Privacy Policy

1. About this Policy

1.1 This Privacy Policy (the “Policy”) describes how we collect, share and use any information that, used alone or in combination with other information, relates to you (“Personal Data”) when you (“you” and “your”) use the Evenly website (“Website”) or the Evenly applications (“Application/Applications”).

1.2 This Policy also sets out the rights you have in relation to the Personal Data we process concerning you, and how you can exercise them.

1.3 For the purposes of this Policy, “we”, “us” and “our” refer to the operator of Evenly, which owns, develops and operates the Application and the Website and acts as the controller of your Personal Data.

1.4 Respecting your privacy is one of our core values. We apply the standards described in this Policy and keep the amount of Personal Data we collect limited to what the features you use actually need. Please take the time to read this Policy carefully. If you have any questions, you can reach us through the Contact page in the app.

2. What Personal Data we collect and why

2.1 We collect the Personal Data you provide, or that is generated when you use a feature. Each purpose below lists the data involved and the basis on which we process it.

• Creating and managing your account: your name, email address and profile photo, so you can sign in and so the people you share a Split with recognise you — performance of our contract with you.
• Keeping your accounts, balances, transactions, budgets, goals and recurring payments: the amounts, currencies, dates, categories, descriptions and notes you enter, and the accounts you create — performance of our contract with you.
• Split groups: the name, currency and members of each Split, the expenses, contributions, refunds and payment requests in it, and the aliases used to match the people in the group — performance of our contract with you, and the legitimate interest of the group's other members in keeping a correct shared account sheet.
• Split Memories: the photos and videos you upload to a Split, the note attached to them, the reactions and comments, and who viewed them. Memories are visible to the members of that Split only — performance of our contract with you.
• Friends and invitations: the name, email address or phone number of a person you invite to Evenly or to a Split, so the invitation can reach them — our legitimate interest in letting you share an expense with them, and your responsibility to only invite people who expect it.
• The Even assistant: the questions you type, together with the financial data needed to answer them. Your conversation is cleared when you close the app — performance of our contract with you.
• Evenly+: if you subscribe, the plan you chose and the status and renewal date of your subscription. Card details are entered directly with our payment provider and never reach us — performance of our contract with you.
• Sending notifications inside the app and, where you allow it, emails about invitations, expenses and your account — your consent for notifications, and our legitimate interest for service messages.
• Responding to your requests when you contact us: your email address and the content of your message — our legitimate interest in answering you.
• Statistical analysis of how the app is used, so we can fix bugs and improve it: technical data described in section 3, in aggregate form wherever possible — our legitimate interest in improving Evenly.

3. Information collected automatically

3.1 When you use the Application, we may automatically collect limited technical information: your IP address, device type, operating system, browser type, the language of the app, broad location derived from your IP address (country or city), the screens you open, the actions you take and any errors you encounter.

3.2 We use this information to keep the service secure, to diagnose and correct bugs and to understand which parts of Evenly are used, so we can improve them.

3.3 Evenly contains no third-party advertising and no advertising identifier is collected. The only sponsored content that can appear in a Split gallery is Evenly's own, and it is labelled as such. We do not build advertising profiles of you and we do not sell your Personal Data.

4. Information stored on your device

4.1 Evenly keeps some information on your device so the app opens quickly and works with a weak connection: your session, your display preferences (language, theme, preferred currencies), cached memories of your Splits and your most recently used accounts.

4.2 This information stays on your device. You can clear it at any time by signing out of the app or by deleting the app from your device.

4.3 The Website uses only the storage needed to keep you signed in and to remember your preferences. It does not use advertising or third-party tracking cookies.

