Privacy Policy

1. Introduction

Welcome to FamiShare (the "App"). This Privacy Policy explains how FamiShare ("we," "our," or "us") collects, uses, processes, and protects your personal information when you use our mobile application.

We are committed to protecting your privacy and ensuring transparency about our data practices. This Privacy Policy complies with the EU General Data Protection Regulation (GDPR), Apple's App Store Guidelines, and other applicable privacy laws.

If you have any questions about this Privacy Policy or our data practices, please contact us using the information provided above.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

• Email address (for account creation, identification, group invitations)
• Display name (to identify you in the app for other users)
• Default currency (to improve usability when submitting expense information)

Expense Data:

• Expense amounts
• Expense currency
• Expense date
• Date of creating the expense
• Group for the Expense
• User who paid the expense
• Expense split (among group members)

Group Data:

• Group names
• Group default currency
• Emails of people invited to a Group

Communication Data:

• Support communications with our team

2.3 Information We Do NOT Collect

We do not collect:

• Payment or banking information (we do not process payments)
• Location data or GPS coordinates
• Contacts from your device
• Information from other apps on your device
• Biometric information
• Health information

3. Legal Basis for Processing (EU Users)

Under the GDPR, we process your personal data based on the following legal grounds:

Contract Performance (Article 6(1)(b)):

• Creating and managing your account
• Providing expense tracking and calculation services within Groups

Legitimate Interest (Article 6(1)(f)):

• Improving App functionality and user experience
• Ensuring App security and preventing fraud
• Providing customer support
• Analyzing usage patterns to enhance services

Legal Obligation (Article 6(1)(c)):

• Complying with applicable laws and regulations
• Responding to legal requests from authorities

4. How We Use Your Information

4.1 Primary Purposes

Service Provision:

• Create and maintain your account
• Calculate expense sharing and balances
• Store your expense history and group information
• Sharing a Group invitation

App Improvement:

• Analyze usage patterns to improve functionality
• Identify and fix technical issues
• Develop new features based on user needs

Communication:

• Send service-related notifications
• Provide customer support
• Notify you of important App updates

Security:

• Protect against fraud and abuse
• Maintain App security and stability
• Verify user identity when necessary

4.2 We Do NOT Use Your Information For

• Selling or renting your data to third parties
• Creating advertising profiles
• Tracking you across other websites or apps
• Processing financial transactions

5. Data Sharing and Disclosure

5.1 Sharing Within the App

Group Members: When you join or create an expense group, your display name and expense data are shared with other group members. This is essential for the App's expense-sharing functionality.

User Choice: You control which groups you join. You can leave groups at any time.

5.2 Third-Party Service Providers

We may share limited data with trusted service providers who assist us in operating the App:

Cloud Services Provider:

• Purpose: Secure data storage, Authentication
• Data Shared: account, group and expense data

Email sending service:

• Purpose: Sending transactional emails (signup verification codes (OTPs) and group invitations
• Data Shared: email address, group name

Customer Support Tools:

• Purpose: Providing user support
• Data Shared: Support conversation history

5.3 Legal Disclosure

We may disclose your information if required by law or in good faith belief that such action is necessary to:

• Comply with legal obligations or court orders
• Protect and defend our rights or property
• Prevent or investigate fraud or security issues
• Protect the safety of users or the public

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections outlined in this policy.

6. Data Security

6.1 Technical Safeguards

• Limited access to personal data
• Multi-factor authentication for administrative accounts
• Secure cloud services with reputable providers
• Regular security updates

6.2 Organizational Safeguards

• Privacy by design principles in App development
• Data minimization and purpose limitation practices

6.3 Your Role in Security

Please help protect your account by:

• Keeping your login credentials confidential
• Logging out of shared devices
• Reporting suspicious activity immediately

7. Data Retention

7.1 Retention Periods

Active Accounts: We retain your personal data for as long as your account remains active and you continue to use the App.

Inactive Accounts: If you don't use the App for 24 months, we may delete your account and associated data after providing reasonable notice.

Specific Data Types:

• Expense records: Retained while your account is active
• Communication data: Retained in line with support tool data retention

7.2 Legal Requirements

We may retain certain information for longer periods if required by law, to comply with legal obligations, or to resolve disputes.

