Privacy Policy

Finsplit Privacy Policy

We are committed to respecting your data privacy and providing transparency about our data practices. This Privacy Policy (this “Privacy Policy”) explains how ITHUB, LLC (“Company” or “we” or “us”) collects, stores, uses, transfers and discloses Personal Data from our users (“you”) in connection with the Finsplit mobile application and related services (collectively, the “App”).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional Personal Data from you. Changes are effective immediately upon posting. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our website and the App for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

Last Modified: April 2, 2019

Overview

Finsplit is a shared ledger for friends - expenses you add in App are not public. Friends who are included on an expense can view that expense, and, if an expense is added in a group, other group members can view expenses shared on App. You choose who you share your expenses with and what kind of expenses you want to share. Anyone shared on an expense or in a shared group has the ability to edit, delete, and undelete the expenses that have been shared with them.

In order to use App, we ask that you create an account. When you sign up we'll ask for some registration information. We need this information to create an account so that we can contact you about your account, so that your friends can find you, and so you can access your account from anywhere.

In addition to sharing your registration information to set up your account, we collect some other information about you. We may also collect information about the type of expenses you add or the groups you create. We use this information to help improve and secure our service and to show ads based on your usage of our services.

You have control over the type of information you provide and how we use it. We will never share your information with other parties for use other than what’s laid out in this policy without your consent. You can view your Privacy and Notification Settings from your Account Settings page.

Section 1. Personal Data and information we collect
1.1. Personal Data you provide to us

When you sign up to use the App, we may collect Personal Data about you such as:

а. Full name;

b. Email address;

c. Phone number;

d. Gender;

e. Date of birth;

f. Password;

g. Place of residence;

h. Location information;

i. Other information about your activities (collectively, “Personal Data”).

We require you to provide an email address in order to use App so that we can contact you about your account, and so that you can access your data from any device. Friends will be able to add you using your email address. We require you to provide a name for your account, this is the name your friends will see when adding expenses with you. Providing a phone number gives your friends another way to find you and adds an extra layer of security to your account. You can make changes to this information at any point from your Account Settings.

1.2. User-generated content

We also collect and store the information you provide to us when using our service to share expenses, payments, and communicate with others. This data includes, for example, group names, expense descriptions and amounts, payments and their confirmation numbers, comments and reminders, receipt images, notes, and memos, in addition to any other information that you attach or share while using Finsplit. You may share this information with contacts you specify in the course of using the App. For example, if you add an expense with a group of roommates, those roommates will be able to see that bill, while users who are not the roommate’s group will not. You are solely responsible for which contacts you share this information with.

We may offer bulletin boards, blogs, chat rooms, message boards, or similar public forums where you can communicate with us or other users. Any information that you submit or post to these blogs or other forums could be viewed by other viewers or may otherwise be publicly available. For example, new feature suggestions posted in our public suggestion forum are public and can be viewed by anyone. We don’t recommend posting Personal Data in public forums. If you choose to post Personal Data, other viewers may use this information to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these blogs and other forums, so please be careful about what you disclose and do not post any information that you expect to keep private. If you would like to request removal of your information from our blogs or other forums, please contact us at support@finsplit.app.

1.3. The way you use our service

We collect information about how you use and interact with App. Such as the types of expenses you add, the features you use, the actions you take, and the time, frequency and duration of your activities. For example, we log when and how often you add images to a bill and may use that information to improve our service or suggest new features we offer.

1.4. Information shared by others users

Other App users may share information with you using your contact information (such as email or phone number), and that information will be stored in the course of using App. For instance, if a contact of yours shares a bill with you or adds you to a group using your email address, App may notify you and store that information under your account according to your preferences.

1.5. Device and location information

When you download or use App, we may receive information about your device and location, which allows us to provide increased account security and regulatory compliance. It also allows us to provide location-based services such as targeted advertising, search results, and other personalized content. We also collect information about your interaction with App including, but not limited to, your computer browser type, pages visited, advertisements clicked on, average time spent on our websites, your IP address, unique identifiers of your device, the operating system version and app version.

