Privacy Policy for Greenbar
Effective Date: [Effective Date]
Last Updated: [Effective Date]
Publisher: [Company Name]
Address: [Business Address]
Contact: [Support Email]
1. Introduction
[Company Name]("we," "us," or "our") publishes Greenbar (the "App"), an offline-first personal finance and money-tracking application available on the Apple App Store and Google Play. This Privacy Policy explains how the App handles information when you use it on your mobile device.
Greenbar is built around a single privacy principle: your financial data never leaves your device unless you choose to export it. We do not operate servers that receive, store, or process your financial information. We cannot see your transactions, your balances, your budgets, or your goals.
By installing or using the App, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not install or continue using the App.
2. Information We Collect
Because Greenbar runs entirely on your device, the categories of information we, as the publisher, actually receive are very narrow. They are:
2.1 Information You Provide Directly to Us
- Support correspondence. If you email [Support Email] for help, we receive the contents of your message, your email address, and any attachments you choose to send. We use this only to respond to you.
2.2 Information the App Stores Locally on Your Device
The following data is created and held only on your device's local storage. We do not receive it.
- Imported transaction data from CSV or PDF bank statements you select.
- Budgets, categories, goals, and notes you create.
- Detected recurring expenses, anomaly flags, and insights computed locally from the above.
- Application preferences (theme, display options, onboarding state).
- A PIN hash (one-way derived; the PIN itself is never stored) and a flag indicating whether you have enabled biometric unlock.
- Encrypted backup archives you generate, until you delete them or share them yourself.
2.3 Information Collected by the Platforms (Apple / Google), Not by Us
When you download a paid app, the App Store or Google Play handle the transaction. Those platforms may collect your purchase and device information under their privacy policies, not ours. We receive only aggregate, de-identified sales and crash reports through those platforms' developer dashboards (for example, "X downloads this week" or "App crashed on device model Y"). These reports do not identify you to us.
3. Information We Do Not Collect
For the avoidance of doubt, we do not:
- Require you to create an account, register, or sign in.
- Operate cloud servers that store your financial data.
- Transmit your transactions, balances, budgets, or imported documents to us or to any third party.
- Sell, rent, lease, or share your personal information for monetary or other valuable consideration with any third party.
- Use advertising networks or display third-party ads inside the App.
- Embed third-party analytics SDKs, marketing SDKs, attribution SDKs, or behavioral tracking SDKs.
- Build a behavioral profile of you, your spending, or your finances on our servers (because we have no servers that touch your financial data).
- Track you across other apps, websites, or services.
- Use cookies or similar tracking technologies inside the App.
4. How Data Is Processed
All processing happens locally on your device:
- Statement import. When you select a CSV or PDF file, the App parses it in-memory on your device. The file is not uploaded.
- Categorization, budgeting, anomaly detection, recurring-charge detection, and insights. These computations run entirely on your device.
- Backup and restore.When you create a backup, the App produces an encrypted archive on your device using AES-GCM with a 256-bit key derived from a passphrase you supply. You choose where to save it (for example, your device's Files app or a cloud drive of your choice). Restoring works in reverse and also runs locally.
We have no ability to access, read, or decrypt your data.
5. Local Device Storage
Greenbar uses your device's standard local storage facilities (such as the WebView's localStorage and, where supported, encrypted local storage provided by the operating system) to persist the information described in Section 2.2.
You control this storage. You can:
- Clear individual records from inside the App.
- Use the App's built-in "reset" / "delete all data" function.
- Uninstall the App, which deletes its locally stored data in accordance with the host operating system's rules.
Backups you have exported to other locations (a cloud drive, an email, an external SD card) are not affected by uninstalling and must be deleted by you separately.
6. Third-Party Services
The App is designed to function without contacting third-party services for its core features. The limited third-party interactions that exist are:
- Apple App Store / Google Play. Distribution, purchase, subscription management, and platform-level crash reporting are handled by Apple Inc. and Google LLC under their respective privacy policies.
- Your device's operating system. Biometric verification (Face ID, Touch ID, fingerprint, etc.) is performed by the operating system. The App receives only a success/failure signal; it never sees your biometric data.
- Destinations you choose for backups. If you save an encrypted backup to a cloud drive (e.g., iCloud Drive, Google Drive) or share it through another app, that destination's privacy policy applies to the file once it leaves the App.
We do not embed third-party advertising, analytics, marketing, attribution, or social-media SDKs in the App.
7. Analytics and Crash Reporting
The App currently does not include in-app analytics or in-app crash reporting. We rely solely on the aggregate, de-identified reports the Apple and Google developer dashboards provide.
We may, in a future version, add optional, opt-in, anonymous diagnostic reporting to help us identify bugs and improve stability. If we do:
- It will be off by default.
- We will request your explicit consent through an in-app prompt before enabling it.
- It will collect only non-identifying technical signals (for example, anonymized crash stack traces, app version, OS version, device model).
- It will not transmit your financial data, transactions, budgets, goals, or any document you import.
- You will be able to disable it at any time in the App's settings.
If and when that feature ships, this Policy will be updated and you will be notified in-app on first launch of the updated version.
8. Apple App Store Compliance
The App is distributed through the Apple App Store and complies with Apple's Developer Program License Agreement and App Store Review Guidelines, including:
- App Tracking Transparency (ATT). The App does not track you across apps and websites owned by other companies as "tracking" is defined by Apple, and therefore does not request the ATT permission.
- Privacy Nutrition Labels.Our App Store privacy disclosures ("Data Not Collected") match the practices described in this Policy.
- Data Minimization. The App requests only the device permissions necessary to function (for example, file access when you import a statement, biometric access when you choose to enable biometric unlock).
- Purchases.All paid features and any subscriptions are processed through Apple's In-App Purchase or App Store billing system, subject to Apple's terms and privacy policy.
