Privacy Policy

App: Saldo  ·  Last updated: August 1, 2026

This Privacy Policy describes how Fulvio Gilardoni ("we", "us", "our") collects, uses, stores, and protects personal data when you use the Saldo mobile application ("App"), available on iOS and Android. By creating an account and using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

2. Data We Collect

We collect only the data strictly necessary to provide the service:

• Account data: email address, display name, and profile photo (if provided via Google or Apple Sign-In).
• Expense and financial data: amounts, categories, dates, notes, and split information you enter manually. This data is never used for advertising or sold to third parties.
• Group data: group names, membership, roles, and settlement records.
• Recurring expense templates: titles, amounts, frequencies, and reminders you configure.
• Subscription data: your plan (Free or Plus), purchase status, platform (iOS/Android), and subscription expiry date. We never store raw payment card details — all payments are processed entirely by Apple or Google.
• Device and session data: Firebase Cloud Messaging (FCM) token for push notifications; OS type (iOS/Android) for in-app purchase receipt verification.
• Crash reports: anonymised diagnostic logs collected by Firebase Crashlytics (production builds only), which may include device model, OS version, and the app state at the time of the crash.
• Analytics events: anonymised, aggregated behavioural events (e.g. screen views, feature interactions) collected by Firebase Analytics to improve the product. No event is linked to your identity.

3. Legal Basis for Processing (GDPR)

We process your personal data on the following legal bases under Regulation (EU) 2016/679 (GDPR):

• Performance of a contract (Art. 6(1)(b)): account management, expense synchronisation, settlement tracking, and subscription verification are necessary to deliver the service you signed up for.
• Legitimate interests (Art. 6(1)(f)): crash reporting and anonymised analytics allow us to maintain stability and improve the App. These interests do not override your rights.
• Compliance with legal obligations (Art. 6(1)(c)): retention of certain records as required by applicable Italian tax and accounting laws.

4. How We Use Your Data

• To create and manage your account and authenticate your identity.
• To synchronise your expense and group data in real time across your devices and with other group members.
• To send push notifications about new expenses, settlement confirmations, and recurring reminders — only with your permission (you can opt out at any time in device settings or in-app settings).
• To verify in-app purchases and grant or revoke access to Saldo Plus features.
• To diagnose crashes, fix bugs, and improve App stability.
• To understand how features are used at an aggregated level so we can improve the product.

5. Data Storage and Security

Your data is stored in Google Firebase Firestore, hosted in the EU (europe-west1 region). Data is encrypted in transit (TLS 1.2+) and at rest using AES-256 encryption managed by Google. We apply Firestore Security Rules to ensure each user can only read and write data belonging to groups they are a member of.

6. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data. Data is shared only with the following sub-processors, solely to the extent necessary to provide the service:

• Google LLC (Firebase): database (Firestore), authentication (Firebase Auth), push notifications (FCM), crash reporting (Crashlytics), and anonymised analytics (Firebase Analytics). Google LLC is certified under the EU–US Data Privacy Framework. Firebase Privacy Policy.
• Apple Inc. / Google LLC: in-app purchase receipt verification. These companies process payment data under their own privacy policies.
• Group members: your display name and profile photo are visible to other members of groups you create or join. Expense amounts and notes entered in a group are visible to all group members.

No other third parties receive your personal data.

7. Data Retention

We retain your personal data for as long as your account is active. When you delete your account through the App (Settings → Delete Account), all your personal data — including profile information, expenses, groups, recurring templates, settlements, and subscription records — is permanently deleted within 30 days. Anonymised, aggregated analytics data may be retained indefinitely as it cannot be linked to you.

Certain fiscal and accounting records may be retained for the minimum period required by Italian law (currently 10 years under Art. 2220 c.c.), but only to the minimum extent legally required.

8. Your Rights (GDPR)

As a data subject under EU/EEA law, you have the following rights:

• Right of access (Art. 15): request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): ask us to correct inaccurate or incomplete data.
• Right to erasure (Art. 17): request deletion of your data. You can exercise this directly from the App via Settings → Delete Account.
• Right to restriction of processing (Art. 18): ask us to restrict processing in certain circumstances.
• Right to data portability (Art. 20): receive your data in a structured, machine-readable format (CSV export available in-app).
• Right to object (Art. 21): object to processing based on legitimate interests.
• Right to lodge a complaint: you have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

To exercise any of these rights, contact us at fulvio.gilardoni@gmail.com. We will respond within 30 days.

9. Age Restriction

Saldo is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete it promptly.

10. International Transfers

Your data is processed within the EU (Firebase europe-west1 region). Google LLC may transfer certain operational data to the United States under the EU–US Data Privacy Framework, which provides an adequate level of protection as recognised by the European Commission.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by email before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the App after the effective date constitutes acceptance of the updated policy.

12. Contact

For any questions, requests, or concerns regarding this Privacy Policy:

Fulvio Gilardoni
Via Leonardo da Vinci, 3 — 23865 Oliveto Lario (LC), Italy
fulvio.gilardoni@gmail.com