Privacy policy

1. Introduction

At SubTamer, we respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use our subscription management application available on iOS and Android devices.

Privacy-First Design: SubTamer is built with your privacy in mind, featuring permanent account and data deletion capabilities that put you in complete control of your personal information.

By using SubTamer, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Email address, username, and authentication data when using Apple Sign-In, Google Sign-In, or other supported authentication methods
• Subscription Details: Service names, costs, billing cycles, renewal dates, payment methods, and free trial information you choose to track (including SubTamer's own subscription when you subscribe)
• Expense Details: Individual expense entries including merchant names, amounts, dates, categories, and notes that you manually enter or capture through receipt scanning
• Receipt Images (Full Plan Only): Photos or images of receipts that you choose to scan using the receipt scanning feature. Important: These images are processed entirely on your device using Google ML Kit for OCR (Optical Character Recognition) and are NOT saved or stored anywhere. Images are immediately discarded after text extraction, and only the extracted text is used for AI-assisted data extraction.
• Financial Information (Optional): Income data that you voluntarily choose to share for enhanced AI insights and analytics. You have complete control over whether to provide this information and can opt out at any time
• Sharing Preferences: Settings that control what subscription and financial data you choose to share with other SubTamer users, including subscription details and income information
• Connected Users: Email addresses of other SubTamer users you choose to share your data with, and users who have shared their data with you
• User Preferences: App settings, notification preferences, currency settings, display customizations, and service tier preferences (Basic vs Full Plan)
• AI Assistant Interactions: Questions, queries, and conversations you have with the AI-powered financial assistant, including requests for spending insights, trend analysis, and predictions
• Support Communications: Information you provide when contacting customer support
• Subscription Purchase Data: Information about your SubTamer subscription status, billing history, and entitlements processed through app stores

2.2 Information Collected Automatically

• Usage Data: How you interact with the app, features used, time spent in the application, feature usage patterns between Basic and Full Plan tiers, AI assistant usage patterns, receipt scanning frequency, and subscription sharing activity
• Device Information: Device type, operating system (iOS/Android), app version, unique device identifiers, device tokens for push notifications, and camera permissions status
• Technical Data: IP address, app performance data, crash reports, and access times for security and performance monitoring
• App Store Data: Purchase receipts, subscription status, and transaction IDs from Apple App Store and Google Play Store
• Authentication Data: Tokens and identifiers from Apple Sign-In, Google Sign-In, and other authentication providers
• OCR Processing Data: Metadata about receipt scanning operations, including success rates and processing times (receipt images are processed locally on your device where possible)

2.3 Information We Do NOT Collect

• We do not access your actual bank accounts, credit cards, or payment processor accounts
• We do not collect sensitive personal information such as government IDs, biometric data, or health information
• We do not track your location unless explicitly required for a specific feature with your consent
• We do not store your actual payment card details - all subscription payments are processed securely by Apple App Store or Google Play Store
• We do not retain AI assistant conversation history beyond what is necessary to provide contextual responses during your active session
• We do not store receipt images permanently - they are processed and then deleted unless you choose to save them locally on your device
• We cannot access subscriptions or data shared with you by other users unless they explicitly grant you permission

3. How We Use Your Information

We use your information to:

• Provide Core Services: Display subscription tracking, expense tracking, billing calendars, cost analytics, renewal reminders, and differentiate between Basic and Full Plan features
• Receipt Scanning (Full Plan Only): Process receipt images using Google ML Kit OCR and AI-powered extraction to automatically populate expense details, recognize merchants, extract amounts and dates, and categorize expenses
• Subscription Sharing: Enable you to share your subscription information and optional income data with other SubTamer users you designate, and view shared data from users who have granted you access
• AI-Powered Insights: Analyze your subscription and expense data to provide personalised spending insights, identify spending patterns and trends, predict future expenses, generate spending forecasts, and create dynamic visualizations through our AI assistant powered by GPT-4o-mini
• Enhanced Analytics: Process your optional income data to provide more accurate financial insights, spending-to-income ratios, and personalised recommendations
• Generate Visualizations: Create dynamic charts, graphs, and diagrams using Mermaid markdown to help you visualize your spending patterns, trends, and predictions
• Process Subscriptions: Manage your SubTamer subscription, process free trials, handle billing, and verify subscription status with app stores
• Send Notifications: Deliver push notifications for subscription renewals, billing alerts, trial expiration warnings (1 week, 3 days, 1 day before), and important app updates
• Auto-tracking Feature: Automatically add SubTamer as a tracked subscription in your account when you start a trial or subscription
• Authentication: Verify your identity through third-party services like Apple Sign-In and Google Sign-In
• Account Management: Manage your account, sync data across devices, manage sharing permissions, and provide customer support
• App Enhancement: Analyze usage patterns to improve features, develop new functionality, optimize the user experience, improve AI assistant accuracy and relevance, and enhance receipt scanning accuracy
• Security: Detect and prevent fraudulent activity, unauthorized access, unauthorized sharing, and technical issues
• Legal Compliance: Meet legal obligations, enforce our terms of service, and comply with app store requirements

