Privacy Policy

Effective Date: August 8, 2026

This Privacy Policy explains how the iOS application iSpendo (the “App”), developed by Elizaveta Peshchanskaya (“we”, “us”, or “our”), handles information about you.

The App is a journal of personal spending. The entries you write down are stored on your device and, if you enable it, synchronised through your own iCloud account. In addition, the App uses a small number of third-party services to process subscriptions and to understand how the App is used. This policy describes exactly what those services receive.

1. Summary

• We do not ask you for your name, email address, phone number, or postal address.
• Your expenses, categories, budgets, and notes stay on your device and in your private iCloud database. We cannot read them.
• We use RevenueCat to manage subscriptions and Amplitude to measure product usage. Both receive pseudonymous identifiers and technical data, not your expense records.
• We do not show advertising, do not use the advertising identifier (IDFA), and do not track you across apps or websites owned by other companies.
• We do not sell or share your personal information.

2. Data You Enter Into the App

Expense amounts, categories, dates, budgets, notes, currency selection, and app preferences are created by you and stored locally on your device.

We do not receive this content, and it is never transmitted to our servers. We do not operate servers that store user content.

3. iCloud Synchronisation

The App can synchronise your data across your Apple devices using iCloud (Apple’s CloudKit private database). This feature depends on your device and iCloud settings.

When synchronisation is active:

• your data is stored in the private database of your own iCloud account, under your Apple Account;
• the data is transmitted and stored by Apple, acting as our service provider and as the provider of your iCloud account;
• we have no access to it — we cannot read, export, or restore your iCloud data, and we receive no copy of it;
• Apple’s handling of iCloud data is governed by the Apple Privacy Policy and your iCloud terms.

You can disable synchronisation for the App at any time in the iOS Settings app, under your Apple Account → iCloud. Disabling iCloud does not delete data already stored on your device.

4. Subscriptions and Purchase Data (RevenueCat)

The App offers paid subscriptions. Payments are processed exclusively by Apple through the App Store. We never see your card number, bank details, or full billing information.

To manage subscription entitlements and to see how the subscription business is performing, we use RevenueCat, Inc. as a processor. RevenueCat may receive and store:

• a pseudonymous App User ID generated by the App (not your name or email);
• App Store transaction and receipt data — purchases, trial starts, renewals, cancellations, billing issues, refunds;
• subscription status, product identifiers, price, and currency;
• country or region of your App Store account;
• technical information such as device model, operating system version, app version, and IP address (used to derive approximate country and to protect against fraud).

RevenueCat does not receive your expense records. Its processing is described in the RevenueCat Privacy Policy.

Purchase events may also be forwarded from RevenueCat to Amplitude (see the next section) so that revenue and usage can be analysed together.

5. Product Analytics (Amplitude)

We use Amplitude, Inc. as a processor to understand how the App is used — for example, how many people complete onboarding, how often the App is opened, and which features are used. This helps us fix problems and decide what to improve.

Amplitude may receive:

• a pseudonymous identifier for your installation of the App;
• in-app events, such as opening a screen, completing onboarding, or creating an entry — recorded as event names and counts;
• session information: timestamps, session length, frequency of use;
• technical information: device model, operating system version, app version, language, and country or region (derived from IP address);
• subscription events forwarded from RevenueCat.

Amplitude does not receive the content of your expenses — no amounts you entered, category names you created, notes, or budgets are sent as event content.

Amplitude’s processing is described in the Amplitude Privacy Policy. Where consent is required in your jurisdiction, analytics are collected only after you have given it, and you may withdraw it at any time (see “Your Choices”).

6. Information From Apple

Apple provides us with aggregated and anonymised reports through App Store Connect and App Analytics — for example, numbers of impressions, downloads, sales, crashes, and the performance of marketing campaign links and custom product pages.

These reports do not identify individual users, and we cannot link them to a person. Apple’s own collection is governed by the Apple Privacy Policy.

If you have enabled “Share With App Developers” in iOS diagnostics settings, Apple may also provide us with crash and energy reports. This is controlled by you in the iOS Settings app, under Privacy & Security → Analytics & Improvements.

7. Advertising and Cross-App Tracking

The App contains no advertising and no advertising SDKs.

We do not use the Identifier for Advertisers (IDFA), do not request permission under Apple’s App Tracking Transparency framework, and do not track you across apps or websites owned by other companies.

We do not build advertising profiles and do not engage in targeted advertising.

