This Privacy Policy explains how PivotalPoint OÜ ("we", "us", or "our") collects, uses, and protects your personal data when you use ClearRecord (the "Service").

1. Data Controller

Legal entity: PivotalPoint OÜ
Country of incorporation: Estonia
Registry code: 16951192
Contact email: clearrecord@pivotalpoint.io

2. Data We Collect

We collect the following types of data:

ClearRecord acts as a technical processor of user-submitted content and does not verify its accuracy or legality.

2.1 Account Information

Email address
Display name (if provided)
Authentication data (managed by Firebase Authentication)

2.2 Expense and Record Data

Data entered by users into the Service, which may include personal data relating to them or third parties, such as:

Expense descriptions and amounts
Categories and dates
Split rules and calculations
Approval status and history

2.3 Usage Data

Pages visited and features used
Device type and browser information
IP address (anonymized)
Language preferences

3. How We Use Your Data

We use your personal data for the following purposes:

Service provision: To create and manage your account, process expense records, and enable collaboration with your co-parent
Communication: To send service-related notifications and respond to your inquiries
Analytics: To understand how the Service is used and improve it (with your consent)
Legal compliance: To comply with applicable laws and regulations

4. Legal Basis for Processing

Under GDPR, we process your data based on:

Contract: Processing necessary to provide the Service you requested
Consent: For analytics cookies and marketing communications (where applicable)
Legitimate interest: For security, fraud prevention, and service improvement
Legal obligation: Where required by law

5. Cookies and Tracking

We use the following types of cookies:

5.1 Strictly Necessary Cookies

These cookies are essential for the Service to function and cannot be disabled:

Authentication cookies: To keep you logged in
Language preference: To remember your language selection

5.2 Analytics Cookies (Consent Required)

With your consent, we use Google Analytics to understand how visitors use our Service:

Page views and navigation patterns
Device and browser information
Geographic location (country level)

IP addresses are anonymized before storage and are not accessible to us.

You can withdraw your consent at any time by clearing your browser cookies and revisiting our site.

6. Data Sharing

We share your data with:

Your co-parent: Expense data you create is shared with invited workspace members
Service providers:
- Firebase (Google) - Authentication and database hosting
- Google Analytics - Usage analytics (with consent)
Legal authorities: When required by law or to protect our rights

We do not sell your personal data to third parties.

7. Data Retention

Account data: Retained while your account is active, deleted within 30 days of account deletion request
Expense records: Retained as long as the workspace exists, as they form part of the immutable ledger
Analytics data: Retained for 14 months (Google Analytics default)

Due to the immutable, append-only nature of shared financial records, certain data entered into a workspace may not be erasable without affecting the integrity of the record. In such cases, we will restrict processing and access rather than delete historical entries, as permitted under Article 17(3) GDPR.

8. Your Rights (GDPR)

Under GDPR, you have the following rights:

Access: Request a copy of your personal data
Rectification: Request correction of inaccurate data
Erasure: Request deletion of your data ("right to be forgotten")
Restriction: Request limitation of processing
Portability: Receive your data in a structured, machine-readable format
Objection: Object to processing based on legitimate interest
Withdraw consent: Withdraw consent for analytics at any time

To exercise these rights, contact us at clearrecord@pivotalpoint.io.

9. Data Security

We implement appropriate technical and organizational measures to protect your data, including encryption in transit (HTTPS), secure authentication, and access controls. Our infrastructure is hosted on Google Cloud Platform through Firebase.

10. International Transfers

Your data may be processed in countries outside the European Economic Area (EEA). This includes transfers to Google LLC (United States) as part of our use of Firebase and Google Cloud services. Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

11. Children's Privacy

ClearRecord is intended for adults managing shared child expenses. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last updated" date. Continued use of the Service after changes constitutes acceptance of the updated policy.

13. Complaints

If you have concerns about how we handle your data, please contact us first. You also have the right to lodge a complaint with a supervisory authority, such as the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

14. Contact Us

For privacy-related questions or requests, contact:

PivotalPoint OÜ
Email: clearrecord@pivotalpoint.io