9. Google Play Compliance
The App complies with Google Play's Developer Program Policies, including the User Data, Permissions, and Families policies, as well as Play's Data Safety disclosure requirements:
- Data Safety form. Our Play Console disclosures state that the App does not collect or share user data, that data is processed on-device, and that data is encrypted in transit (where any transmission you initiate, such as a backup upload to your own cloud drive, leverages standard OS-level transport security).
- Permissions. The App requests only the permissions necessary for declared functionality.
- Purchases.Paid features and subscriptions are processed through Google Play Billing, subject to Google's terms and privacy policy.
10. Your Rights Under the GDPR (and UK GDPR)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (or the UK GDPR) gives you certain rights regarding personal data.
Because the data the App handles stays on your device and is not received by us, you can exercise most of these rights directly inside the App:
| Right | How to exercise it |
|---|---|
| Access | Open the App; all your data is visible to you. |
| Rectification | Edit any record directly in the App. |
| Erasure (“right to be forgotten”) | Delete records in-app or use the App's reset function; uninstalling the App removes local data. |
| Restriction | Stop using affected features or delete the relevant records. |
| Portability | Use the App's encrypted backup/export function to obtain a copy of your data. |
| Objection | Stop using the App and uninstall it. |
| Withdraw consent | Disable any optional feature you previously enabled (e.g., biometric unlock). |
For data you have actually transmitted to us (for example, the contents of a support email you sent to [Support Email]), you may exercise these rights by writing to [Support Email] or [Business Address]. We will respond within one month, as required by the GDPR.
Lawful bases. For the limited personal data we do receive (support correspondence), we rely on legitimate interests (Art. 6(1)(f) GDPR) in responding to your inquiries and, where you contact us, your consent (Art. 6(1)(a) GDPR).
Supervisory authority. You have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence or place of the alleged infringement.
11. Your Rights Under the CCPA / CPRA (California Residents)
If you are a California resident, the California Consumer Privacy Act, as amended by the CPRA, gives you the following rights:
- Right to Know what categories of personal information have been collected about you.
- Right to Delete personal information collected from you.
- Right to Correct inaccurate personal information.
- Right to Opt Out of Sale or Sharing of personal information.
- Right to Limit Use of Sensitive Personal Information.
- Right to Non-Discrimination for exercising any of the above rights.
Sale and Sharing. We do not, and have not in the preceding twelve (12) months, sold or shared your personal information within the meaning of the CCPA/CPRA. We do not use or disclose sensitive personal information for purposes beyond those permitted under CCPA § 1798.121.
Because the App stores your financial data on your device only, you can exercise the rights to know, delete, and correct directly inside the App (see the table in Section 10). For data you sent us in support correspondence, contact [Support Email].
We do not "financially incentivize" you to provide personal information.
12. Children's Privacy
The App is not directed to children under the age of 13 (or under 16 in the EEA, or under the equivalent age in your jurisdiction), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe a child has provided us with personal information (for example, by sending us a support email), please contact [Support Email] and we will delete it.
The App is rated according to the applicable Apple and Google age-rating systems.
13. Data Retention
- On-device data. Data stored on your device is retained until you delete it or uninstall the App. We have no role in this retention.
- Backups you export. Encrypted backup files you create remain wherever you saved them until you delete them.
- Support correspondence. We retain support emails for a period reasonably necessary to resolve your issue and to maintain records of customer service, typically no longer than 24 months, after which we delete or anonymize them, unless a longer period is required by law.
14. Security Measures
We have designed the App to minimize risk by minimizing what leaves your device. In addition:
- PIN protection. You may set a numeric PIN. The PIN is never stored in plaintext; only a one-way derivation (PBKDF2-SHA256 with a per-install salt) is stored locally.
- Biometric authentication.Where your device supports it (Face ID, Touch ID, fingerprint), you may enable biometric unlock. The biometric match is performed by your device's operating system; the App does not receive or store your biometric data.
- Encrypted backups. Backup archives you create are encrypted using AES-GCM with a 256-bit key derived from a passphrase you provide. Without that passphrase, the archive cannot be decrypted by us or by anyone else.
- No cloud surface. Because we do not operate servers that receive your data, there is no cloud-side breach vector for your financial information.
No security measure is perfect. We encourage you to keep your device's operating system up to date, use a strong device passcode, and protect any passphrases you choose for backups.
15. International Users
The App can be used worldwide, subject to applicable export-control laws. Because your data stays on your device, no cross-border transfer of your financial data is performed by us. If you contact us from outside the country in which [Company Name] is established, you understand that your support correspondence will be received and processed there.
Where required (for example, transfers from the EEA to a third country), we rely on appropriate safeguards under the GDPR, such as the European Commission's Standard Contractual Clauses, as applicable.
16. Contact Information
Questions, requests, and privacy rights inquiries can be sent to:
[Company Name]
[Business Address]
Email: [Support Email]
For GDPR / UK GDPR matters, you may address correspondence to our Privacy Contactat the same address. For CCPA / CPRA requests, please state "California Privacy Request" in the subject line so we can route it appropriately.
We will respond to verifiable consumer requests within the timeframes required by applicable law (generally 45 days under CCPA/CPRA and one month under GDPR, each extendable as the statutes permit).
17. Changes to This Policy
We may update this Policy from time to time to reflect changes in the App, in applicable law, or in our practices. When we do:
- We will update the Effective Date at the top of this Policy.
- For material changes, we will display an in-app notice on first launch of the updated App version and, where required by law, obtain your consent before applying the change to data you previously provided.
Your continued use of the App after the Effective Date of an updated Policy constitutes acceptance of that update, to the extent permitted by law.
© [Effective Date] [Company Name]. All rights reserved.