5. Who we share your Personal Data with

5.1 We share Personal Data only in the situations below, and never sell it.

• The other members of a Split: they can see the expenses, contributions, balances, names, aliases and Memories of that Split. A Split can be shared through a link, so anyone holding that link can open a read-only view of it — share it only with people you trust.
• Our technical service providers, who process data on our behalf to run Evenly: hosting and database services, file storage for your memories and photos, and email delivery. They act only on our instructions.
• Our payment provider, when you subscribe to Evenly+, to process the payment and manage the subscription. Your card details are given to that provider directly.
• Any relevant law enforcement agency, regulator, court or other authority, when we believe disclosure is required by law, necessary to establish or defend our rights, or necessary to protect your vital interests or those of another person.
• Our auditors, advisors and legal representatives when their advisory services require it, under an obligation of confidentiality.
• A potential purchaser, investor or lender in connection with a sale, merger or financing of our business, provided they may only use your Personal Data for the purposes described in this Policy.
• Any other person, where you have given your prior consent to the disclosure.

6. How we protect your privacy

6.1 In accordance with this Policy, we process Personal Data as follows:

• Loyalty and transparency: we process Personal Data fairly, in accordance with applicable law, and we are transparent about how we do it.
• Purpose limitation: we process Personal Data for the specified and lawful purposes described in this Policy, and not in a manner inconsistent with them.
• Proportionality: we process Personal Data in a manner proportionate to the purposes for which the processing is intended, and we keep it to what a feature needs.
• Accuracy: we take appropriate measures to keep the Personal Data we hold accurate and up to date. You can correct most of it yourself from My Profile or from the relevant screen, and you can also contact us.
• Security: we use appropriate technical and organisational measures to protect your Personal Data, designed to provide a level of security appropriate to the risk. These include securing system access, protecting credentials, encrypting traffic between the app and our servers, logical access control, a list of authorised personnel, and backup systems.
• Data processors: third parties that process Personal Data for us are required to act strictly on our instructions and to keep the data protected.
• International transfers: your Personal Data may be transferred to and processed in countries other than the one you live in, whose data protection laws may differ from yours. Where that happens, we rely on appropriate safeguards, including standard contractual clauses, so that your Personal Data remains protected in accordance with this Policy.
• Retention: we keep your Personal Data for as long as you have an account, and afterwards only as long as we have a legitimate need (for example to comply with legal, tax or accounting obligations, or to keep a Split correct for its other members). When we no longer have that need, we delete the data or make it anonymous, or, if that is not possible (for example in backup archives), we store it securely and isolate it from any further processing until deletion is possible.

7. Your data protection rights

7.1 You have the following rights over your Personal Data:

• Access and correction: you can see and update the Personal Data in your profile at any time from My Profile, and you can ask us for a copy of it through the Contact page.
• Deletion: you can delete your account at any time from My Profile. When you do, your Personal Data and your access are removed. The content of the Splits you took part in (expenses, contributions, balances) is not deleted, because a Split is a shared account sheet that must stay correct for the other members; your identifiers in those Splits are pseudonymised instead.
• Objection and restriction: in certain circumstances you can object to the processing of your Personal Data, or ask us to restrict it. You can exercise these rights by contacting us.
• Portability: you can ask us to provide the Personal Data you gave us in a structured, commonly used format, or to transmit it to another controller where technically possible. You can also export your transactions from the app.
• Withdrawal of consent: where we process your Personal Data on the basis of your consent (for example notifications), you can withdraw it at any time from the relevant settings. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, nor processing based on another legal basis.
• Complaint: if you have a complaint or concern about how we process your Personal Data, we will do our best to address it. If you believe we have not addressed it sufficiently, you have the right to lodge a complaint with a data protection authority.

8. Children

8.1 Evenly is not intended for children. You must be at least 16 years old, or the age of digital consent in your country if that is higher, to create an account. We do not knowingly collect Personal Data from children below that age. If you become aware that a child has provided us with Personal Data, please contact us so we can delete it.

9. Links to other websites

9.1 The Website and the Application may contain links or buttons leading to services operated by third parties, including our payment provider and, where you allow it, app stores. These services have their own privacy policies that we encourage you to review; they govern the use of the Personal Data you submit to them. We are not responsible for the privacy practices of third-party services.

10. Updating this Policy

10.1 We may update this Policy from time to time to reflect changes in the law, in our technology or in our services. When we do, we take appropriate steps to inform you given the significance of the changes, and we obtain your consent to material changes where the law requires it.

10.2 The date of the last update is shown at the top of this Policy.