4. Receipt Scanning and OCR Processing

4.1 Receipt Scanning Features (Full Plan Only)

SubTamer's Full Plan includes AI-assisted receipt scanning that allows you to:

• Capture receipt images using your device camera
• Automatically extract expense information from receipts
• Recognize merchant names, amounts, dates, and categories
• Populate expense entries without manual data entry

4.2 Google ML Kit Integration

OCR Processing: Receipt scanning uses Google ML Kit for Optical Character Recognition (OCR). This processing occurs entirely on your device to protect your privacy.

How It Works:

• When you capture a receipt image, Google ML Kit processes the image locally on your device to extract text
• The extracted text (not the image) is then sent to OpenAI's GPT-4o-mini for intelligent interpretation and data extraction
• Receipt images are NOT saved or stored anywhere - they are processed in memory and immediately discarded after text extraction
• Only the extracted text data is sent to our servers and OpenAI for processing
• No receipt photos are ever uploaded, transmitted, or stored on our servers or any third-party servers

4.3 Camera Permissions

To use receipt scanning, you must grant camera permissions to SubTamer. You can:

• Grant or revoke camera access at any time through your device settings
• Use the app's other features without granting camera access
• Manually enter expense information instead of using receipt scanning

4.4 Receipt Data Processing

Data Shared for Receipt Processing:

• Extracted text from receipts (not the images themselves)
• Merchant information, amounts, and dates detected in receipts
• Context about your existing expense categories for better classification

Data NOT Shared or Stored:

• Receipt images are NEVER saved, stored, or transmitted - they exist only temporarily in device memory during processing
• Your personal account credentials
• Unrelated subscription or financial data

Important: Receipt photos are processed entirely on your device and are immediately discarded after text extraction. We have no access to your receipt images at any point.

5. Subscription Sharing Features

5.1 How Subscription Sharing Works

SubTamer allows you to share your subscription information with other SubTamer users via email invitation. You have complete control over:

• Which users can view your subscription data
• Whether to share your optional income information
• The ability to revoke sharing access at any time

5.2 What Can Be Shared

When you enable subscription sharing, you can choose to share:

• Subscription Information: Service names, costs, billing cycles, renewal dates, and payment methods for subscriptions you track
• Expense Information: Individual expenses and receipt-scanned transactions
• Income Data (Optional): Your income information, only if you explicitly choose to share it
• Analytics: Spending insights, trends, and patterns based on your data

5.3 Receiving Shared Data

When another user shares their subscriptions with you:

• You can only view the data they explicitly choose to share with you
• You receive read-only access - you cannot modify their data
• You can see their income data only if they choose to make it available
• Their data is clearly distinguished from your own data in the app
• Access is automatically revoked if they remove sharing permissions

5.4 Sharing Privacy and Security

• Email-Based Invitations: Sharing is initiated by email address, and both users must have SubTamer accounts
• Explicit Consent: Data is only shared when you explicitly grant permission
• Granular Control: You can control exactly what information is shared
• Revocable Access: You can revoke sharing access at any time, immediately removing the other user's ability to view your data
• No Third-Party Sharing: Shared data is only visible to the specific users you designate and is never shared with third parties
• Audit Trail: You can view who has access to your shared data at any time

5.5 Your Responsibilities When Sharing

When you share your subscription data with others, you acknowledge that:

• You are responsible for choosing trustworthy users to share with
• Shared data becomes visible to the recipients and should be treated as disclosed information
• You should regularly review and manage your sharing permissions
• SubTamer is not responsible for how recipients use your shared data within their own accounts

