Privacy Policy for Billka AI

1. Introduction

This Privacy Policy explains how Sytoss, s. r. o. ("we," "us," or "our") collects, uses, and protects your personal data when you use the Billka AI mobile application ("App"). We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the CPRA, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable data protection laws.

Data Controller:

2. Data We Collect

2.1 Information You Provide Directly

  • Email Address: Required for account registration and login (provided directly or via Apple/Google authentication).
  • Name: Optional, for self-identification within the app (can also be retrieved from third-party login providers like Apple/Google).
  • Receipt/Bill Photos: Images you upload for scanning and expense tracking.

2.2 Information Collected Automatically

  • Device Information: Device type, operating system, and unique device identifiers.
  • Push Notification Tokens: Device-specific tokens to deliver in-app transaction alerts and friend requests.
  • IP Address: Collected for security, error logging, and to ensure data residency within the EU.
  • App Usage Data: Information on how you interact with our app (e.g., features used, session duration).
  • Subscription and Transaction Data: We receive transaction identifiers and subscription status from the Apple App Store and Google Play Store via RevenueCat. We do not process or store your credit card details.
  • Marketing Attribution Data: Information about which advertisement led to app installation (if marketing consent is given).

3. How We Use Your Data

We process your personal data under the following legal bases:

3.1 Essential Services (Legal Basis: Contract Performance)

  • Creating and managing your account.
  • Processing receipt/bill images to extract expense information.
  • Enabling expense splitting and saving features.
  • Communication: Delivering friend requests and splitting updates via Push Notification services.
  • Subscription Management: Processing purchase tokens to validate and provide access to premium features via RevenueCat.

3.2 App Improvement and Stability (Legal Basis: Legitimate Interest)

  • Error Tracking: Debugging and fixing technical issues through error logs (Sentry).
  • Product Health: Using anonymized analytics (PostHog) to monitor basic app performance and stability. This is processed based on our legitimate interest in providing a functional, bug-free application (Art. 6(1)(f) GDPR).

3.3 Advanced Analytics and Marketing (Legal Basis: Consent)

  • Usage Patterns: Understanding detailed user behavior to improve the app (PostHog).
  • Campaign Effectiveness: Measuring the effectiveness of marketing campaigns (AppsFlyer).

4. Data Sharing and Third-Party Services

We use the following third-party services to provide and improve our app:

4.1 Essential Services

  • Supabase: Authentication and user management (EU-Central-1).
  • Apple & Google Authentication: Third-party identity providers used conditionally during sign-up/login.
  • Google Vertex AI/Gemini API: Receipt image processing and text recognition (EU).
  • RevenueCat: Subscription management and entitlement validation (US/EU).
  • Hetzner: Backend hosting (Germany).
  • DigitalOcean Spaces: Image storage (EU).
  • ElasticSearch: Search functionality (hosted on our servers in Germany).
  • Google Cloud Run: PDF to JPG conversion service (EU).

4.2 Analytics and Marketing Services

  • PostHog: Product analytics. If consent is provided, data is linked to your user ID. If consent is declined, PostHog is used in an anonymized mode where personal identifiers and IP addresses are masked or removed before storage.
  • Google Analytics for Firebase: Product analytics and event tracking (e.g., login, onboarding, receipt processing). Disabled entirely if analytics consent is declined.
  • Sentry: Error tracking and app stability monitoring (Frankfurt, Germany).
  • AppsFlyer: Marketing attribution and campaign effectiveness (connected to Google Ads, Meta Ads Manager, TikTok Ads Manager).

5. Data Storage and Security

5.1 Storage Locations

All primary user data is stored within the European Union:

  • Backend servers: Germany (Hetzner).
  • Authentication data: EU-Central-1 (Supabase).
  • Error logs & Analytics: EU-based instances (Sentry/PostHog EU).
  • Images: EU (DigitalOcean).

5.2 Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including secure authentication through Supabase, encrypted data transmission (TLS), and strict access controls.

5.3 International Data Transfers

If you are accessing the App from the United States, Canada, or other regions outside the European Union, please note that your personal data is transferred to, stored, and processed in the EU (primarily Germany). By using our App, you consent to this cross-border transfer. We ensure your data remains protected under the stringent standards of the GDPR.

6. Data Retention

We retain your data for as long as your account is active. Specific retention periods include:

  • Authentication data: Deleted immediately when your account is deleted.
  • Uploaded receipts and images: Anonymized within 7 days after account deletion.
  • Subscription Records: Transaction history and subscription status are retained for up to 10 years after account deletion to comply with statutory tax and accounting obligations.
  • Anonymized data: Data that can no longer be linked to an individual is retained indefinitely for statistical purposes.

7. Your Privacy Rights

7.1 EU Residents (GDPR)

As a data subject under GDPR, you have the following rights:

  • Right to Access: Request a copy of your personal data.
  • Right to Rectification: Update your account information in the app settings.
  • Right to Erasure: Delete your account via the "Delete Profile" button in settings.
  • Right to Restrict Processing: Limit how we use your data via consent settings.
  • Right to Data Portability: Request your data in a structured, machine-readable format.
  • Right to Object: Object to processing based on legitimate interests.
  • Right to Withdraw Consent: Change your analytics and marketing preferences at any time.

7.2 US Residents (CCPA/CPRA)

Under California law and similar state laws, you have specific rights regarding your personal information:

  • Right to Know and Access: Request the categories and specific pieces of information we have collected.
  • Right to Delete: Request deletion of your personal information (via the "Delete Profile" feature).
  • Right to Correct: Request correction of inaccurate information.
  • Right to Opt-Out of Sale/Sharing: We do not "sell" data for monetary value. However, sharing data with marketing partners (like AppsFlyer) may constitute "sharing for cross-context behavioral advertising." You can opt-out at any time by turning off "Marketing" in the App's consent settings (which serves as your "Do Not Sell/Share" toggle).
  • Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

7.3 Canadian Residents (PIPEDA)

Under PIPEDA, Canadian users have the right to access the personal information we hold about them, request corrections, and withdraw consent for further processing. If you have questions or wish to file a complaint, you may contact our Privacy Officer at info@sytoss.com. You also have the right to direct privacy complaints to the Office of the Privacy Commissioner of Canada (OPC).

8. Consent Management

Upon your first launch of the app, you can manage your preferences:

  • Necessary: Essential functionality and anonymized health monitoring (always enabled).
  • Analytics (PostHog/Sentry/Google Analytics): Opt-in for full usage tracking. If you decline, PostHog and Sentry will switch to an anonymized mode where no PII is stored; Google Analytics will be disabled entirely.
  • Marketing (AppsFlyer): Opt-in for attribution tracking.

9. Children's Privacy

Our app is rated 3+ in app stores, but we do not knowingly collect personal data from children. To comply with regional laws (such as COPPA in the US and GDPR in the EU), our service is not directed at children under the age of 13 in the US, or under the age of 16 in the EU. If we become aware that we have inadvertently collected data from a child under these applicable age thresholds, we will take immediate steps to delete that information.

10. Contact Us

If you have any questions about this Privacy Policy:

Email: info@sytoss.com

Address: Sytoss, s. r. o., Hany Melickovej 6, 841 05 Bratislava, Slovakia

You also have the right to lodge a complaint with the Office for Personal Data Protection of the Slovak Republic (Urad na ochranu osobnych udajov Slovenskej republiky).