Privacy Policy

This Privacy Policy ("Policy") describes how Oleh Herasymenko ("we", "us", or "our") collects, uses, and protects your personal information when you use the mobile application Quro (the "App").

This Policy complies with the General Data Protection Regulation (GDPR) (EU) and other applicable data protection laws.

Data Controller:
Oleh Herasymenko
Friedrichshafen, Germany
Email: thevaltorna@gmail.com

This Policy is publicly accessible within the App and on our support website. We may update this Policy from time to time.

1. Definitions

• Personal Data — any information relating to an identified or identifiable natural person.
• Processing — any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• Data Controller — Oleh Herasymenko, the entity that determines the purposes and means of processing personal data.
• User — any natural person who uses the App.
• App — the mobile application Quro, available on the App Store.
• AI Agent — the automated assistant within the App that analyzes financial data and generates responses using Google Vertex AI (Gemini models).
• Financial Transaction — a record of income or expense manually entered or imported by the User.
• Bank Statement Import — a feature allowing Users to photograph, scan, or upload bank statements or receipts for AI-assisted parsing.
• Family Space — a shared account feature allowing multiple users to manage finances together.

2. Principles of Data Processing

We process personal data in accordance with the following principles:

• Lawfulness, fairness, and transparency
• Purpose limitation
• Data minimization
• Accuracy
• Storage limitation
• Integrity and confidentiality
• Accountability

3. Information We Collect

Information You Provide

• Anonymous account data: when you tap Get Started on the Welcome screen, before signing in, we create a temporary anonymous Firebase user identifier. Your onboarding answers (income range, spending categories, savings goals), AI-generated categories and budget suggestions, and any data you enter during onboarding are stored in Cloud Firestore under this anonymous identifier. If you do not complete sign-in within a reasonable period, the anonymous account and any associated data may be removed.
• Permanent account data: collected when you complete account creation via Sign in with Apple or Google Sign-In at the end of onboarding. We collect: display name (from your Apple or Google profile, optional), profile photo URL (from your Apple or Google profile, optional), and email address (stored in Firebase Authentication and replicated to your user profile in Cloud Firestore for in-app display and account-related communication). At sign-in, the anonymous account is linked to your permanent account and all anonymous-period data is migrated to your linked identity.
• Financial data: transaction amounts, currencies, categories, comments, dates, and tags entered manually or imported by you
• Budget and goal data: budget limits, savings goals, and scheduled recurring transactions
• Receipt and bank statement content: image and document data from files you choose to scan or import (see Section 6a)
• AI chat messages: your messages to the AI assistant and the assistant's responses, including tool call data (transaction lookups, balance queries)
• Currency preference: your selected primary currency, collected during onboarding

Automatically Collected Information

• Device information: device model, operating system version, app version
• Device tokens: push notification tokens (FCM) stored for delivering notifications
• Crash data: technical crash reports including device info and stack traces, collected via Firebase Crashlytics. A hashed user identifier is associated with crash reports to help diagnose issues; this identifier is cleared upon logout.
• Usage analytics: app events collected via Firebase Analytics, including: login method, logout, account deletion, onboarding completion, paywall views

Purchase Information

• Subscription tier, status, renewal date, and transaction history managed via RevenueCat and Apple In-App Purchase

Data Collected Through Device Permissions

• Camera: used via document scanner (VNDocumentCameraViewController) to capture receipts and bank statements directly. Requires camera permission grant via the standard iOS permission prompt.
• Photos (via system PhotosPicker): used to select existing photos of receipts or bank statements from your photo library. Uses the system picker which does not require explicit Photos permission.
• Files: used via system file picker (fileImporter) to select PDF, CSV, Excel (XLSX), JPEG, and PNG files for bank statement import. No special permission required beyond standard file access.
• Biometric authentication (Face ID / Touch ID): used for app unlock and re-authentication. Biometric data is processed entirely by iOS and is never transmitted to our servers or accessed by the App.
• Push Notifications: used to deliver reminders and budget alerts. Requested via the standard iOS permission prompt when you first enable reminders in the App.

We do not collect location data, advertising identifiers (IDFA), or any tracking data.

We do not collect special categories of personal data (health data, biometric data for identification, political opinions, etc.).

Our Service is not intended for children under 13 (or 16 in the EU), and we do not knowingly collect their data. If we learn that we have collected personal data from a child without verifiable parental consent, we will take steps to delete that information promptly.