6. AI Assistant and Third-Party AI Services

6.1 AI Assistant Features

SubTamer includes an AI-powered financial assistant that provides:

• Personalised spending insights and analysis
• Identification of spending patterns and trends
• Predictive analytics for future expenses
• Dynamic chart and visualization generation
• Answers to questions about your subscription and expense data
• Intelligent receipt data extraction and categorization
• Customized financial recommendations based on your spending habits

6.2 OpenAI Integration

Third-Party AI Processing: The AI assistant is powered by OpenAI's GPT-4o-mini model. When you interact with the AI assistant or use receipt scanning, your data and queries are securely transmitted to OpenAI's servers for processing.

Data Shared with OpenAI:

• Your subscription information (service names, costs, billing cycles, renewal dates)
• Your expense information and receipt-extracted data
• Optional income data (only if you choose to provide it)
• Your questions and queries to the AI assistant
• Extracted text from receipts for intelligent interpretation
• Relevant financial summary data needed to generate insights

Data NOT Shared with OpenAI:

• Your personal account credentials or authentication tokens
• Actual payment card details (we don't have access to these)
• Receipt images (only extracted text is shared)
• Your device identifiers or IP address
• Data shared with you by other users (unless you explicitly query about it)
• Any data unrelated to the specific AI query

6.3 OpenAI's Data Usage

OpenAI processes your data to generate AI responses and improve their services. According to OpenAI's policies:

• Data sent through the API may be retained by OpenAI for up to 30 days for abuse monitoring
• After 30 days, your data is deleted from OpenAI's systems
• OpenAI does not use API data to train their models unless you explicitly opt in
• Your interactions are subject to OpenAI's Privacy Policy and Terms of Service

For more information, please review OpenAI's Privacy Policy.

6.4 Your Control Over AI Features

• Optional Feature: The AI assistant and receipt scanning are optional features that you can choose to use or not use
• Income Data Control: You have complete control over whether to share your income data with the AI assistant. This information is entirely optional and can be added, modified, or removed at any time
• Session-Based Processing: AI conversations are processed in real-time and are not permanently stored in our systems beyond your active session
• Data Minimization: We only send the minimum data necessary to provide relevant AI insights and receipt processing

7. Legal Basis for Processing (EU/UK Users)

Under GDPR and UK GDPR, we process your data based on:

• Contract Performance: To provide the subscription management services you've requested, process your SubTamer subscription, deliver AI-powered insights and analytics, process receipt images, and enable subscription sharing features
• Legitimate Interests: To improve our services, ensure security, provide customer support, optimize app performance, enhance AI assistant accuracy, and improve receipt scanning capabilities
• Consent: For optional features like marketing communications, certain types of notifications, sharing income data with the AI assistant, using AI-powered features, using camera for receipt scanning, and sharing your subscription data with other users

8. Data Storage and Security

8.1 Security Measures

• Industry-standard encryption for data transmission and storage
• Secure API connections to OpenAI using encrypted HTTPS protocols
• Encrypted transmission of receipt data and OCR results
• Regular security audits and vulnerability assessments
• Access controls limiting employee access to personal data
• Secure backup systems with encryption
• Secure integration with Apple and Google authentication and billing services
• Encrypted storage of shared subscription data with access controls
• Protection against unauthorized access to shared data

8.2 Data Location

Your data is stored on secure servers located in Europe. We ensure adequate protection regardless of location through contractual safeguards and technical measures. Some data may be processed by Apple, Google, and OpenAI services in accordance with their privacy policies. OpenAI processes data on servers located in the United States with appropriate safeguards in place. Google ML Kit processes receipt images locally on your device where possible.

