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Privacy Policy

Last updated: 9 April 2026

1. Who We Are

This Privacy Policy is issued by Spykra Technologies UK Ltd ("we", "us", "our"), the data controller for Debt Sorted. Email: support@spykra.co.uk. Website: https://spykra.co.uk/debt-sorted. We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What Data We Collect

Financial data (entered by you): Debt names, balances, interest rates, minimum payments, due dates, monthly expenses, categories and amounts, monthly income (optional), budget limits, and payment records.

Account data (if you create an account): Email address, hashed password, country and currency preferences.

Usage data (automatically collected): Daily AI query count (stored locally), app preferences.

We do NOT collect: Your real name (unless provided), bank account numbers, card numbers, National Insurance number, location data, contacts, or biometric data.

3. How and Where Your Data Is Stored

Local storage (default): All financial data is stored locally on your device in an encrypted SQLite database. This data does not leave your device unless you explicitly enable cloud sync.

Cloud sync (optional): If you enable cloud sync, your data is transmitted to our PocketBase server located in the EEA, protected using TLS 1.3.

AI features: When you use AI features, an anonymised debt summary is sent to Google's Gemini API servers. No name, email, or account details are shared with Google.

Subscription data: Managed by RevenueCat and Apple/Google. We do not receive or store payment card details.

4. Legal Basis for Processing (UK GDPR)

• Contract performance: core functionality, account creation, cloud sync
• Legitimate interests: improving the App, preventing abuse
• Consent: push notifications, AI processing
• Legal obligation: where required by law

5. How We Use Your Data

We use your data solely to provide and improve the App, sync data across devices (if enabled), generate AI responses, verify subscription status, send payment reminders (if enabled), and respond to support requests. We do NOT use your data for advertising, building marketing profiles, or selling to third parties.

6. Third-Party Services

• Google LLC (Gemini API): AI response generation. Anonymised debt summary. USA. Standard Contractual Clauses.
• RevenueCat Inc.: Subscription management. Anonymised App User ID. USA.
• Apple Inc.: App distribution, payment processing, push notifications.
• PocketBase (self-hosted): Cloud sync and authentication. EEA.

7. Your Rights Under UK GDPR

• Right of access: request a copy of your personal data
• Right to rectification: request correction of inaccurate data
• Right to erasure: request deletion (via Settings or email)
• Right to restriction: request limited processing
• Right to data portability: export in CSV or JSON format
• Right to object: object to processing based on legitimate interests
• Right to withdraw consent: for push notifications and AI at any time

Contact support@spykra.co.uk. We will respond within 30 days. You may also lodge a complaint with the ICO at ico.org.uk.

8. Data Retention

Local data is retained until you delete it or uninstall the App. Cloud data is retained while your account is active and deleted within 30 days of account deletion. AI query content is not stored on our servers.

9. Security

All data in transit is encrypted using TLS 1.3. Passwords are hashed using bcrypt. Local data is stored in an encrypted SQLite database. We do not store payment card details.

10. Children's Privacy

Debt Sorted is not intended for use by children under 18. We do not knowingly collect data from children under 18. Contact support@spykra.co.uk if you believe a child has provided us with personal data.

Legal Information

Regulatory notices and company information

Financial Disclaimer

Debt Sorted is not a regulated financial service and does not provide regulated financial advice. Spykra Technologies UK Ltd is not authorised or regulated by the Financial Conduct Authority (FCA). Nothing within the App constitutes financial advice, debt advice, legal advice, credit counselling, or insolvency advice under the Financial Services and Markets Act 2000.

All content and tools are provided for general educational and informational purposes only. Before making any significant financial decision, seek independent advice from a qualified, FCA-authorised financial adviser or a free debt advice service:

• StepChange Debt Charity — stepchange.org
• National Debtline — nationaldebtline.org
• Citizens Advice — citizensadvice.org.uk
• MoneyHelper — moneyhelper.org.uk

Governing Law

These Terms are governed by and construed in accordance with the laws of England and Wales. Any disputes arising in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

Data Protection

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

• ICO Website: ico.org.uk
• Phone: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Company Information

• Company: Spykra Technologies UK Ltd
• Registered in: England and Wales
• Email: support@spykra.co.uk
• Website: https://spykra.co.uk/debt-sorted
• App version: 1.2.0

International Data Transfers

Some third-party service providers (Google LLC, RevenueCat Inc., Apple Inc.) are based in the United States. When data is transferred outside the UK, we ensure appropriate safeguards are in place including UK International Data Transfer Agreements (IDTAs) and Standard Contractual Clauses approved by the ICO.