4. How We Use Your Information

We use your personal data for the following purposes:

• To provide and maintain the App and its features
• To operate the AI assistant and generate financial insights based on your data
• To process and manage your subscription via RevenueCat
• To send push notifications (reminders, budget alerts) if you have enabled them
• To analyze App usage in anonymized form to improve functionality (Firebase Analytics)
• To diagnose and fix technical issues (Firebase Crashlytics)
• To comply with legal obligations
• To respond to your support inquiries

5. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

• Performance of a contract — providing access to the App and its features
• Your consent (Art. 6(1)(a) GDPR) — when you enable camera access, AI features, push notifications, or accept marketing cookies (Meta Pixel) on our website (see Section 6c)
• Legitimate interests — improving the App through anonymized analytics, diagnosing crashes, ensuring security
• Legal obligations — compliance with applicable laws

You may withdraw your consent at any time by contacting us at thevaltorna@gmail.com or by adjusting your in-App settings or iOS Settings. Withdrawing consent for AI features disables those features while all other App functionality remains available.

6. Third-Party Services

We share data with the following third-party service providers solely to operate the App:

All Google services operate under Google's Privacy Policy and Google Cloud Data Processing Addendum (DPA).

All Firebase and Vertex AI services process data within the European Union (europe-west1, Belgium / eur3 Europe multi-region), ensuring GDPR compliance.

We do not sell your personal data to third parties.

6a. Third-Party AI Services (Google Vertex AI)

To provide AI-powered features (financial chat assistant, receipt scanning, bank statement import), we send certain data to Google Vertex AI.

AI features are powered by Google Vertex AI (Gemini models). All AI processing occurs within the European Union (europe-west1 region). Google does not use your data to train or improve its models. Data is processed in accordance with Google Cloud's Data Processing Addendum and is not retained by Google after processing.

Consent: You consent to AI processing of your financial data when you tap Get Started on the Welcome screen. The legal notice immediately below the Get Started button references this Privacy Policy, which sets out exactly which data is sent to Google Vertex AI and for what purpose. This consent covers all AI features used during onboarding (initial category and budget personalisation) and all post-onboarding AI features (chat assistant, receipt scanning, bank statement import).

You may withdraw your consent at any time in Settings → AI Features. Withdrawing consent disables all AI features while all other App functionality remains available. If you withdraw consent and later attempt to use an AI feature, the App displays a re-consent prompt explaining what data will be processed before that feature is re-enabled.

Data we send to Google Vertex AI

For receipt and bank statement scanning:

• The captured image or uploaded document (PDF, CSV, Excel, JPEG, PNG) as base64 data
• OCR text pre-extracted on your device as a processing hint
• Your category names and types (to improve categorization accuracy)
• Language hint

For AI chat assistant (via tool calls based on your queries):

• Your chat messages and conversation history (up to ~32,000 characters of recent context)
• Financial data relevant to your query only: transaction descriptions, amounts, dates, categories, account names, budget limits, scheduled payments, currency rates
• Session context: currency preference, timezone, locale

Data we do NOT send to Google Vertex AI

• Your name or email address
• Firebase User ID or Account ID
• Device identifiers
• Your full transaction history — only data directly relevant to your query is retrieved and sent

Privacy masking: In Family Space, other members' individual data is masked before being sent to AI.

AI features are optional. The free tier provides full access to manual transaction entry, budgets, accounts, scheduled payments, and Family Space without using AI. AI features (chat assistant, receipt scanning, bank statement import) require an active Quro Pro subscription. AI access is licensed per individual user — Pro is not extended to other Family Space members through the owner's subscription.

6c. Website Cookies & Meta Pixel (getquro.app)

This section applies to our website at getquro.app. It does not describe data processed inside the iOS App.

Strictly necessary

The website uses one strictly necessary storage entry (quro_consent in localStorage) to remember your choice on the cookie banner. No tracking occurs from this entry. It is set under our legitimate interest in honoring your consent decision (Art. 6(1)(f) GDPR) and does not require consent under § 25(2) TTDSG.

Marketing cookies — Meta Pixel

Only if you click "Принять" / Accept on the cookie banner, we load the Meta Pixel (provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland). The Pixel is a JavaScript snippet from connect.facebook.net that fires a PageView event and sets Meta cookies (typically _fbp, fr) in your browser.

