Privacy Policy

1. Controller and Contact

DolFin is operated by EMIGLOBAL S.R.L. ("DolFin", "we", "us", "our"), Strada Democratiei 103, Bl. ICIM, 100562 Ploiesti, Romania.

For privacy questions, data requests, support, or complaints, contact us at support@dolfinapp.org. We answer data-protection requests within one month, as required by Article 12(3) GDPR.

We have not appointed a Data Protection Officer; the Article 37(1) criteria do not apply to us. Because we are established in the European Union, we do not need an EU representative under Article 27 GDPR.

2. Data We Collect

2.1 Account and authentication data

• Email address, user ID, username or display name, preferred language, and authentication identifiers.
• Apple or Google sign-in identifiers if you choose those login methods.
• Session and security data needed to keep you signed in and protect your account.
• If you start using DolFin before creating an account, an anonymous session identifier so your progress is not lost. If you later create an account, that identifier becomes your account.

2.2 App profile, education, and progress data

• Onboarding answers such as income range, money goal, experience level, spending style, and country/region settings.
• Lessons, quiz answers, XP, levels, streaks, habits, achievements, and app progress.
• Money Leak Audit actions, recurring-plan review status, and other in-app choices.

2.3 Financial and transaction data you choose to add

• Manual expenses, categories, budgets, recurring plans, merchant names, notes, and dates.
• Imported transaction rows that you review and choose to save.
• Financial overview inputs and Money Leak Check answers submitted on this website.

2.4 Bank statement uploads

• The contents of the PDF or CSV statement you choose to upload, and the transactions we extract from it: dates, amounts, merchant names, descriptions, balances, categories, confidence values, and import hashes.
• PDF statements are uploaded to our server, where they are read in memory. CSV files are read on your device where we recognise the layout.
• Parsed transaction rows are shown for review. On the free plan the most recent month of a statement is saved to your tracker as part of building your report; the remaining months stay on your device unless you upgrade.
• Diagnostic logs may include parser metadata and raw or cleaned merchant text, to improve parser reliability.
• We do not intentionally store your uploaded file — except in one case: if you choose to share a statement with us so that we can add support for your bank. That is a separate, optional choice you make on screen, and it is the only circumstance in which your raw file is retained. See section 7 for how long.

Upload only statements you are authorised to use.

2.5 Sensitive information in statements

We do not ask you for special-category data. But a bank statement can reveal it anyway. A payment to a pharmacy, a clinic, a place of worship, a political party, a trade union, or a dating service can indicate health, religious or philosophical beliefs, political opinions, trade-union membership, or sexual orientation. These are "special categories of personal data" under Article 9(1) GDPR.

We therefore treat everything in an uploaded statement as sensitive. We do not use it for advertising, we do not use it for cross-app tracking, and we do not sell it. Before we process your file, we ask for your explicit consent under Article 9(2)(a) GDPR — see section 4.

2.6 Purchase and subscription data

• Subscription tier, product ID, entitlement status, renewal/restore events, and app-store or RevenueCat identifiers needed to validate purchases.
• Apple App Store or Google Play process payments. DolFin does not receive your full card details.

2.7 Website and email data

• Email addresses submitted through the early-access form.
• Money Leak Check answers submitted on the website, including income, fixed costs, spending estimates, savings bucket, investing status, goal, and worry.
• Messages you send to support.

2.8 Diagnostics, security, and local device data

• App version, parser outcome, file size, page count, text length, bank/parser name, error class, and security events.
• IP address, user agent, and request metadata where logged by our hosting, backend, or security infrastructure.
• Local app preferences, notification settings, cached app data, and copied statement files while they are being parsed.

2.9 Product analytics data

Only if you turn analytics on. Until you do, our analytics provider is not started at all and stores nothing on your device.

• Events such as screens viewed, onboarding and lesson progress, imports started, and purchases viewed, together with your account identifier (a random user ID), app version, device type, and approximate region.
• We do not send your financial values, transaction details, statement contents, email, or name to our analytics provider. There is no session recording.
• You can turn it off at any time in the app under Profile → Share usage analytics, which also removes the identifier from your device.

3. Why We Use Data and Legal Bases

• Provide the service: account, lessons, progress, expense tracking, imports, and Money Leak Audits. Legal basis: Article 6(1)(b) — performance of our contract with you.
• Personalise the app: adapt lessons, insights, and app state to your profile and activity. Legal basis: Article 6(1)(b) contract, or Article 6(1)(f) legitimate interests.
• Read your statement and extract transactions: Legal basis: Article 6(1)(b) — contract. For any special-category data the statement may reveal, and for the AI processing in section 5: Article 9(2)(a) — your explicit consent, given on the upload screen before the file is processed.
• Improve statement parsing using a file you chose to share with us: Legal basis: Article 6(1)(a) — your consent, given when you choose to share it.
• Validate subscriptions: manage Pro access, restores, renewals, and purchase support. Legal basis: Article 6(1)(b) contract; Article 6(1)(c) legal obligation for tax and accounting records.
• Security and abuse prevention: protect accounts, rate-limit uploads, investigate misuse, and keep the service reliable. Legal basis: Article 6(1)(f) — legitimate interests.
• Parser and reliability diagnostics: troubleshoot statement parsing and app reliability. Legal basis: Article 6(1)(f) — legitimate interests, with limited retention.
• Product analytics: understand feature usage and improve the app. Legal basis: Article 6(1)(a) — consent, off unless you turn it on.
• Notifications: local reminders and streak warnings if you enable them. Legal basis: consent / device permission.
• Website forms and early access: send your requested Money Leak Check, launch access, or support response. Legal basis: Article 6(1)(a) consent, or a pre-contractual request under Article 6(1)(b).
• Legal compliance: tax, accounting, disputes, consumer-law, and regulatory obligations. Legal basis: Article 6(1)(c) legal obligation and Article 6(1)(f) legitimate interests.

