Before using Spendly you are required to acquaint yourself with the Terms of Use ("Terms") and this Privacy Policy ("Policy") regulating the collection, processing and use of your personal data. The Policy forms an integral part of the Terms and all definitions and names shall have the respective meaning defined therein. You agree to provide the Provider always only accurate, truthful and current personal data and keep it up to date.
You acknowledge that ISABEL SALES DE CASTRO ALMEIDA DESENVOLVIMENTO DE SOFTWARE LTDA, CNPJ. No.: 39.779.539/0001-26, with its registered office at street CONQUISTA DO PARQUE UNIAO, 00015 COND 282 LOTE 28PAV 2 AP 201 - MARE, RJ - BRAZIL ("Provider") may, as a data controller, process your personal data in a scope specified hereunder as necessary for the performance of a contract arising out of these Terms. The purpose of this personal data processing is service provision which includes, but is not limited to, setting up and keeping your Spendly account, ensuring Spendly features and providing support. Minimum scope of your personal data required for a conclusion of a contract with the Provider and setting up and keeping your Spendly account include your first name, last name, e-mail address, login credentials, language, currency and subscription details. Provision of other personal data is completely voluntary and therefore the scope of the data being processed by the Provider depends mainly on the Spendly features you want to use.
The Provider is obliged to process your personal data in order to identify you in accordance with the act no. 253/2008 Coll., on Selected Measures against Legitimisation of Proceeds of Crime and Financing of Terrorism (the “AML Act”). The scope of the collected data is first name, last name, sex, birth number, or date of birth if the birth number is not applicable, place of birth, permanent address, and citizenship. The purpose of this personal data processing is to comply with the legal obligation to which Spendly is subject. The data on potentially suspicious transactions within the meaning of the AML act are stored for the period of 10 years, even after the deletion of your Spendly account. In case you want to use login through Facebook or Google account, the Provider will process identification details of the respective social media account.
In order to get more personalized experience and better financial advice, you can also fill out your Spendly account and let us process your personal data including profile photo, birth date, sex, family status, place of residence, housing situation, education and employment details, property details and economic situation.
You furthermore acknowledge that as a part of the personal data processing for the purpose of service provision the Provider may use profiling to analyse or predict aspects concerning your family status, housing situation, education and employment, property details and economic situation, as well as behaviour in order to deliver you the best personalised experience and financial advice. This profiling doesn't result in any automated decision-making which would produce legal effects to you or would have similarly significant consequence.
All personal data categories mentioned above in this section can be hereinafter referred to as "Personal data". The Personal data will be processed by the Provider for the purpose of service provision until you delete it or until you or the Provider will terminate the Agreement.
You acknowledge that the Provider, as a data controller, may use your e-mail address and its details it has obtained in the course of registration to send you direct marketing communications regarding Spendly. Your e-mail may be used by the Provider until you opt out. You can opt out at any time by clicking on the "unsubscribe" link in the respective e-mail or by another action described therein.
You can give the Provider, as a data controller, consent to process your Personal data for marketing purposes, particularly in order to create audiences and otherwise personalise your ad experience, including marketing communications. The Personal data will be processed by the Provider for marketing purposes until you withdraw your consent. You can withdraw your consent at any time within the Spendly application.
You acknowledge that as a part of the personal data processing for marketing purposes the Provider may use profiling to analyse or predict aspects concerning your family status, housing situation, education and employment, property details and economic situation, as well as behaviour in order to deliver you the best ad experience. This profiling doesn't result in any automated decision-making which would produce legal effects to you or would have similarly significant consequence.