7.3 Deletion Upon Request

You may request deletion of your account and data at any time (see Section 9 for details). When you delete your account, some of the data shared with other Users will not be deleted from the App. For example, expense information shared with a Group may still be required to provide Services to other Users and it will not be deleted. However, your display name and email will be anonymised.

8. International Data Transfers

8.1 Data Location

Your data may be processed in countries other than your country of residence.

8.2 EU Data Transfers

For users in the European Union, any transfers of personal data outside the EU are protected by:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses approved by the European Commission
• Other appropriate safeguards recognized under GDPR

8.3 Transfer Recipients

Data may be transferred to our service providers located in:

• United States of America
• Germany
• Poland

9. Your Privacy Rights

9.1 Rights Available to All Users

• Access: Request information about the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your account and personal data
• Data Export: Request a copy of your data in a portable format
• Communication Preferences: Opt-out of non-essential communications

9.2 Additional Rights for EU Users (GDPR)

• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of personal data ("right to be forgotten")
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing
• Right to Lodge Complaints: File complaints with supervisory authorities

9.3 How to Exercise Your Rights

Within the App:

• Access Account page to modify or delete data

Contact Us:

• Email: support@famishare.app
• Subject line: "Privacy Rights Request"
• Include: Your name, account email, and specific request

Response Time: We will respond to your request within 30 days (or as required by applicable law).

Verification: We may need to verify your identity before processing requests that involve accessing or deleting personal data.

10. Cookies and Tracking

10.1 App-Based Data Collection

As a native mobile app, FamiShare does not use traditional web cookies.

10.2 Third-Party Tracking

We do not allow third-party tracking or advertising networks to collect data from our App users.

10.3 Do Not Track

Our App does not respond to "Do Not Track" signals as it does not track users across different websites or services.

11. Children's Privacy

11.1 Age Requirements

The App is not intended for use by children under 13 years of age. We do not knowingly collect personal information from children below these age thresholds.

11.2 Parental Notice

If you believe your child has provided personal information to us, please contact us immediately. We will delete such information from our records.

11.3 School Use

If the App is used in educational settings, schools must obtain appropriate parental consents as required by applicable laws (such as COPPA in the US or GDPR in the EU).

12. Privacy Policy Changes

12.1 Updates and Notifications

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Material Changes:

• We will notify when material changes take effect
• Notification methods: In-app notification, email, or App Store updates
• You may review changes and decide whether to continue using the App

Non-Material Changes:

• Minor updates may be made without advance notice
• Updated "Last Updated" date will reflect recent changes
• We encourage periodic review of this Privacy Policy

12.2 Continued Use

Your continued use of the App after privacy policy changes indicates acceptance of the updated terms.

14. Data Breach Notification

14.1 Our Commitment

In the unlikely event of a data breach that may adversely affect your privacy or security:

• We will investigate and assess the incident promptly
• We will notify relevant authorities as required by law
• We will notify affected users if required by law or if we believe notification is appropriate

14.2 User Actions

If you suspect a security incident:

• Change your account password immediately
• Contact us at support@famishare.app
• Monitor your accounts for unusual activity

15. Contact Information and Complaints

15.1 Privacy Questions and Requests

15.2 Complaints and Disputes

Internal Resolution: We encourage you to contact us first with any privacy concerns. We are committed to resolving issues promptly and fairly.

External Complaints (EU Users): EU residents have the right to lodge complaints with their local supervisory authority.

Other Jurisdictions: Users in other regions may contact their local privacy or data protection authorities as applicable.

16. Data Protection Officer

For users in the European Union, you may contact our Data Protection Officer with questions about data processing:

17. Consent Management

17.1 Explicit Consent

Where we rely on consent for processing, we ensure that:

• Consent is freely given, specific, informed, and unambiguous
• You can withdraw consent at any time
• Withdrawal of consent does not affect the lawfulness of processing before withdrawal

17.2 Consent Records

We maintain records of consents given, including:

• What you consented to
• When consent was given
• Whether consent has been withdrawn