Consumer Health Data Privacy Policy

1. Why this policy exists

DolFin is a budgeting app. It is not a health app, and it never asks you for health information.

But when you upload a bank statement, DolFin sorts each charge into a spending category — and one of those categories is Health. A payment to a pharmacy, a doctor, a physiotherapist, an optician or a health insurer gets labelled that way. Washington law treats an inference like that as consumer health data, even though it was worked out from an ordinary payment line rather than from anything you told us about your health.

We think that is the right way to read it, so we are telling you plainly rather than arguing about the definition.

2. What we collect, and why

• The Health category label we attach to a charge, stored against your account so your spending breakdown adds up. Purpose: to show you what you spend and to find recurring charges worth reviewing.
• The merchant name and description text from the statement line the label came from — for example a pharmacy's name as your bank printed it. Purpose: the label cannot be produced without reading it, and you need to recognise the charge when you see it.

We do not collect any other health information. We do not ask about conditions, treatments, medications or providers. We do not track location, so we never infer anything from somewhere you have been.

3. Where it comes from

One source only: the bank statement file you choose to upload. You export it from your bank yourself and hand it to us. DolFin never connects to your bank, never holds your banking credentials, and never retrieves anything on your behalf.

4. Who it is shared with

We do not sell consumer health data, and we do not share it with third parties for their own purposes. We have never done so and this policy does not permit it.

Two service providers process it strictly on our instructions, under contract, and may not use it for anything of their own:

• Supabase — hosts our database and storage. Contact: privacy@supabase.io
• OpenAI Ireland Ltd — reads statement layouts our own parsers do not recognise, and suggests a category for each charge. This happens only when your bank's format is unfamiliar to us, and only after you have agreed to it on a screen that says so. Contact: dsar@openai.com

Under Washington law these are processors, not third parties. We list them anyway, with a working contact for each, because if you ask us who has touched your data that is the answer you should get.

5. Your rights

These rights are free to use, and using them never degrades the app.

• Confirm and access. Ask whether we hold consumer health data about you, get a copy, and get the list of everyone it has been shared with — which is the list in section 4 above, with their contact details.
• Withdraw consent. You can withdraw your agreement to statement processing at any time, in the app under Profile → AI statement processing. It takes one tap, which is no harder than giving it was. Withdrawal stops future processing; it does not undo processing that already happened.
• Delete. Ask us to delete your consumer health data and we delete it — from our live systems and from backups as they expire — and we tell our processors to do the same. There is no exception we can invoke to keep it anyway. You can also delete your whole account at any time in the app under Profile → Delete account, or at dolfinapp.org/delete-account, which removes this data along with everything else.

6. How to exercise them, and what happens next

Email support@dolfinapp.org with what you want to do. You do not need a particular form of words.

• We respond within 45 days of receiving your request. If we genuinely need longer we may take one further 45 days, and we will tell you why before the first 45 are up.
• We may need to confirm you are the account holder before acting — usually just replying from the address on the account.
• If we refuse, you can appeal. Reply to our decision and say you are appealing. We will reconsider and give you a written explanation of the outcome.
• If we deny the appeal, you may complain to the Washington State Attorney General at atg.wa.gov/file-complaint. We will include that link in our decision.

7. How long we keep it

The category label and the charge it belongs to stay in your account while the account exists, so your history stays complete. Deleting your account deletes them. Statement parser diagnostics are deleted on a 30-day schedule, and parser metadata on a 90-day schedule, both enforced automatically. The retention detail for every other kind of data is in section 8 of the main Privacy Policy.

8. Who we are

DolFin is operated by EMIGLOBAL S.R.L., Strada Democratiei 103, Bl. ICIM, 100562 Ploiesti, Romania. Questions about this policy: support@dolfinapp.org.

We are based in the European Union, which means you also have the protections described in our main Privacy Policy — including that we never process your statement without asking you first.

9. Changes

If we ever change what consumer health data we collect, what we do with it, or who processes it, we will update this policy and change the date at the top before the change takes effect. We cannot collect, use or share consumer health data for a purpose this policy does not already describe.