8. Why We Process Data and Our Legal Bases

For users in the European Economic Area, the United Kingdom, and Switzerland, we rely on the following legal bases under the GDPR and UK GDPR:

• Performance of a contract (Art. 6(1)(b)) — providing the App, verifying and restoring your subscription entitlement, and providing support.
• Consent (Art. 6(1)(a)) — product analytics, where consent is required in your jurisdiction. You may withdraw consent at any time; withdrawal does not affect processing carried out before withdrawal.
• Legitimate interests (Art. 6(1)(f)) — keeping the App secure, preventing fraudulent or abusive use of purchases and trials, and understanding aggregate product performance where consent is not required.
• Legal obligation (Art. 6(1)(c)) — meeting tax, accounting, and consumer-law requirements relating to purchases.

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects.

9. Sharing and Recipients

We do not sell your personal information, and we do not share it for cross-context behavioural advertising or targeted advertising.

We disclose data only to the service providers (processors) listed below, and only for the purposes described:

• Apple Inc. — App Store distribution, payment processing, iCloud storage, aggregated analytics. Privacy Policy
• RevenueCat, Inc. — subscription management and revenue reporting. Privacy Policy
• Amplitude, Inc. — product analytics. Privacy Policy

We may also disclose information if required by law, court order, or a lawful request from a public authority, or where necessary to establish, exercise, or defend legal claims.

If the App or our business is transferred to another owner, information may be transferred as part of that transaction; the recipient will remain bound by this policy or a policy that is no less protective.

10. International Transfers

Our service providers are established in the United States and may process data there and in other countries where they or their sub-processors operate.

Where data is transferred out of the European Economic Area, the United Kingdom, or Switzerland, the transfer is protected by appropriate safeguards — in particular the European Commission’s Standard Contractual Clauses (with the UK Addendum where applicable) or another lawful transfer mechanism relied on by the relevant provider.

11. Retention

• Data on your device — kept until you delete the entries or delete the App.
• iCloud data — kept in your own iCloud account until you delete it or disable synchronisation and remove the data, subject to Apple’s backup behaviour.
• Subscription records (RevenueCat) — retained for the life of the subscription relationship and afterwards for as long as needed for entitlement restoration, dispute handling, and tax and accounting obligations.
• Analytics events (Amplitude) — retained in pseudonymous form for a limited period for trend analysis, and deleted or aggregated afterwards.

12. Your Rights

Depending on where you live, you may have the right to: access the personal data we hold about you; have it corrected; have it erased; restrict or object to its processing; receive it in a portable format; withdraw consent; and not be discriminated against for exercising these rights.

If you are in California, you may also request disclosure of the categories of personal information collected, disclosed, and (if applicable) sold or shared. We do not sell or share personal information as those terms are defined by the CCPA/CPRA, including with respect to consumers under 16.

To exercise any of these rights, email support@utilsapps.com. Because we identify users only by pseudonymous identifiers, we may need additional information from you — such as the App User ID shown in the App’s settings or your App Store purchase receipt — to locate the relevant records. We will respond within the period required by applicable law.

If you are in the EEA, the UK, or Switzerland, you also have the right to lodge a complaint with your local data protection supervisory authority.

13. Your Choices

• Analytics — you can opt out of product analytics in the App’s settings, where this option is offered, or by contacting us.
• iCloud synchronisation — enable or disable it in the iOS Settings app under your Apple Account → iCloud.
• Subscription — manage or cancel it in the App Store account settings on your device.
• Deleting everything — delete the App from your device and remove its iCloud data in your Apple Account settings.

14. Children’s Privacy

The App is not directed to children under 13 (or the higher minimum age that applies in your country, such as 16 in parts of the EEA), and we do not knowingly collect personal information from them.

If you believe a child has provided us with personal information, contact support@utilsapps.com and we will delete it.

15. Security

Data on your device is protected by iOS platform security, including your device passcode and biometric authentication. Data synchronised to iCloud is protected by Apple’s security measures for your Apple Account.

Data transmitted to our service providers is sent over encrypted connections (TLS). Our providers maintain their own technical and organisational security measures.

No method of transmission or storage is completely secure. You are responsible for keeping your device and Apple Account secure, including your passcode, biometrics, and two-factor authentication.

16. Changes to This Privacy Policy

We may update this Privacy Policy if the App’s functionality, our service providers, or legal requirements change.

The updated version will be posted here with a new effective date. Where changes are material, we will provide notice in the App or through the App Store listing. Continued use of the App after the changes take effect means you accept the updated policy.

17. Contact Us

Elizaveta Peshchanskaya is the data controller for the processing described in this policy. If you have questions or wish to exercise your rights, contact us at: