Privacy Policy

1. Data controller

• Controller: NeoCapita • Privacy contact: privacidad@neocapita.app You can exercise your GDPR rights by writing to that address.

2. Data we collect

NeoCapita only collects the data needed to provide the service: ACCOUNT DATA • Email address (for authentication via Firebase Auth) • Username, which you choose when you sign up. If you sign in with Google or Apple, they provide it. • If you sign in with Google or Apple, we receive your account identifier and email address from them. We never receive your password. With Apple you may hide your real email; in that case we only ever see the relay address Apple generates. • Date of birth: requested at sign-up and used at that moment for two things, to check you are at least 16 and to decide whether the account must be created as a supervised minor account. It is NOT stored, neither on your device nor on our servers. The only thing recorded is whether the account is of the "junior" type, which is what the supervision feature needs. FINANCIAL DATA ENTERED BY THE USER • Income and expense transactions • Bank account balances • Loans and debts • Recurring and fixed expenses • Savings goals ARTIFICIAL INTELLIGENCE FEATURES • Photos of purchase receipts captured with the camera, sent to the Google Gemini API for analysis. NeoCapita does not store these images once processed. • Text from expense descriptions, financial-assistant queries and monthly summaries, processed via the Groq API to categorize transactions and generate analysis. Only the necessary text is sent, never your identity or credentials. All calls to these AI services are made through our secure servers (Firebase Cloud Functions); the access keys are never in the app. TECHNICAL DATA • Firebase session data for the proper functioning of the service. • A device identifier managed by OneSignal, solely to send you push notifications (e.g. alerts when your partner records an expense). • Usage and crash-diagnostics data (Firebase Analytics and Crashlytics) to improve the app's stability. These are not strictly anonymous: they are tied to an installation identifier, not to your account or your email address. They are not used for advertising and are not combined with data from other apps. BETA FORM DATA (web) • If you request access to the beta from our website, we collect your name and email for the sole purpose of inviting you to the TestFlight or Google Play beta. DATA YOU SEND US WHEN YOU WRITE TO US • If you use the in-app option to send feedback or report a bug, we collect the text you write along with your email, username, app version, platform, device model and language. This lets us reply and reproduce the problem. The notification reaches us by email through Resend.

3. Purpose and legal basis

• Service provision and cloud sync → legal basis: performance of a contract (art. 6.1.b GDPR) • AI features (receipt analysis, expense categorization, assistant and summaries) → legal basis: the user's explicit consent (art. 6.1.a GDPR). Only processed when the user starts the feature voluntarily. • Push notifications (OneSignal) → legal basis: consent (art. 6.1.a GDPR). You can revoke it at any time from your device settings. • Handling the beta request → legal basis: consent of the data subject (art. 6.1.a GDPR). • Shared household and minor supervision → legal basis: performance of a contract (art. 6.1.b GDPR). Processing only begins when one party invites and the other accepts the link, and ends when either of them breaks it. • Handling feedback and bug reports, and the automated emails they generate → legal basis: legitimate interest in maintaining and improving the service (art. 6.1.f GDPR) • Security and fraud prevention → legal basis: legitimate interest (art. 6.1.f GDPR)

4. Storage and international transfers

Your financial and account data is stored in Google Firestore, in the Madrid region (europe-southwest1). The server-side processes that handle it (Cloud Functions) run in Belgium (europe-west1). In other words, your data resides inside the European Union. It leaves the EEA in three specific cases, and only the content strictly needed: • When you scan a receipt, the photo is sent to the Google Gemini API to be read. • When you use automatic categorization, the assistant or the summaries, the relevant text is sent to the Groq API. • Push notifications are delivered through OneSignal, and automated emails (feedback and beta-request alerts) through Resend. These providers act as data processors and the transfers rely on the standard contractual clauses approved by the European Commission. All calls leave from our servers, never directly from your phone, and do not include your name, your email or your credentials.

5. Retention period

• Account data and financial data: while you keep your account active. When you delete your account from Settings, deletion is immediate and permanent: your accounts, transactions, fixed expenses, goals, budgets, invitation codes and AI usage counter are all erased. There is no grace period and we will not be able to give your data back if you change your mind: we do not restore individual accounts. We do keep technical backups of the whole database, retained for at most four weeks, plus a seven-day recovery history. They exist so we can bring the service back if something breaks, not to undo a user's deletion, and your data disappears from them when those copies expire. • Local copy on your device: the app keeps a copy of your data on the phone so you can open it without a connection. That copy disappears when you sign out or uninstall the app, and it is excluded from Android's automatic backups. • Receipt images and text sent to the AI: not stored on any NeoCapita server. They are sent to Google Gemini or Groq, the response is processed and the content is discarded. Retention on those providers' side is governed by their own policies. • Beta form data: kept for the duration of the testing period and deleted when the beta ends. • Feedback and bug reports: kept for as long as they remain useful to fix what you reported.