9. Data Sharing and Third Parties

9.1 We Do NOT Share Your Data With:

• Marketing companies or advertisers
• Data brokers or analytics companies for commercial purposes
• Social media platforms
• Any third party for profit or commercial gain
• Other SubTamer users unless you explicitly grant sharing permissions

9.2 Limited Sharing May Occur For:

• User-Authorized Sharing: Other SubTamer users you explicitly choose to share your subscription and optional income data with via email invitation. This sharing is entirely under your control and can be revoked at any time.
• AI Service Providers: OpenAI (GPT-4o-mini) receives your subscription data, expense data, receipt-extracted text, and queries solely to provide AI-powered insights, analysis, predictions, and receipt processing. This data is processed securely and is subject to OpenAI's privacy policies and data retention practices
• OCR Service Providers: Google ML Kit processes receipt images locally on your device to extract text. Minimal metadata may be sent to Google for service improvement in accordance with their privacy policies
• App Store Providers: Apple App Store and Google Play Store for subscription processing, authentication, and compliance
• Authentication Providers: Apple, Google, and other authentication services for secure sign-in functionality
• Service Providers: Trusted vendors who help us operate the app (hosting, customer support tools, push notification services) under strict confidentiality agreements
• Legal Requirements: When required by law, court order, or to protect our legal rights
• Business Transfers: In the event of a merger, acquisition, or sale of assets (with user notification)

10. Data Retention and Permanent Deletion

10.1 Your Right to Permanent Deletion

Complete Data Control: SubTamer provides you with the ability to permanently delete your account and all associated personal data. This privacy-first feature ensures you maintain complete control over your information.

10.2 Data Retention Periods

• Active Accounts: Data is retained while your account remains active
• Receipt Images: Receipt photos are NEVER stored - they are processed in device memory and immediately discarded after text extraction. Only the extracted expense data is retained with your expense records
• Shared Data: Data you've shared with other users remains accessible to them until you revoke sharing permissions. After revocation, access is immediately removed
• AI Conversation Data: AI assistant conversations are not permanently stored beyond your active session. Temporary processing data is retained only as long as necessary to provide responses
• OpenAI Data Retention: Data sent to OpenAI for AI processing and receipt interpretation is retained for up to 30 days for abuse monitoring, then permanently deleted from their systems
• Deleted Accounts: All personal data, including shared data associations, is permanently and irreversibly deleted within 30 days of account deletion request
• Subscription Data: SubTamer subscription records may be retained for tax and legal compliance purposes as required by law, but will be anonymized where possible
• Legal Requirements: Some data may be retained longer only if required by law or app store policies
• Backup Systems: Data in secure backups is permanently deleted within 90 days of account deletion

10.3 Account Deletion Process

When you request account deletion:

• Immediate Effect: Your account is deactivated immediately
• Data Removal: All your personal data, subscription tracking information, expense records, receipt data, preferences, and AI-related data are permanently deleted
• Sharing Termination: All sharing permissions you've granted are immediately revoked, and other users lose access to your shared data
• Shared Access Removal: You lose access to data that other users have shared with you
• Third-Party Processing: We ensure that any data shared with OpenAI for AI processing is subject to their deletion policies
• Irreversible Process: Account deletion cannot be undone - this ensures your data is truly removed

10.4 Important: Subscription Billing Responsibility

Critical Notice: Deleting your SubTamer account does NOT automatically cancel your paid SubTamer subscription through the app stores. This is your responsibility and you will be clearly notified during the deletion process.

• Active Subscription Warning: If you have an active paid subscription, you must cancel it separately through your app store account settings before or after deleting your account
• Continued Billing: Failure to cancel your app store subscription will result in continued billing even after your SubTamer account is deleted
• Your Responsibility: Managing app store subscriptions is your responsibility - we cannot cancel these on your behalf
• Clear Instructions: The app provides clear instructions on how to cancel subscriptions during the account deletion process

To Cancel Your Subscription:

• iOS users: Go to Settings → Apple ID → Subscriptions → SubTamer → Cancel Subscription
• Android users: Go to Google Play Store → Account → Payments & Subscriptions → Subscriptions → SubTamer → Cancel

11. Your Rights

11.1 Access and Control

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete information
• Erasure: Request deletion of your data ("right to be forgotten")
• Portability: Receive your data in a structured, machine-readable format
• Restriction: Limit how we process your data in certain circumstances
• Objection: Object to processing based on legitimate interests
• AI Feature Control: Choose whether to use AI-powered features, receipt scanning, and whether to share optional income data
• Sharing Control: Manage who has access to your shared subscription data and revoke sharing permissions at any time
• Withdraw Consent: Withdraw consent for AI data processing, receipt scanning, and subscription sharing at any time
• Subscription Management: Cancel your SubTamer subscription through app store settings

11.2 Exercising Your Rights

To exercise these rights, contact us at [email protected] with:

• Your full name and email address
• Specific request details
• Verification of your identity

We will respond within 30 days of receiving your request.