1.6. Payment information

Finsplit may offers paid services in some markets. If you choose to subscribe to this service, we will ask for additional information. This includes your payment information, such as your credit or debit card number, other card information, and other account and authentication information, as well as billing, and contact details. For certain services, you may be required to provide your checking account number and routing number. For security purposes, you may also be asked to provide identification information to confirm your identity, including your first and last name, address, and phone number, or in some cases, a copy of an identification document.

1.7. Google accounts

As part of using App, you may be presented with the option to link one or more parts of your Google account to your Finsplit account. If you authorize App to use your Google Account to login to App, your name, contact information (usually an email address) and other basic account details (profile picture, age, gender, birthday) may be shared with App at your discretion. Sharing this data is not required to start a Finsplit account. These details will be stored by App and will generally be treated as if you had manually provided that data to App under this Privacy Policy.

1.8. Information from other sources

Finsplit may collect information about you from third parties to help improve our App, or for security and support reasons. If you choose to use some of the optional integrations the third-party services that we offer we may collect information about you from those services. For example, if you choose to send payments to your friends using one of the payment services we integrate with we may collect information from that payment service.

We may use publicly available information about your name, email address, phone number, or other demographic data to help you during support, to address fraud or security concerns, or to personalize your experience, including by providing ads or offers. For instance, if you have a public avatar stored on a service associated with your email, we may automatically populate your user avatar on App. We may also collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records, and to better customize the App for you.

Permitting us to access third-party information can help you to maximize your App experience, and we will handle any such third-party information in full accordance with this Privacy Policy.

1.9. Information we collect automatically

When you access or use the App, we may automatically collect the following information:

а. Device Information: We collect information about the mobile device you use to access the App, including the hardware model, operating system and version, unique device identifiers and mobile network information.

b. Location Information: We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location.

c. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc. To collect this information, we may send cookies to your mobile device or computer. Cookies are small data files stored on your hard drive or in device memory.

YOUR CONSENT. By creating a profile in the App, you explicitly consent that:

I. WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.

II. PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS).

III. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY.

1.10. Other information

We may request or receive other information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the services.

Section 2. How we use your Personal Data and information

WE WILL NOT PROVIDE ANY OF YOUR PERSONAL DATA TO ANY THIRD PARTY EXCEPT AS OUTLINED IN THIS POLICY OR WITH YOUR CONSENT.

Finsplit is designed to help people share expenses and informal IOUs with friends. We process your information to provide, support, and secure our App.

We may use your information, including your Personal Data, for the following purposes:

а. to analyze, operate, maintain and improve the App, to add new features and services to the App;

b. to customize content you see when you use the App;

c. to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;

d. to customize product and service offerings and recommendations to you, including third-party products and offerings;

e. to verify your identity, for billing (invoicing), account management and other administrative purposes;

f. to send you technical notices, updates, security alerts and support and administrative messages;

g. to record informal records of expenses, IOUs, and payments;

h. to respond to your comments, questions and requests and provide customer service;

i. to monitor and analyze trends, usage and activities in connection with our App;

j. solely with respect to information that you mark for sharing, for Company promotional purposes;

k. to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence, as well as for any other automated decision-making processing);

l. for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy.

Section 3. Your rights
3.1. Access and choice to your Personal Data

You have a right to access your Personal Data you insert into the App and ask us about what kind of Personal Data we have about you. You can do this by using the app settings or by writing us at support@finsplit.app.

You may review and update the Personal Data you have submitted to us at any time. You can make changes to your Personal Data from your Account Settings page. If you need help updating or correcting your Personal Data please contact us at support@finsplit.app.

Users can export data from their groups and friendships by following the instructions found here. We’re happy to help provide exports from your account. You can request exports by contacting us at support@finsplit.app.

