Privacy Policy

1. Introduction

Custovia Inc., operating as BudgX ("BudgX," "we," "our," or "us"), is committed to protecting your privacy. This policy explains how we collect, use, share, and protect your personal and financial information when you use the BudgX web application and mobile apps (iOS & Android) (collectively, the "Service").

By using BudgX you agree to this policy. If you do not agree, please do not use the Service.

2. Information We Collect

Information you provide directly:

• Account details — email address, display name, profile photo
• Manually entered transactions — amount, date, merchant, category
• Budget limits and savings goals you create
• Messages and questions sent to the AI coach
• Security settings, preferences, and notification choices

Financial data collected via Plaid:

When you choose to link a bank account, BudgX uses Plaid — a regulated financial data platform — to connect to your financial institution. Through Plaid we may receive:

• Transaction history (payee, amount, date, category, payment method)
• Account balances (current and available)
• Account identifiers (institution name, account type, last 4 digits)
• Investment holdings and portfolio values (if you link investment accounts)
• Liability information such as credit card balances, loan balances, minimum payments (if linked)
• Recurring transaction and subscription detection data

We receive this data on a read-only basis. BudgX cannot initiate transfers, payments, or any transactions on your behalf. Your banking credentials (username, password) are entered directly into Plaid's interface and are never transmitted to or stored by BudgX. Plaid access tokens are encrypted at rest using AES-256-GCM before storage.

Bank linking is entirely optional. You can use BudgX by entering transactions manually. You can disconnect any linked account at any time from Settings → Connected Accounts.

Automatically collected data:

• Device type, operating system, and app version
• IP address and approximate location (country/region)
• Usage patterns — which features you use and how often
• Error logs and crash reports (excluding financial data)
• Push notification tokens (for in-app alerts, if you opt in)

3. How We Use Your Information

We process your information for the following purposes and legal bases:

Automated decision-making: BudgX uses AI (powered by Anthropic Claude) to automatically categorise transactions, generate spending insights, and provide financial coaching. These are informational outputs to help you understand your finances — they do not produce legal or similarly significant effects. You can override any AI categorisation in the app.

4. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share data only as follows:

We may also disclose your information (i) if required by law, court order, or regulatory authority; (ii) to protect the rights, safety, or property of BudgX or others; or (iii) in connection with a merger, acquisition, or sale of assets, in which case the acquirer will be bound by this policy.

5. International Data Transfers

BudgX is operated from the United States. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, your personal data is transferred to and processed in the United States. We rely on the following safeguards for such transfers:

• Standard Contractual Clauses (SCCs) approved by the European Commission with our service providers
• Processing by providers certified under applicable data transfer frameworks (where applicable)

By using BudgX you acknowledge that your data may be transferred to and processed in the United States and other countries where our service providers operate.

6. Data Security

We implement the following technical and organisational security measures:

• Encryption in transit: All connections use TLS 1.2 or higher (HTTPS enforced by Vercel; HTTP Strict Transport Security headers set)
• Encryption at rest: Plaid access tokens are encrypted using AES-256-GCM before storage in our database. Google Firebase uses AES-256 for all stored data.
• Access control: Firestore security rules enforce per-user data isolation — your data cannot be accessed by other users. Admin access requires Firebase service account credentials stored as encrypted environment variables.
• Authentication: Two-factor authentication (2FA) available for all user accounts. All staff access to production systems requires MFA.
• Read-only bank access: Plaid connections are provisioned with read-only permissions. BudgX cannot initiate any financial transactions.
• Monitoring: Real-time error monitoring (Sentry), rate limiting on all API endpoints, and Vercel access logs for anomaly detection.

Despite these measures, no method of transmission or storage is 100% secure. If you believe your account has been compromised, contact us immediately at privacy@budgx.ai.

7. Data Retention

8. Your Privacy Rights

Depending on your location you may have the following rights. You can exercise most of these directly in the app at Settings → Privacy & data:

• Access: Request a copy of the personal data we hold about you.
• Portability: Download your data in JSON format from Settings → Privacy → Export data.
• Correction: Update inaccurate information from your profile settings.
• Deletion (right to be forgotten): Delete your account and all associated data from Settings → Privacy → Delete account. Data is permanently purged within 30 days.
• Restriction: Request that we limit how we process your data in certain circumstances.
• Objection: Object to processing based on legitimate interest (e.g. marketing).
• Withdraw consent: Where we rely on consent (e.g. marketing emails), you can withdraw it at any time. Withdrawing consent does not affect lawful processing before withdrawal.
• Disconnect bank accounts: Revoke Plaid access at any time from Settings → Connected Accounts. This immediately revokes our access to your bank data.

California residents (CCPA/CPRA): We do not sell or share your personal information for cross-context behavioural advertising. You have the right to know what data we collect, the right to delete, the right to correct, and the right to opt out of any future sale (we have no such programme). To exercise CCPA rights, contact us at privacy@budgx.ai.

EEA/UK residents (GDPR/UK GDPR): You have the right to lodge a complaint with your local data protection authority if you believe we have not handled your data in accordance with applicable law.

9. Cookies and Tracking

We use a small number of strictly necessary cookies:

• budgx_session — authenticates your API requests. Expires with your session or after 24 hours.
• budgx_subscription — stores your subscription status so we can gate Premium features without an extra API call on every page load.

We do not use advertising cookies, cross-site tracking cookies, or third-party analytics that track you across the web. See our Cookie Policy for full details.

10. Children's Privacy

BudgX is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@budgx.ai and we will delete it promptly.

11. Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of any third-party services you access.

12. Changes to This Policy

We may update this policy from time to time. When we make material changes, we will notify you via email (to the address on your account) and/or a prominent notice in the app at least 30 days before the change takes effect. The "Effective date" at the top of this page reflects when the current version became active. Your continued use of BudgX after changes are effective constitutes acceptance of the updated policy.

13. Contact & Data Controller

The data controller responsible for your personal information is:

For data subject rights requests, you can also use the in-app tools at Settings → Privacy & data. We aim to respond to all requests within 30 days.