Privacy Policy for the App

This privacy policy applies to the Festen app. It explains which personal data we process when you use the app, for what purposes, on what legal basis, and with whom it is shared. Festen is an app for recording your finances manually. You enter your numbers yourself. Festen does not connect to your bank account and does not retrieve transactions. Data processing on the festen.app website is described separately in the website privacy policy.

Controller

The party responsible for data processing in the app is:

Wamb’s Consulting, owner Poclaire Wamba, trading as Festen App
Knesebeckstraße 63, 10719 Berlin, Germany
Email: kontakt@festen.app
Phone: 0176 47358408

We are not legally required to appoint a data protection officer and have not done so. For any data protection questions, reach us at kontakt@festen.app.

Legal bases at a glance

Most processing in the app is necessary to provide you the app you requested when you entered into the user agreement; the legal basis is Art. 6(1)(b) GDPR. Where we obtain your consent for a particular feature, the basis is Art. 6(1)(a) GDPR. Where we are subject to a legal obligation, such as tax retention obligations for billing data, the basis is Art. 6(1)(c) GDPR. Where processing is necessary for legitimate interests, such as the security of the app, the basis is Art. 6(1)(f) GDPR.

What data we process

Account and sign-in data. For your account we process your email address and the details needed to sign in. Sign-in works without a password, via a code sent by email, or via "Sign in with Google" or "Sign in with Apple". More on these sign-in routes below. The purpose is to set up and secure your account. The legal basis is Art. 6(1)(b) GDPR.

Your entries. The core of the app is the information you enter yourself: income and spending with amount, category, description, date, and the marking as a need or a want, together with your goals and loans. This information can allow conclusions about your financial situation and is treated by us with corresponding care. It stays in your account and serves solely to show you your overview in the app. The legal basis is Art. 6(1)(b) GDPR.

Receipt images (only if you scan). If you use the optional receipt-scanning feature, the image of the receipt is processed in order to take the relevant details from it, such as the amount. This processing happens only when you actively trigger it. Details of the transfer to our service provider are in the "Scanning receipts" section.

Subscription and purchase data. To manage your subscription we process its status (such as whether the free access period is running or a subscription is active). The purchase itself is handled through Apple’s App Store; Apple is the seller and payment processor. We do not receive payment data such as card numbers. The legal basis is Art. 6(1)(b) GDPR.

Technical data. To operate and secure the app, technical data arises, such as device and connection data and logs relating to errors and account security. The legal basis is our legitimate interest in a secure and functional app under Art. 6(1)(f) GDPR and contract performance under Art. 6(1)(b) GDPR.

Sign-in and account management (Clerk, Google, Apple)

We handle sign-in and account management through the service Clerk, provider Clerk, Inc., 660 King Street, Unit 345, San Francisco, CA 94107, USA. Clerk processes your email address and sign-in information on our behalf so you can sign in without a password. The legal basis is Art. 6(1)(b) GDPR. A data processing agreement is in place with Clerk; processing in the USA is possible, see the section "Transfers to third countries".

If you choose "Sign in with Google", Google confirms your identity to the app. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Personal data may be transmitted to Google and processed by Google LLC in the USA. Google’s privacy notice applies additionally.

If you choose "Sign in with Apple", Apple confirms your identity to the app. The provider is Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA (for users in the EEA the provider is Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, T23 YK84, Ireland). Apple offers the option to hide your email address and use an anonymised relay address. Apple’s privacy notice applies additionally.

Storage of your entries (Convex)

Your account and entry data is stored and processed by our backend provider Convex, provider Convex, Inc., 444 De Haro Street, Suite 218, San Francisco, CA 94107, USA. We use Convex so that your data is stored in a region within the European Union. Convex processes this data solely on our behalf in order to provide the app. The legal basis is Art. 6(1)(b) GDPR. A data processing agreement is in place with Convex. Where the provider, as a US company, may access data in individual cases, for example for maintenance, we rely on the safeguards stated in the section "Transfers to third countries".

Subscription (Apple App Store, RevenueCat)

The subscription is concluded and billed through Apple’s App Store. Apple is the seller and payment processor; Apple’s terms and privacy notice apply, and we do not receive any payment data. To manage the subscription status in the app, we use the service RevenueCat, provider RevenueCat, Inc., 1032 E Brandon Blvd #3003, Brandon, FL 33511, USA. RevenueCat processes a pseudonymous identifier and the status of your subscription on our behalf, so the app knows whether your free access period is running or a subscription is active. The legal basis is Art. 6(1)(b) GDPR. A data processing agreement is in place with RevenueCat; processing in the USA is possible.

Scanning receipts (Anthropic)

Scanning a receipt is an optional feature. Only if you actively use it, the image of the receipt is transmitted to our service provider Anthropic, which reads the relevant details from it, such as the amount, so you can take them into an entry. The provider is Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA. Anthropic processes the image solely for this purpose on our behalf and uses Amazon Web Services as a sub-processor. The processing serves to provide the feature you requested under Art. 6(1)(b) GDPR; the associated transfer to the USA is explained in the section "Transfers to third countries". If you do not scan a receipt, no such transfer takes place.

What we deliberately do not do

Festen does not connect to your bank account and does not retrieve transactions. The app contains no advertising and no tracking or analytics services that evaluate your behaviour in the app. We do not sell your data. Every number in the app comes from your own entries.

Exporting and deleting your data

You can export your data as a file and take it with you at any time in the app. You can delete your account and the associated data at any time in the app. After deletion we remove your data, unless a statutory retention obligation applies; in that case we restrict processing until the period expires.

Transfers to third countries

Some of the providers we use are US companies or may process personal data in the USA, namely Clerk, RevenueCat, and Anthropic, and, depending on the sign-in route, Google and Apple. We use Convex with storage in the EU; access from the USA cannot be ruled out in individual cases. The USA is not consistently regarded as offering a level of data protection equivalent to EU law. Where a transfer takes place, we base it on the European Commission’s standard contractual clauses under Art. 46(2)(c) GDPR and, where applicable, on the recipient’s certification under the EU-US Data Privacy Framework. For the optional receipt feature, by using it you additionally consent to the transfer under Art. 49(1)(a) GDPR. We provide copies of the safeguards on request via kontakt@festen.app.

Retention period

We process your account and entry data for as long as your account exists. If you delete your account, the data is removed unless a statutory retention obligation applies. Billing-related data may be subject to statutory retention periods; for that period, processing is restricted to the retention purpose. Receipt images are transmitted solely to read the details from them and are not stored in your account.

Minimum age

Festen is intended for adults and is not directed at children. By using it you confirm that you have reached the minimum age required under the terms of use.

Your rights

Under the GDPR you have the right to access the data we process about you (Art. 15), to rectification of inaccurate data (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18), to data portability (Art. 20), and a right to object (Art. 21). Where processing is based on your consent, you can withdraw it at any time with future effect; the lawfulness of processing carried out until then is unaffected. You can exercise many of these rights directly in the app, for example through export and deletion; otherwise a message to kontakt@festen.app is enough.

Right to object

Where we process data on the basis of our legitimate interest under Art. 6(1)(f) GDPR, you have the right to object at any time, on grounds relating to your particular situation, to that processing. We will then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves to assert, exercise, or defend legal claims.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority about how we process your personal data. The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59-61, 10555 Berlin, Germany. You may also contact the supervisory authority where you usually reside.

Changes to this privacy policy

We update this privacy policy when our data processing in the app changes or legal requirements change. The version published in the app and on festen.app applies.