Portemonnaie

Legal

Privacy Policy for Portemonnaie

Last updated: 10 October 2026

This policy explains how personal data is handled when you use the Portemonnaie iOS app (the "App") and the website portemonnaie.app (the "Website").

In short

  • Your spending records stay on your device. We do not receive, store or have access to them.
  • The App has no user accounts, no analytics, no advertising, no tracking and no third-party SDKs.
  • The App does not connect to any server operated by us.
  • Purchases and subscriptions are handled entirely by Apple.

1. Who is responsible

The controller under the EU General Data Protection Regulation (GDPR) is:

Nándor Soma Abonyi
Anton-Flettner-Str. 25
14542 Werder (Havel)
Germany
Email: [email protected]

We have not appointed a data protection officer, as we are not required to do so.

2. Data in the App

2.1 What the App stores

The App stores the spending entries you create: amount, currency, description, your answers to "Did I need this?" and "Did I see it coming?", and the date and time. It also stores your settings (default currency, language, time format, whether the welcome screen was shown) and whether your subscription currently grants access.

The description field is free text. Please avoid entering information you would not want stored on your device.

2.2 Where it is stored

All of this data is stored locally on your device only. The App does not send it to us or to anyone else, and the App does not sync it via iCloud. We cannot see, access, restore or delete your data.

The Insights feature analyses your entries on your device only. Its results are shown to you and are not stored or sent anywhere. No automated decisions within the meaning of Art. 22 GDPR are made.

2.3 Device backups

Like most iOS apps, the App's data is included in your device backups (iCloud Backup or a backup on your computer) if you have enabled them. These backups are controlled by you and, for iCloud, processed by Apple under Apple's own privacy policy. We have no access to them.

2.4 Export and import

You can export all your entries as a JSON file and import such a file again. The export file is not encrypted. You choose where it is saved (for example on your device, in iCloud Drive or in another storage provider). The App does not upload the file anywhere on its own. Once exported, the file is under your control.

2.5 Deleting your data

You can delete individual entries, or all entries via Settings > Data > Erase All Data. Deleting the App removes all data stored by the App from your device. Copies in earlier device backups or in export files you saved remain until you delete them.

2.6 Permissions

The App does not request access to your location, contacts, photos, camera, microphone or notifications. It only accesses files you explicitly pick via the system file picker for import or export.

3. Purchases and subscriptions

Subscriptions are sold and processed by Apple through the App Store. Apple (Apple Distribution International Ltd. in the EU, Apple Inc. in other regions) acts as an independent controller for this processing, including payment, billing, refunds and subscription management.

The App checks your subscription status on your device using Apple's StoreKit framework. We do not receive your name, Apple Account details or payment information. Your spending data is never shared with Apple through this process.

For details see Apple's privacy policy: https://www.apple.com/legal/privacy/

You can manage or cancel your subscription in your Apple Account settings. Deleting the App does not cancel a subscription.

4. Crash reports and app statistics provided by Apple

If you have agreed in your device settings to share analytics with app developers, Apple may provide us with crash reports and aggregated usage statistics for the App (for example device model, iOS version, App version and technical details about a crash). These reports do not contain your spending entries.

We use this information only to find and fix errors. The legal basis is our legitimate interest in a stable, working App (Art. 6(1)(f) GDPR). You can stop sharing at any time in iOS Settings > Privacy & Security > Analytics & Improvements.

5. Beta testing via TestFlight

If you take part in a beta test via Apple's TestFlight, Apple provides us with information such as the name and email address associated with your invitation, installation and usage details of the beta, crash reports, and any feedback and screenshots you choose to send. We use this only to run the beta test and improve the App (Art. 6(1)(b) and (f) GDPR). See Apple's TestFlight privacy information for details. We delete this information when it is no longer needed for the beta test.

6. Contacting us

If you email us, we process your email address and the content of your message to answer your request. The legal basis is Art. 6(1)(b) GDPR where your request relates to a contract, otherwise our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). We delete your messages once your request has been fully handled, unless legal retention obligations apply. Our email is hosted by Apple (iCloud Mail).

7. The Website

The Website is a static site without cookies, tracking or analytics scripts. It is delivered by Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) as our hosting provider.

When you visit the Website, Cloudflare automatically processes technical data needed to deliver the pages and protect against attacks, such as your IP address, date and time of access, the page requested, browser type and referring page. The legal basis is our legitimate interest in providing a secure, working website (Art. 6(1)(f) GDPR). Cloudflare processes this data on our behalf under a data processing agreement and retains it only for a limited period according to its policies. From this data, Cloudflare provides us with aggregated statistics only, such as the number of visitors, requests and data transferred. We cannot identify individual visitors from these statistics.

8. Transfers outside the EU

Apple and Cloudflare may process data in the United States. Both are certified under the EU-U.S. Data Privacy Framework, which the European Commission has found to provide an adequate level of protection (Art. 45 GDPR). Where needed, Standard Contractual Clauses (Art. 46 GDPR) apply in addition.

9. Your rights

Under the GDPR you have the right to:

  • access the personal data we hold about you (Art. 15)
  • have it corrected (Art. 16)
  • have it deleted (Art. 17)
  • restrict its processing (Art. 18)
  • receive it in a portable format (Art. 20)
  • object to processing based on legitimate interests (Art. 21)

Right to object: Where we process data based on our legitimate interest (Art. 6(1)(f) GDPR), you can object at any time for reasons arising from your particular situation.

To exercise your rights, email us at the address in section 1. Please note that we do not hold the data stored in the App on your device, so we cannot access or delete it for you. You can do so yourself as described in section 2.5.

You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Die Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg
Stahnsdorfer Damm 77
14532 Kleinmachnow
Germany
https://www.lda.brandenburg.de

10. Children

The App is not directed at children, and we do not knowingly collect personal data from children. Since the App does not send any personal data to us, no such data is collected through the App.

11. Users outside the EU

We apply this policy to all users worldwide. We do not sell or share personal information, and we do not use personal information for targeted advertising.

12. Changes to this policy

We may update this policy when the App, the Website or legal requirements change. The current version is always available at https://portemonnaie.app/privacy/. The date at the top shows when it was last updated.