3.2. Your choices regarding the data we collect and process

In many instances, you have choices about the information you provide and limiting how we use your Personal Data. These choices, and any related consequences, are described in detail below:

a. you may choose not to provide your Personal Data, such as your name, address, phone number or payment information, but then you might not be able to take advantage of many of our App features;

b. we may send periodic related alerts, monthly summaries, notifications, newsletters, promotions, or other information via email or push notifications. You may choose whether or not you’d like to receive alerts, summaries, newsletters and promotions by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in the email you receive. Please note that certain App-related messages (such as password resets) that we send are necessary for the proper functioning and use of the services and you may not have the ability to opt-out of those messages;

c. most mobile devices allow you to control or disable the use of location services by any application on your mobile device through the device’s settings’ menu;

d. you can choose whether or not you want friends to know if your email address of phone number is already associated with a Finsplit account from your Account Settings. Friends with your contact information will still be able to send you invitations and share expenses with you;

e. you have the ability to choose whether or not you’d like to use many of the third-party integrations we offer. If you authorize an account connection from a third-party account or platform, such as a Google or Facebook account, you can manage your connection preferences from the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.

3.3. EU residents

Individuals residing in the countries of the European Union have certain statutory rights in relation to their Personal Data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Personal Data (including in a structured and portable form), as well as to seek to update, delete or correct Personal Data:

а. Rectification of Personal Data and Restriction of Processing. You are responsible for ensuring the accuracy of your Personal Data that you submit to Finsplit. Inaccurate information will affect your experience when using the Finsplit website and App and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data by contacting us at support@finsplit.app. You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.

b. Access to your Personal Data and Data Portability. The App gives you the ability to access and update Personal Data within the App and your account settings. You shall have the right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) by simply writing us at support@finsplit.app.

c. Erasure of your Personal Data. If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, or in cases where the processing of your Personal Data does not otherwise comply with the GDPR, you have right to contact us and ask us to erase such Personal Data as described above. You can simply write us at support@finsplit.app. Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.

d. Right to object processing of your Personal Data. You can object processing your Personal Data and stop us from processing your Personal Data, simply write us at support@finsplit.app. Please be aware that erasing some Personal Data inserted by you may affect your possibility to use the App and its features.

e. Notice about automated decision-making. We use automated decision-making tools that process your Personal Data in order to provide you proper services.

f. Notification requirements. We commit to notify you within reasonable period of time and your data protection authority within the timeframe specified in applicable law (72 hours) about any Personal Data breaches in the App.

g. Data Protection Authorities. Subject to GDPR, you also have the right to (i) restrict our use of Personal Data and (ii) lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.

Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems – this is due to the size and complexity of the systems we use to store data.

3.4. Deleting your account

You may choose to close your account at any time. You can close your account from your Account Settings or request that we close it for you by writing to us at support@finsplit.app. When you close your account in this way, we may allow you to reactivate it by writing to us at support@finsplit.app.

3.5. Data retention

In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. We may also retain Personal Data to comply with law, prevent fraud, resolve disputes, enforce our Terms of Service, and as permitted by applicable law.

If you would like to fully delete your account and the information in it, you can write to us at support@finsplit.app. We will use commercially reasonable efforts to remove your Personal Data from our services so long as we do not have any legal reason or obligation to retain the record. It may take up to 90 days for your information to be cleared from our servers.

When you change or delete Personal Data, or close your account from your Account Settings, expenses involving you (either that you have shared or that have been shared with you) and your name may remain visible to people with whom they have been shared as part of their records (just as deleting an email account does not unsend emails that have already been sent).

Section 4. Sharing your Personal Data and information

We will not, without your permission, sell, publish, or share your Personal Data and information to third parties for their marketing purposes. We help you track and manage shared expenses with your friends by sharing your information in the following ways.

4.1. Provide the Finsplit App

Finsplit is designed to help you track and share expenses with your friends. We share some of your Personal Data (name, email address, phone number, user avatar) with your friends and groupmates on App. Someone who knows your email address and/or phone number will be able to add you as a friend and see your name, email address, and user avatar. They will not be able to see expenses that you’ve added with other friends unless you include them on those expenses or in a group.

