Privacy notice

Version 0.1 (draft outline) - effective date not set. Previous versions

Draft outline for counsel. Not the binding text. The structure follows the data map of FABLE-045 step 28; the facts under each heading come from the product as built.

1. Who is responsible

The entity [step 29]; the EU representative and the UK representative [step 29]; the privacy contact [email protected] [step 02].

2. What we collect and why

Account: email address, display name, password hash, authenticator secret, passkey public keys, recovery code hashes, date of birth if you give it (optional; kept for dependents), the 18+ confirmation, the terms version you accepted.
Money records: accounts, transactions, expenses, shares, settlements, budgets, categories, exchange rates you record.
Receipts: the files you upload, with camera and location metadata removed before storage.
Itinerary: places, dates, routes you ask for, and, only if you switch Travel Assist on, your device's location while it is on.
People you enter: names, nicknames and email addresses of people you invite; dependents' names and dates of birth.
Contacts: your private address book, which only you can see.
The audit trail: who did what, when, and from which IP address, for every write.
Sign-in records, bounded: the success, the first failure of a run and a lockout, for known accounts; new-device sign-in emails.
Email: the messages we send you and whether they bounced.

3. Who sees what

Members of your household and participants of your trip, by role; the operator, for support and operations; nobody else.

4. Processors

The sub-processor list. [D4] [D1]

5. Where data is stored

[D4]

6. How long we keep it

Counsel's schedule, built from: backups kept 14 days; audit rows never deleted; a removed receipt's file deleted while its audit record stays; addresses in the audit trail after an account is deleted (open question, FABLE-048); bounced addresses suppressed.

7. Your rights

See, export, correct and erase your data; object; complain to a supervisory authority. How to ask: data requests.

8. Cookies

Only those needed to keep you signed in; none for advertising or analytics, in the app or on this site.

9. Children

18 and over only.

10. Security

By reference to the security page; no claims beyond it.

11. Breaches

Our procedure and the 72-hour notification clock, from the breach procedure of step 28.

12. Changes to this notice

Versioned; see previous versions.