⚠️ Draft — not yet reviewed by legal counsel. This Privacy Policy must be reviewed by a German data protection lawyer before the app is promoted to real users. Budget ~€500. Required before first user onboards. Contact: info@pocketmoneyadvisor.de

Privacy Policy

Last updated: June 2026 · Version 1.0 (Beta)

Pocket Money Advisor ("we", "us", "our") is committed to protecting your personal data in compliance with the EU General Data Protection Regulation (GDPR) and applicable German data protection law (BDSG).

1. Who We Are (Controller)

The data controller for this service is:

Pocket Money Advisor
[Legal entity name to be confirmed — pending UG/GmbH formation]
[Address — pending registration]
Email: info@pocketmoneyadvisor.de

2. What Data We Collect and Why

Data Source Purpose Legal basis (GDPR Art. 6)
Email address, full name, profile picture Clerk authentication provider (sign-up / OAuth) Account identification and communication Art. 6(1)(b) — contract performance
Financial goals questionnaire responses User input on first login Personalising the dashboard experience Art. 6(1)(a) — consent
Imported bank transaction data (CSV) User-uploaded CSV export from their bank Spending analysis, categorisation, insights Art. 6(1)(a) — explicit consent; Art. 6(1)(b) — service provision
App preferences (language, currency, notifications) Settings page Personalising your experience Art. 6(1)(b) — contract performance
In-app feedback (page rating, optional comment) Feedback widget Product improvement Art. 6(1)(a) — consent
Waitlist sign-up (email, interest areas) Waitlist form Notifying you when premium features launch Art. 6(1)(a) — consent
Error and performance data (Sentry) Automatic — browser and server Bug detection and reliability Art. 6(1)(f) — legitimate interest
Product usage events (pages visited, features used, import errors), linked to your account email Automatic — in-app, first-party only (no third-party analytics) Diagnosing problems and improving the product during the alpha phase Art. 6(1)(f) — legitimate interest
Structural file-layout sample when a bank format is not yet recognised (names, addresses, IBANs and account numbers automatically redacted before storage) Import of an unrecognised bank file Adding support for your bank's format Art. 6(1)(f) — legitimate interest

3. How We Store and Protect Your Data

3.1 Database

All personal data is stored in a PostgreSQL database running on our own server hosted by Hostinger in Frankfurt, Germany — within the European Economic Area. The database accepts connections only from the application on the same machine (it is not reachable from the internet), the server firewall exposes only the web ports, and administrative access is restricted to SSH key authentication. All traffic between your browser and our server is encrypted with TLS (HTTPS, enforced via HSTS).

3.2 Authentication

Authentication is handled by Clerk (clerk.com), which processes your email and identity data. Clerk is GDPR-compliant and can be configured for EU data residency. See Clerk's Privacy Policy.

3.3 Bank Statement Import Data

When you upload a bank statement (CSV, Excel, PDF, or MT940), the file is processed in memory on our server and never stored as a raw file. Only the parsed and normalised transaction rows (date, description, amount, category) are stored in our database. The original file is discarded immediately after parsing.

One exception: if your bank's file format is not yet recognised, we keep a small structural sample of the file layout so we can add support for it. Names, addresses, IBANs and account numbers are automatically redacted from that sample before it is stored, and the sample is deleted within 30 days once support has been added.

Your bank credentials are never requested or stored. Statement import is entirely offline — no connection is made to your bank.

3.4 Error Tracking

We use Sentry to capture application errors. Error reports may include IP addresses, browser type, and anonymised stack traces. Sentry processes data under a Data Processing Agreement. No financial transaction data is included in error reports.

3.5 Server Logs

Diagnostic server logs are automatically redacted of personal data (names, addresses, IBANs, account numbers) before being written, and are automatically deleted after 30 days.

4. Data Sharing and Third Parties

We do not sell your personal data. We share data only with the following processors under GDPR-compliant agreements:

No data is transferred outside the EU/EEA.

5. Data Retention

Data typeRetention period
Account dataUntil account deletion
Transaction data (CSV imports)Until account deletion or manual deletion of the import
Questionnaire responsesUntil account deletion
Feedback submissionsUntil account deletion, or 2 years after submission
Waitlist entriesUntil you request removal or premium launches
Error logs (Sentry)30 days
Product usage eventsUntil account deletion (deleted together with the account)
Server logs (PII-redacted)30 days
Structural file-layout samples (PII-redacted)30 days after bank support is added

6. Your Rights Under GDPR

You have the following rights:

To exercise any right, email info@pocketmoneyadvisor.de. We will respond within 30 days.

7. Cookies and Local Storage

We use localStorage in your browser to store your preferences (language, currency, onboarding status). We use session cookies issued by Clerk for authentication. No marketing or advertising cookies are set.

We will ask for your consent before setting any non-essential cookies (analytics, error tracking).

8. Children

This service is not directed at users under 18. We do not knowingly collect data from minors.

9. Changes to This Policy

We may update this policy. We will notify you of material changes via email (if provided) or a prominent notice in the app. Continued use after notification constitutes acceptance.

10. Supervisory Authority

You have the right to lodge a complaint with the relevant data protection supervisory authority. In Germany, this is the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) or the relevant state authority (Landesbeauftragter).

11. Contact

Data protection enquiries: info@pocketmoneyadvisor.de

🇪🇺 GDPR compliant 🏛️ Hosted in Europe 🔒 No data sold 📂 CSV — no bank credentials stored