Privacy policy

1. Who is responsible

Federica Mariani, an individual established in Italy, publishes Trackly and is the data controller for the limited processing described here.

• Controller: Federica Mariani
• Address: Via Rio de Janeiro 30, Torino, Italy
• Privacy contact: [email protected]

We have not appointed a Data Protection Officer. We have not appointed an EU representative because the controller is established in Italy. Privacy requests go to the contact above.

2. At a glance

• The ledger, categories, monthly limit, recurring rules, reminders, preferences and the widget/watch summary stay on your device. We do not receive them and cannot read them.
• The one entry-related call is Smart capture: when you use it, the words you typed or said, the language, the local date and your category names are sent to our classifier so it can suggest a category. The amount and merchant are extracted locally.
• Purchases are processed by Apple or Google, with RevenueCat telling the app whether your subscription is active.
• There is no account, no advertising, no advertising identifier, no analytics SDK and no crash-reporting SDK.
• We do not sell personal data or share it for advertising.

3. What stays on your device

Trackly has no account and no server-side copy of your ledger. Everything you enter lives in a private database inside the app on your device:

• the expenses you log, with their amounts, dates, times, notes, categories and source;
• the monthly limit you set and your category setup;
• recurring payments you add, and reminder settings;
• your app preferences, including language, currency and week start;
• the small summary the iPhone widget and Apple Watch extension display, shared with them through an Apple app group on the same device.

We cannot see any of it. There is no dashboard where we could: no expense ever reaches us unless you use Smart capture, as described below. The app does not attach photos in this version; if that changes, this policy will be updated before the feature ships.

4. What leaves your device

There are five cases. Only the first is specific to this app; the others are the store, the operating system, support email and the website.

4.1 Smart capture

When you describe an expense with Smart capture, the text you typed or the transcript of what you said — together with the language, today’s date and the names of your own categories — is sent to our classification proxy on Cloudflare. The proxy passes it to TypeSafe AI’s System One API and returns a suggested category and, when the words say so, a recurring cadence. The amount and merchant are parsed locally in the app. You see the suggestion before saving and can change it.

Our Worker does not write the text to a database. Cloudflare processes the request and may keep standard request metadata, including the IP address, URL, time and user agent; Worker log retention is up to seven days on a paid plan and three days on the free plan. Request bodies are not logged by default. TypeSafe receives the text as our processor, says it does not train or fine-tune models on Input, and retains personal data for as long as reasonably necessary under its privacy policy. Its data processing addendum uses the European Commission’s Standard Contractual Clauses and the UK IDTA. We have not enabled a zero-retention arrangement; if we do, this policy will say so.

Smart capture is a paid feature and is intended for users aged 18 or over, because the classification provider does not direct its service to children. If you are under 18, use manual logging. Do not type sensitive information — such as health, religious, political or financial account details — into Smart capture.

4.2 Purchases

Subscriptions and any free trial are sold by Apple through your Apple Account on iOS, or by Google through Google Play on Android. The store processes the payment and holds the receipt; we never see your card details. We use RevenueCat to tell the app whether your subscription is active. RevenueCat receives an anonymous app user ID, the device type and operating system, a last-seen time, the store receipt or purchase token, the product and entitlement, and purchase and renewal dates. It does not receive your ledger. RevenueCat stores this data on Amazon Web Services in the United States and keeps end-user data for the subscription relationship and six years afterwards; its privacy policy and data processing addendum apply.

4.3 Speech recognition

When you speak an expense, your words are turned into text by the speech recognition service built into your device. On iOS that is Apple; on Android it is Google. Depending on your device, language and settings, recognition may happen on the device or on the provider’s servers. We do not receive, hear or store the recording. You can revoke microphone or speech permission in your device settings; Smart capture then falls back to typing.

4.4 Support email

If you write to [email protected], Cloudflare Email Routing forwards the message to a private inbox. Cloudflare publishes no fixed retention period for routed messages; we keep the message for as long as needed to answer and for up to 24 months afterwards, unless a legal obligation requires longer. Do not send sensitive data you do not want in an email.