Purpose: measure the effectiveness of our Facebook / Instagram advertising, build conversion statistics, and (in aggregated form) optimize ad delivery to similar audiences. We do not use the Pixel for cross-site behavioral profiling beyond Meta's advertising ecosystem.

Data processed: IP address (truncated by Meta), user agent / browser and device information, referring URL, the fact that you visited getquro.app, page-view event, and Meta cookie identifiers. Meta may link this to your Facebook / Instagram account if you are logged into one.

Legal basis: your prior, freely given, specific, informed and unambiguous consent under Art. 6(1)(a) GDPR and § 25(1) TTDSG (Germany). Until you accept, no Pixel script is loaded and no Meta cookies are set.

Joint controllership: for the collection and transmission of Pixel data to Meta we act as joint controllers with Meta within the meaning of Art. 26 GDPR, under the Controller Addendum. Meta's subsequent processing is governed by Meta's own Privacy Policy.

International transfers: Meta may transfer data to the United States. Transfers are based on the EU-US Data Privacy Framework (Meta Platforms, Inc. is certified) and, where applicable, the EU Standard Contractual Clauses.

Retention: Meta cookies expire up to 90 days after they are set or refreshed. Server-side data is retained by Meta per its own retention schedule.

Withdrawing consent / opt-out

You can withdraw your consent at any time, with effect for the future:

• Click the "Cookies" link in the website footer to re-open the cookie banner and choose "Отказаться" / Decline.
• Clear localStorage for getquro.app and the _fbp / fr cookies via your browser settings.
• Adjust your ad preferences directly with Meta: facebook.com/adpreferences.

If you decline or have not yet accepted, the Pixel script is never loaded and no marketing cookies are set. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

6b. Financial Disclaimer

Quro is a personal finance tracking tool for informational purposes only.

The App and its AI assistant do not provide financial advice, investment recommendations, tax advice, or any regulated financial services. All AI-generated analysis, categorizations, and suggestions are produced automatically based solely on data you provide and are intended for informational purposes only.

You should not make financial decisions based solely on AI-generated content. Always consult a qualified financial professional for financial, investment, or tax advice.

We are not a financial institution, bank, licensed financial advisor, or regulated financial service provider.

7. Data Storage and Retention

All user data is stored in Google Cloud Firestore within the European Union (eur3 multi-region Europe / europe-west1, Belgium).

Categories of data stored on our servers

• User profile (display name, profile photo URL, currency and language preferences)
• Financial transactions, accounts (bills), budgets, categories, and scheduled plans
• AI chat history (messages, tool call results, and generated artifacts)
• Receipt scan results (extracted text and structured transaction data)
• Push notification tokens
• Subscription status and AI usage records (token count, duration — no personal content)

Receipt and bank statement images and documents are not stored on our servers. They are processed in memory during Cloud Function execution and immediately discarded. Only the structured result (parsed transactions) is saved to Firestore.

Retention period: Your data is retained for as long as your account is active. Upon account deletion, all personal data is permanently and irreversibly deleted immediately — there is no grace period or recovery option (see Section 11).

Anonymized data: Anonymized crash reports and aggregated analytics data collected by third-party services (Firebase Crashlytics, Firebase Analytics) may be retained after account deletion, as they cannot be linked back to you personally.

Third-party retention: Crash reports are retained for 90 days. Analytics data is retained according to Firebase Analytics default retention settings.

8. Your Rights

All users of the App have the following rights regarding their personal data:

• Right to access — request a copy of your personal data by contacting us at thevaltorna@gmail.com
• Right to rectification — correct inaccurate data directly in the App or by contacting us
• Right to erasure — delete your account and all associated data directly in the App (Settings → Account → Delete account)
• Right to data portability — request an export of your personal data by contacting us at thevaltorna@gmail.com

Additional rights for users in the European Union (GDPR)

• Right to restrict processing — limit how we use your data
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — withdraw consent for AI features or notifications at any time in App Settings or iOS Settings
• Right to lodge a complaint — you have the right to lodge a complaint with the data protection authority in your country of residence.

