Privacy Policy

Introduction

SpendIntent, operated by Maximilichain, Lda ("we", "our", or "us"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you use our mobile application and related services.

Who we are (data controller)

SpendIntent is operated by Maximilichain, Lda, the data controller for the personal data processed through the SpendIntent app and this website.

• Company: Maximilichain, Lda
• NIPC: 516985302
• Registered address: Rua de São Mateus 14, 2130-244 Benavente, Portugal
• Contact: goncalo@spendintent.app

Information We Collect

Account Information

You sign in with Sign in with Apple or with a one-time code we send to your email address. There are no passwords. We keep your email address and, if you use Sign in with Apple, the name Apple shares with us.

Financial Data

With the consent you give at your bank (under PSD2), we access your bank account information and transaction history through Enable Banking, an open banking provider. The access is read-only (account information under PSD2): we can see balances and transactions, never move money. This includes:

• Account names, balances and IBANs
• Transaction details as your bank reports them (amounts, dates, descriptions and, where given, the other party's name; we drop their account details and address when they arrive)

When you ask the app to fetch your bank data (linking an account, refreshing or fetching more history), we send Enable Banking, which passes them on to your bank, your device's IP address and the app's identifier (its user agent, which can include the app's name and version and your phone's operating system), so that your bank knows you are present; we do not send them on automatic refreshes, and we do not store them.

If you import a bank statement file instead, the file is read on your device; only the transactions you import reach our servers.

Usage Data

The app and this website contain no analytics, advertising or tracking code. Our API's logs record technical events and counts only, never amounts, descriptions, names, IBANs or email addresses. When the app or our API hits an error, it sends an error report to Sentry with technical details only, never your budget or bank data.

How We Use Your Information, and Our Legal Bases

• To provide the app you signed up for: to sign you in and keep your account secure, keep your budget and sync it across your devices, import your bank transactions or a statement when you ask, reuse the categories you chose before, manage your subscription, and send the emails the service needs (sign-in codes, notices about your trial or account). Legal basis: our contract with you (GDPR Art. 6(1)(b)).
• Sensitive data your transactions can reveal: only with your explicit consent (Art. 9(2)(a)); see the next section.
• To suggest categories with a model (Automatic Categorization, below). Legal basis: our legitimate interests (Art. 6(1)(f)), which are also yours: suggesting a category for each new expense, so you sort less by hand. For sensitive data, also your explicit consent.
• The names of other people and shops in your transactions: to show you your own transactions as your bank reports them, to apply your rules and, in the texts sent for suggestions, to suggest a category. Legal basis: our legitimate interest in giving you a complete record of your own spending.
• To keep the service secure and working: API and server logs, error reports, rate limits, and limits on how often we reach your bank. Legal basis: our legitimate interest in protecting the service and your data, and in fixing faults.
• This website: our host keeps request logs. Legal basis: our legitimate interest in presenting SpendIntent to visitors.
• To answer your requests about your data, and keep a record of them and of your consent. Legal basis: our legal obligations under the GDPR (Art. 6(1)(c), and Art. 7(1) for the consent).

Sensitive Data and Your Consent

Bank and statement transactions can reveal special categories of data: a payment to a pharmacy or a doctor can say something about your health; one to a parish, a party or a union, about your beliefs or a membership. We use this data only to run your budget.

We process it only with your explicit consent (GDPR Art. 9(2)(a)). The app asks for it on its own screen before it reads any bank or statement data, with two ways to agree and nothing pre-selected:

• “Aceito”: we use the data for your budget, and the text of each expense also goes to TypeSafe, with the names of your categories, to suggest a category (Automatic Categorization, below).
• “Aceito, sem sugestões da TypeSafe”: the same, but nothing goes to TypeSafe.

If you don't agree (“Agora não”), you can still use the app with the accounts and transactions you add yourself; linking a bank or importing a statement asks again. We keep a record of each time you agree or withdraw (which consent, which version of the text, and when).