6. Data sharing

NeoCapita does not sell or share your personal data with third parties for commercial purposes. Data is only shared with: • Google Firebase: storage, authentication and cloud functions (data processor) • Google Gemini API: analysis of receipt images (data processor) • Groq API: expense categorization, financial assistant and monthly summaries (data processor) • OneSignal: sending push notifications (data processor) • Resend: delivery of the automated emails the app generates (feedback and beta-request alerts) • Google and Apple: only if you choose to sign in with their accounts, to verify your identity • Other people in your household: if you voluntarily enable the shared household or the supervision of a minor. This is explained in detail in the next section, because it is the most distinctive part of NeoCapita.

7. Data shared with other people

NeoCapita lets several people see the accounts of one household. That means sharing financial data with another human being, so you should know exactly what happens. SHARED HOUSEHOLD AND PARTNER When you link your account with another person, they get to see your accounts, balances, transactions, fixed expenses and goals, and you get to see theirs. They can also: • create transactions in the household and edit yours, for example to correct the category of an expense; • modify the household's accounts, fixed expenses and currency. They cannot delete your transactions or delete your household: that stays with each owner. PRIVATE ACCOUNTS AND TRANSACTIONS You can mark an account or a transaction as private and the other person stops seeing it. With two different scopes, and we would rather say so plainly: • Private TRANSACTIONS are protected on the server. Our access rules deny reading them to anyone but you, whether through the app or any other tool. • Private ACCOUNTS and FIXED EXPENSES are today hidden only in the application. They live inside the same document as the household's shared data, and that document is read whole or not at all. It is a barrier designed for ordinary household life, not a guarantee against someone technical. We are working on separating them. In the meantime: if an account's name or balance must not be seen by anyone else under any circumstance, do not create it inside a shared household. UNLINKING Either side can break the link at any time from the app, without the other's permission. From that moment on they stop seeing each other's data. Whatever each person entered remains theirs and stays in their account. SUPERVISED MINOR ACCOUNTS If the account belongs to someone between 16 and 18, it needs an adult to link as a guardian using a temporary code generated by the app itself. While the link is active, the guardian sees the minor's accounts, transactions and fixed expenses, and can write in their household. The guardian cannot change the minor's password or access their email. The minor can break the link from the app whenever they want.

8. Your GDPR rights

As a user, you have the right to: • Access: request a copy of the data we process about you • Rectification: correct inaccurate data • Erasure ("right to be forgotten"): request the deletion of your data • Portability: receive your data in a structured, machine-readable format • Objection and restriction: object to certain processing or request its restriction • Withdrawal of consent: at any time, without affecting the lawfulness of prior processing To exercise any of these rights, write to us at privacidad@neocapita.app. We will respond within a maximum of 30 days. If you believe the processing is not compliant, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

9. Security

NeoCapita implements appropriate technical and organizational measures to protect your data against unauthorized access, loss or disclosure, including: • Authentication via Firebase Authentication, with mandatory email verification before you can sign in. • Encrypted communications in transit (HTTPS/TLS) and data encrypted at rest on Google's servers. • Deny-by-default Firestore security rules: your data is reachable only by you and by the people you have linked, each with different permissions as explained in section 7. • The access keys for the AI and email services live in a server-side secret manager, never inside the app. • Optional biometric lock (fingerprint or face recognition) to open the app. • Per-user usage limits on the AI features, to prevent abuse. We also want to be transparent about the limits of the above: • The local copy the app keeps on your device so it works offline is not encrypted by us; it relies on the phone's own encryption. That is why we have excluded it from Android's automatic backups. We are working on doing the same on iOS. • Inside a shared household, private transactions are protected by the server, but private accounts and fixed expenses are still hidden only in the app, as detailed in section 7. No system is infallible. If we detect a breach affecting your data, we will inform you and notify the Spanish Data Protection Agency within the deadlines set by the GDPR.

10. Minors

The minimum age to use NeoCapita is 16. At sign-up we ask for your date of birth and the account cannot be created below that age. Between 16 and 18 the account is created as a supervised account. It cannot be used until an adult links as a guardian by entering a temporary code generated by the app itself. From then on, the guardian sees the minor's accounts, transactions and fixed expenses, as explained in section 7. The minor can break that link from the app at any time. We chose 16 because that is the age from which the GDPR and Spanish law allow a person to consent on their own to the processing of their data in information-society services. Supervision up to 18 is our own measure, not a legal obligation. If you are a parent or guardian and believe a child under 16 has managed to create an account, write to us at privacidad@neocapita.app and we will delete it.

11. Device permissions

NeoCapita may request the following permissions: • Camera: only to photograph purchase receipts when you start the AI scan feature. The app does not open your photo gallery or read images already on your phone. • Notifications: for payment reminders of fixed expenses and debts, and to alert you when someone in your household records an expense. You can revoke this at any time from your device settings. • Biometrics (fingerprint or face recognition): optional, to protect opening the app. The check is performed by the operating system on the device itself; NeoCapita never receives or stores your fingerprint or your face. No permission is requested without an explicit action from you that justifies it. NeoCapita does not access your contacts, your location, or your real bank accounts: all financial data is entered by you, by hand or by scanning a receipt.

12. Changes to this policy

We may update this Privacy Policy occasionally. When we do, we will update the date at the top of the document and, if the changes are significant, we will notify you through the app or by email.