Privacy Policy

1. Controller

2. Overview

This Privacy Policy informs you about the processing of your personal data when using the SplitHappens app ("App"). SplitHappens is an expense-sharing app for groups with AI-powered receipt recognition and real-time collaboration.

3. Data We Collect

3.1 Registration and Profile Data

• Email address (upon registration)
• Name/display name (freely chosen)
• Profile picture (optional, uploaded by the user)
• User ID (automatically generated)

Note: Uploaded profile and cover images are stored in a publicly accessible location and can be retrieved via their URL. Please do not upload images containing confidential information.

3.2 Third-Party Authentication Data

• Google Sign-In: Name, email address, profile picture (if you sign in via Google)
• Apple Sign-In: Name, email address or anonymous email (if you sign in via Apple)

3.3 Financial and Transaction Data

• Expenses and receipts (amounts, descriptions, categories)
• Group memberships and friend connections
• Balances and debts between users
• Payment history and settlement calculations
• Payment details (optional): bank details you add (IBAN, BIC, bank name, account holder) and PayPal address, stored encrypted (see 5.4)

3.4 Multimedia Data

• Receipt photos (for AI-based text recognition and data extraction)
• Scan feedback (optional): If you actively send us feedback on a receipt scan, we store the relevant receipt photo, the recognized data, and your optional comment to improve recognition quality.

3.5 Device and Usage Data

• Device information (operating system, app version)
• Push token (device identifier used to deliver push notifications)
• Network connection data (for real-time synchronization)
• Crash reports (error message and code location, device model, operating system, app version, time; can be turned off in the app, see 6.6)
• Usage statistics (individual steps in the app without user ID, device identifier or IP address; can be turned off in the app, see 5.5)

4. Legal Basis for Processing

Your data is processed on the basis of the EU General Data Protection Regulation (GDPR):

• Art. 6(1)(a) GDPR: Consent (e.g., for optional profile picture)
• Art. 6(1)(b) GDPR: Performance of a contract (providing app functionality)
• Art. 6(1)(f) GDPR: Legitimate interests (security, error analysis, improving the app)

5. Purposes of Data Processing

5.1 Providing App Features

• User registration and authentication
• Expense tracking and management
• Group management and friend connections
• Real-time synchronization across devices
• Balance calculation and settlement suggestions

5.2 AI-Based Services

• Receipt recognition: Automatic text recognition from receipt photos using Azure Document Intelligence (Microsoft, EU servers)

5.3 App Improvement and Support

• Error analysis and resolution
• Performance optimization
• Development of new features
• Customer support for issues

5.4 Your Payment Details for Other Users

So that people who owe you money can pay you directly, the app shows them your saved payment details when they pay. They are visible only to users with whom you yourself have established a connection:

• a confirmed friendship,
• a bill you created on which the person is listed as payer or participant,
• an active group you created or in which you created bills, provided the person is an active member there.

Someone who merely adds you to their own bill or their own group does not gain access to your payment details. Archived groups do not release payment details. Guest links do not show payment details.

Legal basis: Art. 6(1)(b) GDPR (handling the settle-up you use the app for). Adding payment details is voluntary; you can change or delete them at any time under Profile → Payment methods.

5.5 Usage Statistics

To understand where the app is hard to use, we analyse how it is used. We keep this as lean as possible:

• Steps without a user identifier: The app reports individual steps to our server, for example “new expense opened”, “saved”, “left without saving”, “receipt recognised” or “settle-up recorded”. We store only the type of step, the chosen path, the number of people, a rough duration (under 30 seconds, under 2 minutes, longer), the approximate account age (first day, first week, older), platform and app version. We do not store your user ID, a device identifier or your IP address with it, and the time is rounded to the full hour. We do not combine this information with your account and delete it after 24 months at the latest.
• Analysis of existing data: From data that the app already holds (registration date, bills created, sign-in times, receipt scans) we compile statistics such as “share of new users who create an expense in their first week”. This produces only totals and percentages; we do not report groups of fewer than five people. No additional data is collected for this and no profiles of individual people are created.

Processing takes place exclusively on our own server in Germany (see 6.1). Legal basis: Art. 6(1)(f) GDPR (legitimate interest in an understandable, working app). You can stop sending these steps at any time in the app under Profile → Settings → Privacy → "Send usage statistics". Your right to object under Art. 21 GDPR remains unaffected (see 8).

6. Data Sharing with Third Parties

6.1 Supabase (Backend Service) — Self-Hosted

6.2 Azure Document Intelligence (Receipt Recognition)

6.3 Google Services (for Google Sign-In)

Provider: Google LLC, USA
Data: Name, email address, profile picture
Purpose: Authentication
Privacy: Google Privacy Policy

6.4 Apple Services (for Apple Sign-In)

Provider: Apple Inc., USA
Data: Name, email address (or anonymous email)
Purpose: Authentication
Privacy: Apple Privacy Policy

6.5 Firebase Cloud Messaging (Push Notifications)

6.6 Firebase Crashlytics (Crash Reports)

6.7 No Sharing with Other Third Parties

Your data is not shared with advertisers, data brokers, or other commercial third parties.

