1. Controller
The controller within the meaning of the General Data Protection Regulation for the Fintraq mobile app is:
Andre Neubert
Mainz, Germany
Email: contact@andreneubert.com
2. Scope
This Privacy Policy applies exclusively to the Fintraq mobile app for Android and iOS. It describes which personal data is processed in connection with installing, using, and receiving support for the app.
Fintraq is an app for private financial planning. The app processes planning data relating in particular to accounts, budgets, fixed costs, income, loans, goals, transfers, notifications, and app settings.
3. Local Processing Principle
Fintraq is designed for local use. Financial data entered by you is stored on your device. There is no user account, no bank connection, and no synchronization of your financial data to servers operated by Andre Neubert.
The only transmission to a server operated by Andre Neubert consists of usage counters, which contain no financial data and can be switched off in the app; see the section “Usage Counters”.
Your financial planning data is not transmitted to Andre Neubert, Google AdMob, or other advertising service providers unless you actively transmit such data yourself, for example in connection with a support request.
4. Categories of Data Processed
In connection with the use of the app, the following categories of data may in particular be processed:
- financial planning data, such as account names, account balances, income, budgets, expenses, fixed costs, loans, goals, transfers, and monthly plans;
- app and usage settings, such as currency, notification settings, debugging settings, display options, and saved app configurations;
- backup and export files as well as backups copied to the clipboard, if you use these functions;
- the status of a Fintraq Plus subscription, which is stored exclusively locally on your device;
- technical advertising and device data, insofar as advertising is displayed via Google AdMob;
- usage counters, such as which app areas were opened, which parts of the introduction were used, the progress of the setup, app version, platform, and language, each together with a random identifier for your app installation;
- contact and content data if you voluntarily request support by email.
5. Purposes and Legal Bases
Processing is carried out for the following purposes and on the following legal bases:
- provision of the financial planning functions of the app on the basis of Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR;
- storage of app settings and local planning data for proper app use on the basis of Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR;
- display and management of local notifications on the basis of your device settings and, where required, your consent pursuant to Art. 6(1)(a) GDPR;
- display, frequency capping, security, and measurement of advertising via Google AdMob on the basis of Art. 6(1)(a) GDPR or Art. 6(1)(f) GDPR;
- improving the app on the basis of usage counters pursuant to your consent under Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG; you may withdraw that consent at any time in the app settings with effect for the future;
- handling of voluntary support requests on the basis of Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR.
6. Backups and Import
Fintraq lets you create a backup of your data as a file or copy it as text to the clipboard, and restore such a backup later. You can also export analyses as a file or copy them to the clipboard. The app hands files over through your operating system’s share dialog to the destination you choose there, for example the Files app, a cloud storage service, or an email. Fintraq itself does not upload any backup.
A backup contains all of your planning data, including the offers saved in the loan calculator, as well as app settings such as language and currency. It is not encrypted. You are responsible for the secure storage, disclosure, and deletion of backup and export files. Depending on the operating system, clipboard contents may also be readable by other apps.
Independently of this, the app data may be included in the operating system’s device backup (iCloud Backup or Google backup), depending on your device settings. That backup is carried out by Apple or Google, not by Fintraq.
7. Notifications
Fintraq may schedule local reminders and notifications on your device, for example regarding budgets, fixed costs, or monthly planning topics. These notifications are triggered by the app and the operating system. Fintraq does not operate its own push server.
Depending on your device settings, notification text may contain financial hints. You can disable or adjust notifications in the app and in your device system settings.
8. Usage Counters
Fintraq transmits counters to a server operated by Andre Neubert in Frankfurt am Main, Germany. The sole purpose is to see whether the app is understandable, which areas are used, and where users abandon the setup.
Transmitted are only:
- on which days the app was used and which areas of the app were opened on those days;
- for new installations, during the first 30 days after the first launch: which parts of the introduction were used (the three introductory views, the demo, opening the backup import, the entries made in the introduction, and its completion), how far the setup progressed, whether a backup was restored, and which of the five setup steps (fixed costs, budgets, loans, accounts and cards, reserves) were viewed, completed, or skipped, each only as a yes/no value;
- the app version, the platform, and the language selected in the app.
Not transmitted are: amounts, names, balances, or any other content of your entries, nor the status of a Fintraq Plus subscription.
Every report contains a random identifier for your app installation. It is generated in the app when first needed, is not derived from your device, and is not an advertising ID. Without it there would be no way to tell several people opening the app from one person opening it several times. The identifier therefore allows this installation to be recognised across sessions; a personal reference arises only in combination with additional knowledge that Andre Neubert does not have. The identifier ends when the app is uninstalled and is deleted as soon as you switch the usage counters off; switching them on again creates a new one. No IP addresses are stored.
Transmission happens continuously while you use the app: shortly after the app starts, when new counters arise, and when you leave the app. Without an internet connection, counters not yet transmitted remain on your device for at most seven days and are then discarded.