Where we rely on consent, you can withdraw it at any time, and withdrawing is as easy as giving it — see section 9. Withdrawal does not affect the lawfulness of processing carried out before you withdrew. Where we rely on legitimate interests, you have the right to object.

4. Bank Statement Processing

DolFin does not ask for your online banking password and does not connect directly to your bank account. There is no bank login and no Open Banking connection. If you choose to import a statement, you select the file yourself.

• PDF uploads are limited to 10 MB and are uploaded to our server — a Supabase Edge Function — where they are read in memory. If our own parsers cannot read the layout, the extracted text is sent onward to a third-party AI provider, as described in section 5.
• Preview rows are not saved to your tracker unless you choose to import them.
• Parser diagnostic logs may store raw and cleaned merchant text for up to 30 days.
• Parser attempt metadata may be stored for up to 90 days.
• Imported transactions you save remain in your account until you delete them or delete your account, subject to required legal and security retention.

Consent. Before we process your file, we show you what happens to it and ask you to confirm explicitly. That confirmation is your Article 9(2)(a) explicit consent for any special-category data the statement may reveal, and your consent to the AI processing in section 5. We record the exact wording you were shown, so that we can demonstrate what you agreed to.

5. How We Use AI

When you upload a bank statement, DolFin first tries to read it with its own parsers, which use no AI at all. Most statements from banks we already support are read this way, and nothing leaves our own systems.

If your bank's layout is not one our parsers recognise, we send the text extracted from that statement to OpenAI Ireland Ltd, which reads it back to us as a list of transactions and suggests a spending category for each one. We use those categories to identify recurring charges and to build your Money Leak report.

CSV files, in one narrow case. If DolFin cannot work out which column is which, we send the header row and up to three of your real transaction rows to the same provider so that it can identify the columns. The rest of the file is read on your device.

Merchant names, separately. In an offline process, we send merchant descriptor text — the shop or company name as it appears on a statement — to the same provider so we can improve categorisation for everyone. That process carries no user identifier, no amount, and no date.

What we do not send. We do not send your name, your email address, or your account identifier to this provider alongside the statement text. The statement text itself can, however, contain personal details — including your IBAN, your salary, and the names of people you paid.

What this is not. DolFin does not make binding financial, credit, insurance, employment, legal, or similarly significant decisions about you, and it does not assess your creditworthiness or produce a credit score. Its categorisation and its Money Leak report are for information and review. They are not financial advice. You can correct any category yourself in the app, and nothing is shared with any lender, insurer, employer, or landlord.

Your choice. You can withdraw your consent to this processing at any time in the app under Profile. After you do, DolFin stops sending statement text to the AI provider; statements our own parsers cannot read will simply tell you they could not be read. Withdrawing does not undo processing that already happened.

6. Processors and Recipients

We use service providers only where needed to operate DolFin. Each processes personal data on our instructions, under a contract meeting Article 28 GDPR:

• Supabase: authentication, database, storage-related infrastructure, and the Edge Functions that read statements.
• OpenAI Ireland Ltd: reads statements our own parsers cannot, and suggests spending categories, as described in section 5.
• RevenueCat: subscription entitlement and purchase status management.
• PostHog: pseudonymous product analytics, processed on PostHog's EU infrastructure, only where you have turned analytics on.
• Apple App Store and Google Play: app distribution, sign-in where selected, purchases, refunds, and store account management.
• Website, email, and support providers: hosting, domain, email delivery, and support communications.

We do not share your personal data with data brokers and do not use it for third-party advertising. We may disclose data where the law requires it, or to establish or defend a legal claim. If we add a new provider that processes personal data, we will update this policy and any required app-store privacy information before or when the change takes effect.

7. International Transfers

Some of our providers process data outside the European Economic Area, including in the United States.

Our AI provider, OpenAI Ireland Ltd, is established in the European Union, and our data-processing agreement is with that entity. It processes the data using OpenAI's infrastructure in the United States. For that onward transfer we rely on the European Commission's Standard Contractual Clauses, which form part of the same agreement. You can request a copy by emailing support@dolfinapp.org.

For our other providers we rely on Standard Contractual Clauses or on an applicable adequacy decision. You can ask us which mechanism applies to a specific provider using the same address.