7. Data Storage and Deletion

7.1 Retention Period

• Profile data: As long as your account is active
• Expenses and receipts: As long as the corresponding groups exist
• Receipt photos: After successful text recognition (max. 30 days)
• Scan feedback (photo + recognized data): As long as needed for quality improvement; deleted earlier upon request

7.2 Account Deletion

8. Your Rights

Under the GDPR, you have the following rights:

Contact for privacy inquiries: info@splithappens.io

9. Data Security

We implement technical and organizational measures to protect your data:

• Encryption: All data is transmitted encrypted (TLS/SSL)
• Payment details: Bank details and PayPal address are additionally stored encrypted in the database
• Access control: Restricted access to personal data
• Secure servers: Self-hosted infrastructure on Hetzner Cloud (Germany)
• Regular updates: Security patches and system updates

10. International Data Transfers

Your app data is stored on our self-hosted servers in Germany (Hetzner Cloud) and does not leave the EU. Data transfers only occur when using third-party authentication:

• Google Sign-In / Apple Sign-In: Authentication data is transmitted to Google LLC or Apple Inc. (USA)
• Firebase Cloud Messaging: Device push tokens are transmitted to Google LLC (USA)
• Legal basis: EU-US Data Privacy Framework / EU Commission adequacy decision for the USA, Standard Contractual Clauses
• Additional safeguards: Encryption, access restrictions

11. Children's Privacy

12. Cookies, Tracking and Server Log Files

The SplitHappens app uses no cookies and no advertising tracking. We do not pass on data for advertising purposes and do not create cross-device user profiles. All data is processed exclusively for the app and its improvement; we do not use third-party analytics services (usage statistics see 5.5). Crash reports (section 6.6) serve only to fix errors and contain none of your bill contents. Both can be turned off in the app under Profile → Settings → Privacy.

12.1 Server Log Files

When you visit our website, the web server automatically records access data: date and time, the address requested, HTTP status code, amount of data transferred, referrer, browser and device identifier (user agent) and IP address. This data serves secure operation and error analysis, is not combined with other data sources, and is deleted automatically after 31 days.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure and uninterrupted operation).

12.2 Counting Our Short Links and QR Codes

The short addresses /app, /android, /ios and /instagram — for example from printed QR codes on business cards or flyers — redirect directly to their respective destination. To learn how often these redirects are used, we store only: timestamp, the address requested, status code, referrer, user agent and the device class derived from it (iOS, Android or desktop).

The user agent is deleted after 180 days; the derived device class is retained. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in measuring the reach of our own promotional material).

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. In the event of material changes, you will be notified via the app. The current version is always available at this URL.

14. Contact and Complaints

15. Additional Privacy Information for United States Residents

This section applies to residents of the United States and serves as our “Notice at Collection” under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA). We also honor the comparable rights granted by other U.S. state privacy laws (e.g., Virginia VCDPA, Colorado CPA, Connecticut CTDPA, Utah UCPA, Texas TDPSA). We extend these rights to all U.S. users as a matter of good practice, regardless of whether a given law's business-size or volume thresholds apply to us.

15.1 Notice at Collection — Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information (using CCPA/CPRA terminology):

• Identifiers: name, email address, optional phone number, account/user ID, and device push token
• Customer records & financial information: payment method details you choose to add (e.g., IBAN or PayPal handle), stored encrypted; balances and shares you track
• Commercial information: bills, items, settlements, and event participation you create in the app
• Visual information: receipt photos you upload for automated recognition
• Internet or other electronic network activity: only the limited technical data necessary to operate the app — we use no analytics, advertising, or tracking cookies

We do not collect precise geolocation, biometric information, or background, education, or employment information, and we do not use your data to derive sensitive inferences about you.

15.2 Purposes of Collection

• Providing and operating the app's core features (expense sharing, settlement tracking)
• Automated receipt recognition (OCR)
• Sending push notifications you have enabled
• Security, fraud prevention, and debugging
• Customer support and communication
• Compliance with legal obligations

15.3 Sources of Personal Information

• Directly from you (registration, profile, bills, receipts)
• Automatically from your device (e.g., push token)
• From Google or Apple when you choose to sign in with those services

15.4 Disclosure for Business Purposes

We disclose certain categories of personal information to service providers who process it on our behalf under contract and may not use it for their own purposes (see Section 6): self-hosted backend infrastructure, Azure Document Intelligence (receipt recognition), Google and Apple (authentication), and Firebase Cloud Messaging (push notifications).

15.5 No Sale or Sharing of Personal Information

15.6 Your U.S. State Privacy Rights

Depending on your state of residence, you may have the following rights:

15.7 How to Exercise Your Rights

To exercise any of these rights, email info@splithappens.io. Many rights can also be exercised directly in the app: you can access a complete, machine-readable copy of your data via Profile → Export, and you can delete your account via Profile → Delete Account. We will verify your identity before responding and reply within 45 days (extendable by an additional 45 days where permitted). You may designate an authorized agent to submit a request on your behalf. We do not charge a fee to process or respond to a verifiable request unless it is excessive or repetitive.

15.8 Retention

We retain personal information only for as long as necessary for the purposes described above (see Section 7). Following account deletion, your data is deleted within 30 days.

See also our Terms of Service and Legal Notice.

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