You decide in the dialog shown on first launch whether usage measurement is active; nothing is transmitted before that. You can switch it on or off in the app at any time under “More” → “Data & backup” → “Privacy” → “Share usage data”. When the switch is off, nothing more is collected, stored, or transmitted; counters not yet transmitted and the identifier are deleted.
9. Advertising with Google AdMob
Fintraq may display advertising via Google AdMob and the Google Mobile Ads SDK, in particular interstitial ads at carefully selected points in the app. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Depending on the processing, Google LLC, USA, may also be involved.
When providing, delivering, limiting, and measuring ads, Google may process, in particular, device and app information, IP address, advertising ID or other device identifiers, ad interactions, diagnostic and performance data, and approximate location insofar as this is derived from technical data.
Fintraq does not transmit financial planning data entered by you, such as account balances, budgets, loans, goals, or transfers, to Google.
Where legally required, Fintraq obtains consent before accessing local storage technologies, device identifiers, or before using personalized advertising. For users in the European Economic Area, the United Kingdom, and Switzerland, a Google-supported consent solution or an appropriately configured consent prompt is used for this purpose. Without required consent, non-personalized ads may be displayed or advertising functions may be restricted. You can review, change, or withdraw consent you have given in the app under “More” → “Data & backup” → “Privacy” → “Ads and cookies”.
On iOS, before ads are loaded for the first time, Fintraq uses the system’s App Tracking Transparency dialog to ask whether your device’s advertising identifier may be used for advertising. If you decline, Google does not get access to this identifier. You can change your decision at any time in your device settings.
With an active Fintraq Plus subscription, Fintraq does not display any advertising. If the subscription is active when the app starts, the Google Mobile Ads SDK is not initialized and no advertising-related data processing takes place in the app. If you subscribe while using the app, no more ads are loaded or displayed from that moment on.
Further information is available from Google:
10. App Stores
If you download Fintraq from Google Play or the Apple App Store, Google or Apple independently process data in connection with the download, store use, payment processing, device information, reviews, and support processes. The privacy information of the respective store operator applies to such processing.
11. In-App Purchases (Fintraq Plus)
Fintraq offers the optional auto-renewing subscription "Fintraq Plus" as an in-app purchase. Purchase, billing, management, and refunds are handled entirely by the Apple App Store or Google Play. Andre Neubert does not receive any payment data; no user account is created.
On launch, when you return to the app, and after a purchase, the app queries the system interface of the respective store to determine whether an active subscription exists and stores the result (active/inactive, product identifier, expiry date if available, time of the last check, and whether a subscription existed before) exclusively locally on your device. Beyond the processing by Apple or Google, no purchase data is transmitted to Andre Neubert or to any other third parties; the usage counters do not contain any information about the subscription either. The legal basis is Art. 6(1)(b) GDPR.
The privacy information of the respective store operator applies to the data processing by Apple or Google in connection with the purchase process (see also the "App Stores" section).
12. Support and Contact
If you contact us by email regarding Fintraq, your email address, the content of your message, and the information you voluntarily provide will be processed in order to respond to your request. Please transmit sensitive financial data only if this is necessary for handling your request.
13. Recipients and Third-Country Transfers
Your locally entered financial planning data is not transmitted to Andre Neubert or to advertising service providers unless you actively transmit such data yourself.
The usage counters are processed on a DigitalOcean server in Frankfurt am Main, Germany. No transfer to a third country takes place in this context.
In connection with advertising and app store use, Google, Apple, and, where applicable, their service providers may process data as independent controllers or processors. This may involve transfers to countries outside the EU or the EEA. According to their own statements, the providers rely on appropriate safeguards for such transfers, in particular adequacy decisions or EU Standard Contractual Clauses.
14. Retention Period
The usage counters produce daily totals without any personal reference; they are not re-attributed to individual persons. Installation identifiers are kept separately for at most 62 days and are then deleted automatically — that is as far back as the evaluation window reaches.
Local app data remains stored on your device until you delete it in the app, overwrite a backup, or remove the app or its data. Support requests are stored only for as long as necessary to handle the request and to comply with any statutory retention obligations.
15. Your Rights
Subject to the statutory requirements, you have the right of access, rectification, erasure, restriction of processing, data portability, and objection. You may withdraw consent at any time with effect for the future.
You also have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes data protection law.
16. No Automated Decision-Making
Andre Neubert does not carry out automated decision-making, including profiling, within the meaning of Art. 22 GDPR. To the extent that Google uses its own procedures in connection with advertising, Google's privacy information and settings apply.
17. Children and Minors
Fintraq is not specifically directed at children under the age of 16.
18. Security
Fintraq processes sensitive financial planning data. You should therefore carefully protect your device, exported backup files, and other backups. Use device locks, secure storage locations, and do not disclose backup files to third parties without due care.
19. Changes
This Privacy Policy may be amended if Fintraq, integrated services, or legal requirements change. The current version is available at this URL.