Terms of Service
Last updated: 18 April 2026
1. About Us
Debt Sorted is a product of Spykra Technologies UK Ltd, a company registered in England and Wales. Website: https://spykra.co.uk/debt-sorted. Support: support@spykra.co.uk. References to "we", "us", "our", or "Debt Sorted" in these Terms refer to Spykra Technologies UK Ltd.
2. Acceptance of Terms
By downloading, installing, accessing, or using the Debt Sorted mobile application ("the App"), you agree to be legally bound by these Terms of Service and our Privacy Policy. If you do not agree to these Terms, you must not download, install, or use the App. These Terms apply to all users of the App, including those without a registered account.
3. Eligibility
You must be at least 18 years of age to use Debt Sorted. By using the App, you represent and warrant that you are 18 or older. The App is intended for personal financial management only. It must not be used for commercial, professional, or business financial advice purposes.
4. Description of Service
Debt Sorted is a personal debt management application that allows users to:
- Track personal debts including credit cards, loans, mortgages, and other liabilities
- Monitor monthly expenses and spending categories
- Model debt repayment strategies (Avalanche, Snowball, and custom methods)
- View projected debt-free dates and what-if scenarios
- Create and manage monthly budgets
- Access AI-powered debt coaching and personalised advice
- Generate creditor letters and financial documents
- Sync data securely across devices via optional cloud backup
- Export financial data in CSV and JSON formats (Pro feature)
- Track minimum payment traps and interest costs
The App is an informational and organisational tool only and does not constitute regulated financial advice.
5. Important 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 or any other applicable legislation.
All content, calculations, projections, and AI responses are provided for general educational and informational purposes only. Financial projections are estimates based on user-entered data and standard mathematical models; actual outcomes will vary. Before making any significant financial decision, you should seek independent advice from a qualified FCA-authorised financial adviser or a free debt advice service such as:
6. AI-Powered Features
The App's AI features are powered by Google Gemini (Google LLC). By using AI features, you acknowledge and agree that:
- AI responses are generated automatically and are not verified for accuracy
- AI responses are not a substitute for professional financial, legal, or debt advice
- AI responses may contain errors, omissions, or outdated information
- An anonymised summary of your debt data (debt names, balances, interest rates, minimum payments) is transmitted to Google's servers to generate responses
- No personally identifiable information (name, email, address) is sent to Google
- Free users are limited to 25 AI queries per day; Pro subscribers receive a higher daily allowance. Limits reset at midnight UTC
- We reserve the right to modify or discontinue AI features at any time
7. Debt Sorted Pro — Subscriptions and In-App Purchases
Debt Sorted Pro unlocks premium features including unlimited AI queries, data exports, advanced reports, and more. Pro is available as:
- Monthly subscription: billed monthly, auto-renews unless cancelled
- Annual subscription: billed annually, auto-renews unless cancelled
- Lifetime purchase: one-time payment for permanent access
All purchases are processed through Apple's App Store (iOS) or Google Play (Android) using their respective payment systems. Subscriptions automatically renew at the end of each billing period unless cancelled at least 24 hours before the renewal date. You can manage or cancel your subscription at any time in your device's App Store or Play Store settings. Refunds are handled entirely by Apple or Google in accordance with their respective refund policies. We do not process refunds directly. We reserve the right to change pricing with reasonable advance notice.
8. User Account
Creating an account is optional. An account is required to use cloud sync features. If you create an account, you agree to:
- Provide accurate and complete registration information
- Keep your login credentials confidential and secure
- Not share your account with any other person
- Notify us immediately of any unauthorised access at support@spykra.co.uk
You are solely responsible for all activity that occurs under your account. We reserve the right to suspend or terminate accounts that violate these Terms.
9. Account Deletion
You may delete your account at any time from within the App (Settings → Delete Account & Data). Upon deletion, all cloud-stored data associated with your account will be permanently deleted within 30 days. Local device data must be cleared separately via Settings → Delete All Data.
10. Acceptable Use
You agree not to use the App to:
- Violate any applicable law or regulation
- Input false or misleading financial information with intent to harm
- Attempt to reverse-engineer, decompile, or extract source code from the App
- Generate fraudulent creditor letters or financial documents
- Circumvent daily usage limits or other technical restrictions
- Gain unauthorised access to our systems or servers
- Use the App for any commercial purpose without our prior written consent
- Transmit any malware, viruses, or harmful code
11. Intellectual Property
All content, branding, design, software, and functionality of Debt Sorted are owned by or licensed to Spykra Technologies UK Ltd and are protected by UK and international intellectual property laws including copyright and trade mark law. You are granted a limited, non-exclusive, non-transferable, revocable licence to use the App for personal, non-commercial purposes only. Nothing in these Terms transfers any intellectual property rights to you.