Withdrawing your consent. You can withdraw it at any time in the app: Mais → “Os teus dados” → “Retirar consentimento”, which you can reach with or without a subscription. We then disconnect your banks, stop importing, and delete the text of the transactions we imported, in the app and on our servers (backups follow within 30 days); their amounts, dates and categories stay, with the bank's or the file's own reference for each, so nothing is imported twice if you agree again later. Texts TypeSafe already received carry nothing that would let it find them, so they stay under its terms. To withdraw only the TypeSafe part, switch off “Sugerir categorias automaticamente” in Mais. Withdrawing does not affect what we did with your consent before.

Automatic Categorization

When we import your bank transactions, we suggest a category for those your own rules do not cover. First we reuse the category you chose the last time for the same merchant: this happens on our servers and sends nothing to anyone. For spending you have never categorized, a classification model (Jev, by TypeSafe) suggests one. Our servers send the request to TypeSafe directly. TypeSafe is a US company that says its services are hosted in the United States, and it offers a data processing agreement with the EU standard contractual clauses. It does not train its models on what we send, and it may keep the request data as described in TypeSafe's privacy policy.

To suggest categories, we send the text of each transaction (as your bank wrote it) to our AI provider TypeSafe, together with the names of your categories; to tell what kind of category each one is, we may also send one of your category names on its own. That text can include the name of a shop or of a person you paid, and short numbers such as the last four digits of your card or a date. We remove long numbers such as IBANs, phone numbers and references, and e-mail addresses.

We remove your own name where your bank gives it to us, and we send no email address, account or user identifier, and not the amount or date of the transaction as such. Money coming in, transfers between your own accounts and top-ups of your own wallets are not sent.

Every suggestion stays in “Por rever” until you approve or change it. The model is used only with your consent (“Aceito” on the consent screen, or switching it on later), and you can switch it off at any time in Mais → “Sugerir categorias automaticamente”. Reusing your own past choices keeps working, as it sends nothing.

Automated Decisions

We make no decision about you based solely on automated processing that has legal or similarly significant effects on you (GDPR Art. 22). The model only suggests a category, and it waits in “Por rever” until you approve or change it.

Newsletter

If you ask on our website to be notified, we keep your email address, the language of the page you used and a record of your consent (when you confirmed, the wording version and the source). We use them to send you news about SpendIntent, the launch included. We send a message to confirm your address first, and we add it to the list only when you confirm. Legal basis: your consent (GDPR Art. 6(1)(a)).

Resend sends the emails and keeps the list. The form uses Cloudflare Turnstile to tell people from bots; it receives your IP address and browser details for that purpose.

We keep your address until you unsubscribe. After that we keep it only as a suppression record, so that we do not write to you again, and as proof of your consent. You can withdraw your consent at any time, through the link in every email or by writing to goncalo@spendintent.app.

Data Security

We implement industry-standard security measures to protect your data:

• You log in to your bank on its own page: we never see or store your bank credentials
• Bank access is read-only and lasts only as long as the consent you gave your bank
• Data in transit between the app and our servers is encrypted (TLS)
• On your phone, the app keeps its copy of your data in an encrypted database
• Your account and budget data are stored by Supabase in the EU (Frankfurt, Germany); our sync server at Hetzner keeps a copy to sync it to your devices

Data Sharing

We do not sell your personal or financial data. We only share it with the providers that run the service for us, each for its own part:

• Enable Banking - Connects to your bank, with your consent
• Supabase - Sign-in and our database
• Cloudflare - Runs our API, and its Turnstile check protects the newsletter form from bots
• TypeSafe - Provides the categorization model (it says its services are hosted in the United States); receives only what is described under Automatic Categorization, does not train its models on it, and may keep it according to its own privacy policy
• Hetzner - Hosts the server, run by us, that keeps a copy of your data to sync it to your devices
• RevenueCat - Manages your App Store or Google Play subscription; receives a random account ID, the store's purchase records, and from the app your IP address and device and app details (such as the device model, operating system, app version, language and country), never your name, email or bank data; data held in the United States, under the EU standard contractual clauses of its data processing agreement
• Resend - Sends our emails (sign-in codes, notices about your trial or account, and the newsletter you ask for); it sends from its EU region and keeps its data, the newsletter list included, in the United States, under the EU standard contractual clauses
• Sentry - Receives error reports from the app and our API, in its EU data region; a report from the app carries your device's IP address, as any request does
• Vercel - Hosts this website
• Apple - Only if you use Sign in with Apple

Apple (App Store) and Google (Google Play) sell and bill your subscription under their own privacy policies, as controllers in their own right; so does your bank when it receives the details above.

Transfers Outside the EU

Some of these providers are outside the EU, or can reach data from outside it. Each transfer rests on a safeguard:

• TypeSafe (United States): the EU standard contractual clauses in its data processing agreement; it is not certified under the EU-US Data Privacy Framework
• RevenueCat (United States): the EU standard contractual clauses
• Cloudflare (a US company whose network runs our API worldwide): the EU-US Data Privacy Framework, with the standard contractual clauses as a fallback
• Supabase (data stored in Frankfurt, Germany; contracting company in Singapore, support from the United States): the EU standard contractual clauses
• Vercel, Resend and Sentry (US companies; Resend and Sentry in their EU regions): the EU standard contractual clauses or the EU-US Data Privacy Framework, as their data processing agreements provide

You can ask us for a copy of these safeguards at goncalo@spendintent.app.

Data Retention

We retain your data for as long as your account is active. You can delete your account and all associated data at any time in the app (Mais → “Os teus dados” → “Apagar a conta”). This also ends your bank consents with Enable Banking, deletes your subscription record at RevenueCat (it does not cancel a store subscription: cancel it in the App Store or Google Play) and, if you use Sign in with Apple, revokes our access at Apple. Upon account deletion, we remove all personal data within 30 days, except as listed below.

• The record of your consent: as long as your account exists
• Emails you send us: 24 months after your last message
• The record of a request about your data (who asked, what, when, the outcome): 3 years
• What TypeSafe receives: as long as TypeSafe needs it to provide its service, under its data processing agreement; it deletes or returns it when our contract ends

Your Rights (GDPR)

Under GDPR, you have the right to:

• Access your personal data and get a copy of it
• Correct inaccurate data
• Delete your data
• Restrict how we use your data
• Export your data in a portable format
• Object to what we do on the basis of legitimate interests (next section)
• Withdraw your consent at any time

In the app you can correct anything you see, export everything (Mais → “Os teus dados” → “Exportar tudo”) and delete your account (Mais → “Os teus dados” → “Apagar a conta”). For anything else, email goncalo@spendintent.app; we answer within one month.

You can also lodge a complaint with the Portuguese data protection authority, the CNPD (Comissão Nacional de Proteção de Dados, www.cnpd.pt), or with the authority of the EU country where you live or work.

Your Right to Object

Where we rely on our legitimate interests (above), you have the right to object at any time, on grounds relating to your particular situation.

• To the model's category suggestions: switch off “Sugerir categorias automaticamente” in Mais. It takes effect at once, and you need not give a reason.
• To anything else: email goncalo@spendintent.app. We then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or need the data to establish, exercise or defend legal claims.

People named in a SpendIntent user's transactions can object the same way, by email. We do not use your data for direct marketing.

Do You Have to Give Us Your Data?

You need an email address, or Sign in with Apple, to have an account: without one we cannot provide the app. Everything else is your choice. Linking a bank, importing a statement, the consent for sensitive data and the model's suggestions are all optional; without them, you can use the app with what you add yourself.

Contact Us

If you have questions about this Privacy Policy or your data, please contact us at goncalo@spendintent.app