. Please note:
- We do not control or endorse the privacy practices of these third-party websites.
- Users are responsible for reviewing the privacy policies of any third-party websites they visit to understand how their data will be handled.
Finance Bay is not liable for any data collected, stored, or processed by these third-party services.
5. Compliance with Global Privacy Laws
We adhere to the highest standards of data privacy and comply with the following frameworks:
- General Data Protection Regulation (GDPR): Our processing of anonymized diagnostic data falls under our legitimate interests to improve the app’s functionality and user experience, as allowed under the GDPR. We do not rely on consent or contractual necessity as we do not process personal data.
- California Consumer Privacy Act (CCPA): We do not collect or sell personal information. All data we handle is anonymized, ensuring full compliance with CCPA.
- Brazilian General Data Protection Law (LGPD): While we do not collect personal data, we acknowledge that users in Brazil have rights under LGPD, such as confirmation of data processing, data portability, anonymization, and revocation of consent (if consent-based processing were to occur in the future).
- Virginia Consumer Data Protection Act (VCDPA): If you are a resident of Virginia, please note that no personal data is collected by Finance Bay. Should this change, you would have rights under the VCDPA, including the right to access, correct, delete personal data, and opt-out of personal data processing for targeted advertising and sales, if applicable in the future.
- Other Applicable Laws: Finance Bay complies with privacy regulations in all regions where the app is available.
6. Third-Party Services
Finance Bay integrates with third-party services, including RevenueCat, for subscription management, payment processing, and app functionality improvements. These services may process anonymized usage and diagnostic data to improve service reliability and performance. Additionally, as noted above, consumption data is shared with Apple and RevenueCat strictly for refund processing and compliance with applicable regulations.
7. Security
Finance Bay prioritizes the security of user data:
- Anonymized diagnostic data is stored securely, with strong technical and organizational measures in place. These measures may include encryption at rest, secure data transfer protocols, and restricted access controls to ensure that only authorized personnel can access this data.
- Because no personal data is collected or maintained, the risk of re-identification is minimized.
8. User Rights
Because we do not collect or process personal data, the following rights are inherently fulfilled:
- Right to Access: There is no personal data to access.
- Right to Erasure: There is no personal data to delete.
- Right to Portability: There is no personal data to transfer.
- Right to Rectification: Because we do not collect personal data, there is no personal information to correct. If you believe that RevenueCat, Apple, or any other third-party service provider we integrate with may have personal data associated with you, please review their respective privacy policies and exercise your rights directly with them.
- Right to Know About Data Sales and Sharing: We do not sell or share personal data with third parties. If you have concerns about data handled by RevenueCat or Apple, please review their policies.
- Right to Opt-Out of Data Sale: Since we do not sell personal data, there is no need to opt-out. Should this practice change in the future, we will update this policy and provide a clear method for you to opt-out.
- Right to Lodge a Complaint: If you believe that your rights have been violated, you have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where an alleged infringement of data protection laws has occurred.
If you have concerns about your data in connection with RevenueCat’s payment processing or Apple’s refund process, please refer to their respective privacy policies. If you believe these services are processing personal data, you can exercise your data subject rights directly with them.
9. Children’s Privacy
Finance Bay is not intended for use by children under the age of 13, and we do not knowingly collect any personal information from children. In the event that we become aware that a child under 13 has provided us with personal information, we will promptly delete it in accordance with applicable laws and regulations.
10. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or regulatory requirements. Changes will be posted in the app, and the effective date will be updated accordingly.
11. Contact Us
- Data Controller: Finance Bay operates as the Data Controller for the anonymized data it processes. You may contact the Data Controller at:
Name: Arkadiusz Szczepkowicz
Email: support@financebay.co
If you have unresolved concerns, you may also have the right to contact your local data protection authority.
By using Finance Bay, you acknowledge and accept the terms of this Privacy Policy. Thank you for trusting us to safeguard your privacy.