FinleePrivacy policy
Last updated: 12 November 2026. Applies to the Finlee app and finlee.app.
Finlee is a budgeting app with an AI money coach. To help you, it needs to see your money: your bank transactions, your budgets and goals, and what you tell it in the chat. This policy explains, in plain words, what we collect, why, who helps us process it, how long we keep it and what you can do about it.
1. Who we are
The controller of your personal data is [COMPANY LEGAL NAME], a company registered in Portugal with NIPC [NIPC], at [REGISTERED ADDRESS] ("Finlee", "we", "us").
For anything about your data, write to privacy@finlee.app.
2. What we collect
- Your account. If you sign in with Google: your name, email address and Google account identifier. If you sign up with email: your email address and a password, which our authentication provider stores only as a hash.
- Bank data. When you choose to link a bank account, we receive through Enable Banking, read-only: account details (bank name, account name and type, IBAN, currency), balances, and transactions (date, amount, description, merchant or counterparty name and reference). Access uses open banking account information services under PSD2. You give consent at your bank, for up to 180 days at a time, and you can renew it. Finlee can never make payments or move money.
- What you create in the app. Budgets, categories, goals, debts and assets you track, alerts, your chat messages with the coach, and the short notes the coach keeps about you (for example "saving for a trip in May") so it remembers what matters to you.
- Receipt photos. If you scan a receipt, we store the photo and the items read from it.
- Household. If you invite a partner or join a household, which household you belong to and the shared budgets, goals and debts in it.
- Device push token. If you allow notifications, a token from your phone's push service so we can send you alerts.
- Diagnostics. Technical logs: time of requests, IP address, app version, error codes, and usage figures for the coach (number of model calls, which tools ran, cost). Logs do not contain your chat content. If you report an answer from the coach, we keep that report.
Transactions can sometimes hint at sensitive things, such as a pharmacy purchase or a donation. We use them only to run your budget and coach, never to profile you for anything else. We do not sell your data and we do not use it for advertising. The website has no analytics and sets no cookies.
3. Why we use it, and our legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating and running your account, budgets, goals, alerts, receipts, households and the AI coach | Performance of our contract with you (Art. 6(1)(b)) |
| Accessing your bank accounts through Enable Banking and importing balances and transactions | Your consent (Art. 6(1)(a)), given in the app and confirmed at your bank. You can withdraw it at any time by removing the bank in the app or ending the access at your bank |
| Sending push notifications | Your consent, given through your phone's notification permission |
| Keeping the service secure, preventing abuse, rate limits, diagnosing errors, and reviewing reported answers | Our legitimate interest in a safe, working service (Art. 6(1)(f)) |
| Keeping a minimal record that an account was deleted | Our legitimate interest in showing we honoured deletion requests (accountability, Art. 5(2)) |
| Responding to legal requests from authorities | Legal obligation (Art. 6(1)(c)), where it applies |
4. The AI coach and what it sees
The coach's answers are produced by an AI model from Anthropic. To answer you, the model needs some context: your message, recent chat, your budgets and goals, and the transactions relevant to your question (amounts, dates, categories, descriptions and merchant names).
Before anything is sent to the model, we pseudonymise it. Account identifiers are replaced with keyed pseudonyms that only Finlee can map back. IBANs, card numbers, other long account or reference numbers, email addresses, phone numbers, and your name and your household members' names are removed. The model sees "you" and "your partner", not names.
Some limits you should know about:
- Names of other people or businesses that appear in a transaction description (a landlord, a shop) can be sent, because they are part of the description.
- Receipt photos are sent to the model as images so it can read the items. They are not edited, so anything printed on the receipt (for example a tax number or loyalty card number) is visible to the model.
Anthropic acts as our processor. It does not use data sent through its API to train its models, and keeps it only for a limited period under its commercial terms [CONFIRM ANTHROPIC RETENTION PERIOD].
5. Who we share it with
We use these service providers (processors) to run Finlee. Each processes data only on our instructions, under a data processing agreement.
| Provider | What for | Where |
|---|---|---|
| Supabase, Inc. | Database, authentication, file storage (receipt photos) and server functions | EU: data hosted in Ireland (AWS eu-west-1) |
| Enable Banking Oy | Open banking connection to your bank. A licensed account information service provider supervised in Finland | Finland (EU) |
| Anthropic, PBC | AI model that produces the coach's answers and reads receipts. Receives only the pseudonymised data described in section 4 | United States |
| Sign-in with Google, and delivering push notifications on Android | EU and United States | |
| Vercel, Inc. | Hosting this website (finlee.app). Sees website visitors' requests, such as IP address and browser, not app data | Global network, United States company |
Your bank is also a recipient in the sense that it receives your consent request through Enable Banking. If you share a household, the other members see the household's shared budgets, goals and debts. We may disclose data if the law requires it, or to a successor if Finlee's business is transferred, in which case this policy continues to apply.
6. International transfers
Your account and financial data are stored in the EU. Some processing happens outside the European Economic Area: the AI model (Anthropic) runs in the United States, and some providers (Supabase, Google, Vercel) are US companies that may access data from outside the EU, for example for support. These transfers are covered by the European Commission's Standard Contractual Clauses and, where the provider is certified, the EU-US Data Privacy Framework, together with the safeguards above, such as pseudonymisation before data reaches the model. You can ask us for a copy of the relevant safeguards at privacy@finlee.app.
7. How long we keep it
- While your account exists, we keep your data so the app works. You can delete individual items in the app.
- Bank access lasts up to 180 days per consent. When it ends or you remove a bank, we stop fetching new data.
- When you delete your account, we remove your profile, chat, notes, budgets, goals, debts, assets, alerts, receipts and photos, linked bank accounts and transactions from our live database straight away, and ask your bank (through Enable Banking) to end Finlee's access. We keep only a minimal audit record: a one-way salted hash of an internal identifier and the date, with no name, email or financial data.
- Backups kept by our hosting provider roll off on their normal cycle, at most 30 days, and are not used to restore deleted accounts.
- Technical logs are kept for a short period and then deleted [CONFIRM LOG RETENTION].
How to delete your account: finlee.app/delete-account.
8. Your rights
Under the GDPR you have the right to:
- access your data and get a copy;
- rectification of data that is wrong;
- erasure ("right to be forgotten"), which you can do yourself in the app;
- portability: receive the data you gave us in a machine-readable format;
- object to processing based on our legitimate interest, and to restrict processing in some cases;
- withdraw consent at any time (for example, to bank access), without affecting what was done before.
Write to privacy@finlee.app. We answer within one month and may ask you to confirm it is you. You can also complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt, or to the authority where you live.
9. Automated suggestions
The coach suggests budgets, categories, savings plans and next steps automatically. These are suggestions for you to accept, change or ignore. Finlee does not make decisions that have legal or similarly significant effects on you, such as credit decisions, and it never acts on your bank accounts.
10. Children
Finlee is not for anyone under 18. We do not knowingly collect data from children. If you think a child has given us data, tell us and we will delete it.
11. Security
Data is encrypted in transit (HTTPS) and at rest by our hosting provider. Access to your data is restricted to your own account by database rules. Bank access is read-only. Sensitive actions, such as deleting your account, ask you to sign in again. Only a small number of authorised people can access production systems, and only when needed to run or fix the service. No system is perfectly secure; if a breach affects you, we will tell you and the CNPD as the law requires.
12. Changes and contact
We will update this policy as Finlee changes. If a change is significant, we will tell you in the app before it applies. The date at the top shows the latest version.
Contact: [COMPANY LEGAL NAME], [REGISTERED ADDRESS], privacy@finlee.app.