12. Third-Party Services
The App integrates with the following third-party services, each governed by their own terms and privacy policies:
- Google LLC (Gemini API): AI response generation
- RevenueCat Inc.: Subscription and purchase management
- Apple Inc. / Google LLC: App distribution and payment processing
- PocketBase (self-hosted): Optional cloud sync and authentication
We are not responsible for the availability, accuracy, or content of any third-party service.
13. Disclaimer of Warranties
THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, OR NON-INFRINGEMENT. We do not warrant that the App will be uninterrupted, error-free, or free of viruses or other harmful components. We do not warrant the accuracy of any financial calculations, projections, or AI-generated content.
14. Limitation of Liability
To the fullest extent permitted by applicable law, Spykra Technologies UK Ltd shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from or relating to your use of or inability to use the App, including but not limited to financial losses, loss of data, loss of profits, or any decisions made based on information provided by the App. Our total aggregate liability for any claim arising out of or relating to these Terms or the App shall not exceed the total amount paid by you to us in the 12 months preceding the claim, or £10 if no payment has been made.
Nothing in these Terms limits or excludes our liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be limited or excluded under applicable law.
15. Indemnification
You agree to indemnify, defend, and hold harmless Spykra Technologies UK Ltd, its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in any way connected with your access to or use of the App, your violation of these Terms, or your violation of any third-party rights.
16. Changes to Terms
We reserve the right to modify these Terms at any time. We will notify users of material changes via the App or email. Continued use of the App after changes take effect constitutes your acceptance of the revised Terms. The "Last updated" date at the top of this page indicates when these Terms were last revised.
17. Termination
We reserve the right to suspend or terminate your access to the App at any time, with or without cause, with or without notice. Upon termination, your right to use the App immediately ceases. Provisions of these Terms that by their nature should survive termination shall survive, including intellectual property, disclaimers, and limitation of liability.
18. Governing Law and Dispute Resolution
These Terms are governed by and construed in accordance with the laws of England and Wales. Any disputes arising in connection with these Terms or the App shall be subject to the exclusive jurisdiction of the courts of England and Wales. For complaints or disputes, please contact us first at support@spykra.co.uk so we can attempt to resolve the matter informally.
19. Contact
Spykra Technologies UK Ltd
Email: support@spykra.co.uk
Website: https://spykra.co.uk/debt-sorted
Privacy Policy
Last updated: 18 April 2026
1. Who We Are
This Privacy Policy is issued by Spykra Technologies UK Ltd ("we", "us", "our"), the data controller for the Debt Sorted mobile application. Registered in England and Wales. Email: support@spykra.co.uk. Website: https://spykra.co.uk/debt-sorted.
We are committed to protecting your privacy. 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, types, balances, interest rates, minimum payments, and due dates
- Monthly expenses, spending categories, and amounts
- Monthly income (optional)
- Budget limits per spending category
- Payment records and transaction history
Account data (only if you create an account):
- Email address
- Display name (optional)
- Hashed password (we never store plaintext passwords)
- Country and currency preferences
Usage data (stored locally on your device):
- Daily AI query count
- App preferences (dark mode, notification settings)
We do NOT collect:
- Bank account numbers or sort codes
- Credit or debit card numbers
- National Insurance number or tax identification numbers
- Precise location data
- Contacts or address book
- Biometric data
- Device identifiers (IDFA, IMEI)
- Browsing history or cross-app tracking data
3. How and Where Your Data Is Stored
Local storage (default for all users): All financial data is stored locally on your device in an SQLite database. This data never leaves your device unless you explicitly enable cloud sync. No financial data is transmitted during normal use of the App without your action.
Cloud sync (optional, account required): If you choose to enable cloud sync, your financial data and account information are transmitted to and stored on our self-hosted PocketBase server. Our server is located within the European Economic Area (EEA). All data is transmitted using TLS 1.3 encryption.
AI features: When you use AI-powered features, an anonymised debt summary (debt names, balances, interest rates, minimum payments) is sent to Google's Gemini API. No name, email address, account credentials, or other personally identifiable information is sent to Google. AI query content is not stored on our servers.
Subscription and purchase data: Managed by RevenueCat Inc. and Apple Inc. (App Store) or Google LLC (Play Store). We do not receive, process, or store any payment card details. RevenueCat receives an anonymised App User ID to track subscription status.