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

9. Security

We implement appropriate technical and organizational measures to protect your personal data:

• All data transmitted between the App and our servers is encrypted using HTTPS/TLS
• Firebase Security Rules restrict data access on a per-user and per-account basis
• Server-side logic is executed via authenticated Cloud Functions using verified Firebase ID tokens
• Access to production systems is restricted to authorized personnel only
• AI processing occurs within Google Cloud's secure infrastructure under DPA

10. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users without undue delay and, where required, within 72 hours of becoming aware of the breach. Notification will be provided via the email address associated with your account or via a prominent notice within the App.

11. Account Deletion

You may delete your account at any time from Settings → Account → Delete account. Deletion requires re-authentication for security.

Upon account deletion, the following is permanently and irreversibly deleted:

• All personal financial data: transactions, accounts (bills), categories, budgets, scheduled payments
• AI chat history, receipts, AI usage records
• User profile and settings
• Firebase Authentication record
• Subscription status record

Deletion is immediate. There is no grace period or recovery option.

Active subscriptions managed by Apple are not automatically cancelled upon account deletion. You must cancel your subscription separately via iOS Settings → Subscriptions.

If you are a member (not owner) of a Family Space: your membership is removed automatically upon account deletion. Shared data you contributed (transactions, bills) remains in the Family Space as it belongs to the shared account, not to you individually.

If you are the owner of a Family Space: you must delete the Family Space before deleting your account (see Section 12).

After deleting your account, you may create a new account and restore your active subscription via Restore Purchases in the App. Previously entered personal data cannot be recovered.

12. Family Space

If you participate in a Family Space, certain data — including transactions, budgets, and account balances — is shared with all members of that Family Space. You must only join or invite others to a Family Space with their explicit consent.

Family Space deletion: The owner may delete the Family Space at any time. Upon deletion, all shared financial data (transactions, bills, categories, budgets, receipts, AI chat history) is permanently deleted and all members immediately lose access. The owner's subscription is not affected and may be applied to a new Family Space.

Member removal: The owner may remove any member at any time. The removed member loses access to the shared account immediately. Data contributed by the removed member remains in the shared account. The removed member's personal account and data are not affected.

12a. Automated Decision-Making (Art. 22 GDPR)

The App uses AI for automated processing such as transaction categorization, receipt parsing, and financial analysis. These features assist you in organizing your financial data.

No decisions with legal or similarly significant effects are made solely by automated means. All AI-generated categorizations and suggestions can be reviewed, edited, or rejected by you before saving.

During onboarding, the App generates an initial set of categories and budget suggestions automatically using AI. These suggestions are presented to you for review on the Plan Preview screen before any data is committed to your account, and you may edit, replace, or delete them at any point afterwards. No suggestions are applied to your account without your explicit acceptance via the «Looks Good» action on the Plan Preview screen.

13. International Data Transfers

All primary data storage and processing occurs within the European Union (Google Cloud, eur3 / europe-west1).

RevenueCat, Inc. is based in the United States. Where subscription data is transferred to the US, it is protected by Standard Contractual Clauses (SCCs) approved by the European Commission.

14. Changes to This Policy

We may update this Policy from time to time. We will notify you of any material changes by posting the new Policy within the App and on our support website. The Effective Date at the top of this document will be updated accordingly. If you do not agree with the changes, you may delete your account. Continued use of the App after 30 days constitutes acceptance of the updated Policy.

For material changes that affect the legal basis of data processing or introduce new categories of data collection, we will provide in-App notification with the option to review the changes before they take effect. If you do not accept such changes, you may delete your account.

15. Contact Us

For questions about this Policy or to exercise your rights, contact us:

Oleh Herasymenko
Friedrichshafen, Germany
Email: thevaltorna@gmail.com
Support Website: https://getquro.app

16. Changelog

Version 1.2 (2026-05-15) — Added Section 6c describing website cookies and Meta Pixel on getquro.app: consent-gated loading, joint controllership with Meta (Art. 26 GDPR), legal basis Art. 6(1)(a) GDPR / § 25(1) TTDSG, EU-US Data Privacy Framework transfers, and withdrawal options. Added Meta Pixel row to the Third-Party Services table. Clarified consent reference in Section 5.

Version 1.1 (2026-05-12) — Removed legacy Basic and Family subscription tiers (only unified Pro plan remains). Family Space is now available to all users at no cost. AI features access is per-individual-user (not per-family). AI consent is now given via Welcome screen acceptance, not via a separate first-use prompt. Added documentation of temporary anonymous Firebase authentication during onboarding.

Version 1.0 (2026-03-31) — Initial release.