12. Cookies and Tracking

SubTamer uses minimal tracking technologies:

• Essential Data: Required for app functionality, authentication, and security
• Preference Data: Store your app settings, notification preferences, service tier information, AI feature preferences, and sharing preferences
• Analytics: Basic usage analytics to improve the app, understand feature usage, improve AI assistant performance, and enhance receipt scanning accuracy (anonymized where possible)
• App Store Analytics: Subscription and usage analytics provided by Apple App Store and Google Play Store

You can manage data preferences through your device settings and app preferences.

13. Push Notifications

13.1 Types of Notifications

SubTamer may send push notifications for:

• Subscription Reminders: Alerts before renewals, payment due dates, and billing cycles for your tracked subscriptions
• Trial Expiration Alerts: Notifications 1 week, 3 days, and 1 day before your free trial ends to prevent unexpected charges
• AI Insights: Optional notifications when the AI assistant identifies significant spending patterns or anomalies
• Sharing Notifications: Alerts when another user shares subscriptions with you or when your sharing permissions are modified
• SubTamer Billing Reminders: Notifications about your own SubTamer subscription renewals and billing
• Cost Alerts: Notifications when spending thresholds are reached or cost changes are detected
• Feature Updates: Information about new features, important updates, or maintenance
• Account Security: Alerts about login attempts or account changes

13.2 Managing Notifications

You can control push notifications through:

• App Settings: Enable/disable specific notification types within SubTamer, including trial expiration alerts, AI insight notifications, and sharing notifications
• Device Settings: Manage all app notifications through your device's system settings
• Granular Control: Choose which subscriptions trigger notifications, set custom timing, and customize reminder frequency
• Service Tier Controls: Basic Plan users receive limited notifications; Full Plan users can set up to 3 custom reminders per subscription

13.3 Technical Details

• We use device tokens to deliver notifications through Apple Push Notification Service (APNS) and Firebase Cloud Messaging (FCM)
• Notification content is processed securely and is not stored longer than necessary for delivery
• You can revoke notification permissions at any time through your device settings
• Trial expiration notifications are sent regardless of other notification settings to ensure billing transparency

14. Third-Party Authentication Services

SubTamer integrates with third-party authentication providers:

• Apple Sign-In: Subject to Apple's Privacy Policy and Terms of Service
• Google Sign-In: Subject to Google's Privacy Policy and Terms of Service

When you use these services, we receive only the information you choose to share. We do not have access to your Apple ID or Google account passwords. Please review the respective privacy policies of these providers for information about their data practices.

15. App Store Integration

SubTamer integrates with app stores for subscription processing:

• Apple App Store: Processes subscriptions, handles billing, and manages trial periods for iOS users
• Google Play Store: Processes subscriptions, handles billing, and manages trial periods for Android users

Your subscription and payment data with these services is governed by their respective privacy policies. We receive only necessary information to verify your subscription status and provide appropriate service features.

16. Children's Privacy

SubTamer is not intended for users under 16 years old. We do not knowingly collect personal information from children under 16. If we discover such collection, we will delete the information immediately.

17. International Data Transfers

If you're located outside Europe/UK, your data may be transferred to and processed in countries with different data protection laws. We ensure appropriate safeguards through:

• Standard contractual clauses
• Adequacy decisions
• Other legally approved transfer mechanisms
• Compliance with Apple, Google, and OpenAI data protection standards

OpenAI Data Transfers: When you use the AI assistant or receipt scanning, your data is transferred to OpenAI's servers in the United States. OpenAI implements appropriate technical and organizational measures to protect your data in compliance with applicable data protection laws.

18. Changes to This Policy

We may update this Privacy Policy to reflect:

• Changes in our data practices
• Legal or regulatory requirements
• New features, services, AI capabilities, receipt scanning enhancements, subscription sharing features, or app store integrations
• Updates to third-party service integrations

Notification: We will notify you of material changes via email, push notification, or in-app notification at least 30 days before they take effect.

19. Contact Information

20. Complaints

If you believe we have not handled your personal data properly, please contact us directly at [email protected] and we will work to resolve your concerns.