4. Legal Basis for Processing (UK GDPR)
- Contract performance (Article 6(1)(b)): Core App functionality, account creation, cloud sync, and subscription management
- Legitimate interests (Article 6(1)(f)): Improving App performance, preventing abuse, and ensuring security
- Consent (Article 6(1)(a)): Push notification delivery, AI data processing
- Legal obligation (Article 6(1)(c)): Where required by applicable law
5. How We Use Your Data
We use your data solely to:
- Provide the core functionality of the App
- Sync your data across your devices (if cloud sync is enabled)
- Generate AI-powered debt advice and coaching responses
- Verify your subscription status with RevenueCat
- Send push notification payment reminders (if enabled by you)
- Respond to support requests and enquiries
- Improve the App's performance and functionality
We do NOT use your data for:
- Advertising or targeted marketing
- Building marketing profiles
- Selling to or sharing with third parties for commercial purposes
- Automated decision-making with legal or similarly significant effects
6. Third-Party Services and Data Sharing
We share data with the following third parties only to the extent necessary to provide the App's functionality:
- Google LLC (Gemini API): Receives anonymised debt summaries to generate AI responses. Data processed in the USA. Google's standard contractual clauses and data processing agreements apply. Google Privacy Policy
- RevenueCat Inc.: Receives an anonymised App User ID to manage subscription entitlements. Data processed in the USA. RevenueCat Privacy Policy
- Apple Inc.: Processes App Store purchases and push notifications. Governs its own data practices. Apple Privacy Policy
- PocketBase (self-hosted by us): Stores account data and synced financial data when cloud sync is enabled. Hosted within the EEA.
We do not sell, rent, or trade your personal data to any third party.
7. International Data Transfers
Google LLC and RevenueCat 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 (SCCs) approved by the Information Commissioner's Office (ICO).
8. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Request correction of inaccurate or incomplete data
- Right to erasure ("right to be forgotten"): Request deletion of your personal data — available directly in the App (Settings → Delete Account & Data or Delete All Data) or by emailing us
- Right to restriction: Request that we limit the processing of your data
- Right to data portability: Export your data in CSV or JSON format directly from the App (Settings → Export or Reports → Export)
- Right to object: Object to processing based on legitimate interests
- Right to withdraw consent: Withdraw consent for push notifications (via device settings) or AI processing (by not using AI features) at any time
To exercise any of these rights, contact us at support@spykra.co.uk. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
9. Data Retention
- Local data: Retained on your device until you delete it via Settings or uninstall the App
- Cloud account data: Retained while your account is active. Permanently deleted within 30 days of account deletion
- AI query content: Not stored on our servers. Transmitted to Google for processing only
- Support communications: Retained for up to 2 years for dispute resolution purposes
10. Security
We take the security of your data seriously and implement appropriate technical and organisational measures including:
- TLS 1.3 encryption for all data in transit
- bcrypt hashing for passwords
- SQLite database with encryption for local data storage
- No storage of payment card details at any point
- Regular review of third-party service security practices
Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.
11. Push Notifications
If you enable push notifications, we use Apple Push Notification Service (APNs) or Firebase Cloud Messaging (FCM) to deliver debt payment reminders to your device. You can disable push notifications at any time in your device settings. We do not use push notifications for marketing purposes.
12. Children's Privacy
Debt Sorted is not intended for use by children under 18 years of age. We do not knowingly collect personal data from anyone under 18. If you believe that a child under 18 has provided us with personal data, please contact us at support@spykra.co.uk and we will take steps to delete such information promptly.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any significant changes via the App or by email. The "Last updated" date at the top of this policy indicates when it was last revised. Continued use of the App after changes take effect constitutes your acceptance of the revised policy.
14. Contact Us
For any privacy-related questions, requests, or complaints:
Spykra Technologies UK Ltd
Email: support@spykra.co.uk
Website: https://spykra.co.uk/debt-sorted
Legal Information
Regulatory notices and company information
Company Information
Financial Services 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 or any other applicable legislation.
All content and tools are provided for general educational and informational purposes only. Financial calculations and projections are estimates only. Actual results will vary based on individual circumstances, lender policies, and other factors outside our control. Before making any significant financial decision, seek independent advice from a qualified, FCA-authorised financial adviser or a free debt advice service:
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 or the App shall be subject to the exclusive jurisdiction of the courts of England and Wales.
Data Protection and ICO
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):
- Website: ico.org.uk
- Phone: 0303 123 1113
- Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Apple App Store — Subscription Information
Debt Sorted Pro subscriptions purchased through the Apple App Store are subject to Apple's terms and conditions. Subscriptions auto-renew unless cancelled at least 24 hours before the end of the current billing period. You can manage and cancel subscriptions in your Apple ID account settings. Apple handles all billing and refunds in accordance with their policies.
- Manage subscriptions: Settings → [Your Name] → Subscriptions
- Apple refund policy: support.apple.com
International Data Transfers
Some third-party service providers (Google LLC, RevenueCat Inc., Apple Inc.) are based in the United States. When personal data is transferred outside the UK, we ensure appropriate safeguards are in place including UK International Data Transfer Agreements (IDTAs) and Standard Contractual Clauses (SCCs) approved by the ICO.
⚠️ Important Notice
Debt Sorted is not a regulated financial service. The App and its content are for informational and organisational purposes only. Always seek independent advice from a qualified financial adviser or free debt charity before making important financial decisions.