Finsplit allows you to keep track of expenses in groups. These groups are private, and information and expenses posted in a group is only visible to other members of the group. However, any user in that group may add additional members to the group, so it is the joint and sole responsibility of group members to safeguard who they invite into their group sharing platform. App lets friends add, edit, delete and undelete content shared privately.

4.2. With third parties, affiliates, subsidiaries and service providers

We employ third-party agents, subsidiaries, affiliates, and/or App providers to enable them to help support and improve our App. For example, maintenance services, database management, cloud hosting, web and mobile analytics, receipt scanning services and OCR. Third parties acting on our behalf that are given access to your Personal Data are contractually obligated to abide by our privacy practices and are not allowed to use the information for any other purposes. We may share your Personal Data with other third parties with your consent or instructions to do so. Where permitted by law, third parties may use data provided to them to improve their own services.

4.3. Special Circumstances

We will not share any of your Personal Data to any third party except as otherwise stated in this Privacy Policy and in the following circumstances:

a. in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);

b. when disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws;

c. when disclosure is directed or consented to by the user who has input the Personal Data.

4.4. API Usage

Finsplit provides a third-party API which allows other applications which you sign up for to have access to the data you have provided App. You are in control of this process - we do not disclose any data to these third parties unless you specifically authorize your account with their application by using the Finsplit username and password prompt provided. We do not control these third parties and do not warrant that they are safe or non-fraudulent, and you agree that App is not responsible, liable for anything which occurs on these services. You indemnify Company from all damages if you authorize your Finsplit account with one of these third-party apps.

4.5. Business Transfer

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, Personal Data that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the Personal Data collected by us in connection with our business operations or through our website and such third parties will assume the rights and obligations regarding such information as described in this Privacy Statement and according to applicable regulations.

4.6. Non-identifiable information

We may disclose information that does not personally identify you in any other manner that we deem appropriate, including to third parties for their research, marketing, and promotional purposes and to help us determine how we can improve our App and website. We will also disclose non-personal information to our service providers and other third parties about how our users collectively use the website.

Section 5. Retention of your Personal Data

We will retain your Personal Data as long as your account is active or needed to provide you services, and only for as long as it serves purposes of processing identified in this Privacy Policy. At any time, you can remove your Personal Data as specified in this Privacy Policy.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

If you choose to delete the App, deactivate your account, we retain your Personal Data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the App. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services. Where we retain information for App improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.

Section 6. Personal Data you elect to share with third parties

You can direct us to share data from the App with other parties. For example, you can permit us to share data with other apps and services. Once you direct us to share your data with a third party, that third party will have their own Privacy Policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your Personal Data. For example, for the EU residents’ Personal Data we make reasonable efforts to ensure that such third parties are GDPR compliant and have GDPR compliant privacy policies in place.

Section 7. Security

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, considering the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect. Please understand, however, that while we try our best to safeguard your Personal Data once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. Among others, we utilize the following information security measures to protect your Personal Data:

а. Systematic vulnerability scanning and penetration testing;

b. Protection of data integrity;

c. Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.

d. Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Section 8. Children’s privacy

General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at support@finsplit.app and we will take required steps to delete such information and (or) delete her account.

Age limitation for EU residents. Due to requirements of the GDPR you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at support@finsplit.app and we will take steps to delete such information and (or) delete her account.

Section 9. Third party links

Although the App may contain links to third-party websites or apps, we are not responsible for the privacy policies and/or practices on those third-party websites or apps. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party websites or apps, you should read the Privacy Policy stated on that third-party websites or apps.

Section 10. Email Communications

We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us. We may ask such users at the registration screen to provide their consents for any such communications.

This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to the Company by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to the Company.

Section 11. International Personal Data transfers

The Company is based in the Republic of Belarus and the information we collect is governed by Belarusian law. Please be advised that Belarusian law and laws of other countries may not offer the same protections as the law of your jurisdiction.

In addition, you agree that information collected through the App may be stored and processed in country, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of information outside of your country.

Section 12. Contact us

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at Email: support@finsplit.app.

ITHUB, LLC

30, Engels str.
Minsk, Belarus, 220030
Email: support@finsplit.app