4.5 This website

This is a static website. We do not set cookies, run analytics, advertise or track you across sites. Cloudflare, Inc. serves it through Cloudflare Pages and processes standard request metadata — IP address, user agent, requested URL and time — for security and operations. Cloudflare publishes no fixed retention period for that metadata, and we keep no separate copy of it.

5. What we do not do

• No analytics or crash-reporting service is included in the app.
• No advertising, and no advertising identifier is read or transmitted.
• No account, sign-in, email address or phone number is required to use Trackly.
• No bank or card connection: Trackly works only with the expenses you enter yourself.
• We do not sell personal data, and we do not share it for advertising.
• We do not use your entries to build a profile of you or to make automated decisions that have legal or similarly significant effects. Smart capture suggests; you decide.

6. Legal bases

Where the GDPR applies, we rely on:

• Performance of our contract with you (Article 6(1)(b)) to provide the app, Smart capture, Pro and support.
• Our legitimate interests (Article 6(1)(f)) in keeping the service secure, preventing abuse and fixing failures, balanced against your rights.
• Legal obligations (Article 6(1)(c)) for records that the store or the law requires us to keep.

We do not rely on consent for the core processing described here. If a feature ever relies on consent, it will ask separately and you can withdraw at any time without affecting processing already carried out.

7. How long we keep things

• Your ledger: on your device until you delete the entry or the app. We hold no copy to restore from.
• Smart capture text: not stored by us. Cloudflare request metadata up to 7 days; TypeSafe under its own retention terms, with no fixed period published.
• Purchase and subscription data: Apple/Google under their policies; RevenueCat for the subscription relationship plus six years; the local record until you reset it or delete the app.
• Support email: up to 24 months after the issue is closed, unless a legal obligation requires longer.
• Website logs: Cloudflare’s own retention period for request metadata, which is not fixed; we keep no separate copy.

8. Your rights

Because the ledger is on your device, you can already read, correct and erase it directly in the app — that is the strongest form of these rights. Where we or our providers process data, you have the rights the GDPR gives you: access, rectification, erasure, restriction, portability and objection, as well as the right to withdraw consent where consent is the basis.

Write to [email protected] to exercise any of them. We respond within one month, extendable by up to two months where the request is complex. For purchase data, the store or RevenueCat may need to be involved; we will tell you which route applies.

If you believe your data has been handled unlawfully, you may complain to the Italian data protection authority, the Garante per la protezione dei dati personali, or to the supervisory authority where you live.

9. Security

The ledger is protected by the app sandbox and your device encryption. Network requests use HTTPS. The TypeSafe API key is held in the Cloudflare Worker, not in the app. Access to support email and provider dashboards is limited to the operator. No system is completely secure; if we become aware of a breach that risks your rights, we will notify you and the competent authority as the law requires.

10. International transfers

Smart capture text and purchase data are transferred to the United States. TypeSafe relies on the European Commission’s Standard Contractual Clauses and the UK IDTA; RevenueCat relies on the SCCs and the UK IDTA; Cloudflare is certified under the EU–US Data Privacy Framework and uses the SCCs where needed. You can ask us for more detail about the safeguards before relying on Smart capture.

11. Children and age

Trackly is a general-purpose tool intended for users aged 13 or over. If you are under 18, a parent or guardian must accept the Terms for you. Smart capture is intended only for users aged 18 or over, because the classification provider does not direct its service to children. We do not knowingly collect personal data from children under 13. If you believe a child has sent us data through Smart capture or support, write to [email protected] and we will delete it.

12. Cookies and this website

This website does not set cookies of its own and does not use analytics, advertising pixels or social embeds. Cloudflare Pages may process standard request metadata as described above. If that changes, this section will list the cookies and the choice you have before they are set.

13. Changes and versions

If what the app does with your data changes, this page changes with it and the version and date above move. A material change is shown in the app and, where required, you are asked to accept the new version before continuing. Previous versions are available on request from [email protected].

The English version is the authoritative version. We will publish an Italian translation; until then, if you are an Italian consumer and need the Italian text, write to us and we will provide it.