If you are in the United Kingdom: where a transfer of your data leaves the UK, we rely on the UK International Data Transfer Addendum to the Standard Contractual Clauses, which each of our providers enters into as part of the same agreement, or — for providers certified under the UK Extension to the EU–US Data Privacy Framework — on that framework. You can ask which one applies to a given provider at the address above.

8. Retention

• Account, profile, progress, finance, and imported transaction data: retained while your account is active, unless you delete it sooner.
• Statements you chose to share with us so that we can support your bank: retained for up to 90 days, then deleted.
• Merchant parser logs from PDF parsing: up to 30 days, unless deleted earlier with account deletion.
• PDF parser attempt metadata: up to 90 days.
• Website form submissions from the period when this site ran a signup form: that form has been removed, and any addresses collected through it are deleted on request at support@dolfinapp.org.
• Purchase, tax, accounting, fraud-prevention, dispute, and security records: retained as required or reasonably necessary for those purposes.
• Store and processor records: retained under Apple, Google, RevenueCat, and other provider policies.

Deleting your account deletes the data we hold against it, other than records we are legally required to keep.

9. Security

We use technical and organisational measures designed to protect personal data, including account access controls, encrypted transport, row-level database access rules that stop one user reading another's data, authenticated server functions, rate limits, and limited retention for parser diagnostics. No app or cloud service can guarantee perfect security, and we do not claim to. You should keep your device and login credentials secure.

If a personal-data breach occurs that puts your rights at risk, we will notify the supervisory authority within 72 hours and tell you directly where the law requires it.

10. Your Rights

If you are in the EU or EEA, you have the following rights. They are not conditional, and exercising them is free:

• Access — a copy of the personal data we hold about you (Article 15).
• Rectification — correction of anything inaccurate (Article 16).
• Erasure — deletion of your data (Article 17).
• Restriction — a pause on our processing while a dispute is resolved (Article 18).
• Portability — your data in a machine-readable format (Article 20).
• Objection — to any processing we base on legitimate interests (Article 21).
• Withdrawal of consent — at any time, for anything we base on consent (Article 7(3)).

Several of these are built into the app:

• Delete your account under Profile → Delete account, or at dolfinapp.org/delete-account.
• Turn analytics off under Profile → Share usage analytics.
• Withdraw your consent to AI statement processing under Profile.
• Withdraw notification permission in your device settings.

For anything else, contact support@dolfinapp.org. We reply within one month.

Complain to us first, if you like. You can raise a data-protection complaint with us directly at support@dolfinapp.org. We acknowledge every complaint within 30 days, look into it, keep you informed while we do, and tell you the outcome. You never have to complain to us before going to a regulator — this is in addition to that right, not a step before it.

If you are in the United Kingdom, your supervisory authority is the Information Commissioner's Office (ICO), and you have the right to complain to the Commissioner under section 165 of the Data Protection Act 2018 — ico.org.uk/make-a-complaint.

Complaints. You can complain to the Romanian supervisory authority, the Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), at dataprotection.ro — or to the data protection authority in the country where you live or work.

11. Automated Processing

DolFin categorises transactions, highlights possible recurring charges and fees, and estimates spending patterns. Part of that categorisation is done by the AI described in section 5.

DolFin also derives a short behavioural label describing your recurring-payment habits — for example “the one who forgets annual renewals” — from the charges found in your statement. This is profiling within the meaning of Article 4(4) GDPR. It is worked out on your device from data you already imported, it is shown only to you, and it is sent nowhere unless you choose to share the card it appears on. Separately, categorisation rules we author centrally are applied to transactions already stored on your device when the app next opens, so a merchant we learn to recognise is corrected retrospectively.

This is not automated decision-making that produces legal or similarly significant effects within the meaning of Article 22(1) GDPR. Nothing DolFin outputs is sent to any third party who acts on it, nothing affects your access to credit, insurance, housing, or employment, and you can override any category yourself at any time. The only person who decides what to do with a Money Leak report is you.

12. Children

DolFin is intended for users aged 16 or older in the EU. Users under 16 must not create an account or submit website forms. If we learn that we hold data about a child under 16 without the consent of the holder of parental responsibility, we will delete it. If you believe a child under 16 has provided data to DolFin, contact support@dolfinapp.org.

13. Cookies, Analytics, and Tracking

The DolFin mobile app does not use browser cookies and contains no advertising or cross-app tracking.

Product analytics are off unless you turn them on. Until you do, our analytics provider is not started at all and stores nothing on your device. If you turn analytics on, we use PostHog as described in section 2.9. You can turn it back off at any time under Profile → Share usage analytics, which also removes the identifier from your device.

This website sets no cookies and runs no analytics or marketing scripts. It does use two third-party services that necessarily see your IP address when a page loads: our host, Vercel, which serves the page and keeps short-lived request logs, and Google Fonts, which serves the typefaces. If we enable non-essential website analytics or marketing cookies, we will provide the required cookie notice or consent controls before using them.

14. Changes

We update this policy when what we do with your data changes, or when legal requirements change. When a change is material — for example, adding a new type of processing or a new recipient of your data — we will tell you in the app, on this website, or by email before or when it takes effect, and we will update the date at the top.

Previous version: June 6, 2026.