1. Controller
The controller responsible for processing personal data is:
Yarego Brozek
Wiener Straße 11
10999 Berlin
Germany
Email: brozek.yarego@gmail.com
2. Scope
This policy applies to the Violetly website and application (the “Service”), including marketing pages, free tools, accounts, and the AI assistant.
3. Data we process
Depending on how you use Violetly, we may process:
- Account data: email address, name (if provided), authentication session identifiers
- Finance data you enter: accounts, transactions, budgets, goals, holdings, plans, preferences (e.g. currency, locale, risk profile)
- AI interaction data: prompts, tool results, and conversation history needed to run the assistant
- Technical data: IP address, device/browser information, timestamps, security logs
- Acquisition data: self-reported “how did you find us”, and first-touch campaign parameters (UTM), landing path, and referrer when available
- Analytics data (only with consent): product usage events, funnels, feature adoption, and error/diagnostic events via PostHog; anonymous usage via Vercel Analytics when consented
We do not ask for government ID or payment card data in the current product. If billing is added later, this policy will be updated and the processor (e.g. Stripe) listed.
4. Purposes and legal bases (GDPR)
- Create and secure your account, send magic links, keep you signed in — Art. 6(1)(b) contract
- Provide finance tracking, investments quotes, and AI features you request — Art. 6(1)(b) contract
- Hosting, backups, abuse prevention, security — Art. 6(1)(f) legitimate interests
- Product analytics and error diagnostics with cookies/similar storage — Art. 6(1)(a) consent (and ePrivacy / TDDDG where applicable)
- Understand acquisition (self-report + UTMs) to improve the product — Art. 6(1)(f) legitimate interests; analytics cookies still require consent
- Optional product update emails (features, tips, important product changes) — Art. 6(1)(a) consent; you can change this anytime in Settings
- Comply with law, respond to requests — Art. 6(1)(c) legal obligation
You may withdraw analytics consent at any time (cookie banner before sign-in, or Settings after). Withdrawal does not affect prior lawful processing. You may also turn off product update emails in Settings.
5. Essential vs optional cookies
Essential (no consent required): session/auth cookies required to sign in and operate the Service (Better Auth).
Optional (consent required): PostHog product analytics cookies/local storage; Vercel Analytics when enabled under consent. Advertising pixels are not used today.
6. Processors and partners
We use service providers that process data on our instructions:
- Neon — PostgreSQL database hosting (account and finance data)
- Vercel — application hosting and (with consent) Vercel Analytics
- Resend — transactional email (magic links, account deletion confirmation) and, when you opt in, product update emails
- Google (Gemini / Google AI) — processes prompts and related context to power the Violetly assistant and transcription features you use
- Alpha Vantage — market data / symbol search / quotes for investment features you use (typically symbols and request metadata, not your full ledger)
- PostHog — product analytics and error diagnostics only when you consent
Providers may process data in the EU and/or third countries (including the United States). Where required, we rely on appropriate safeguards such as Standard Contractual Clauses.
7. Retention
- Account and finance data: until you delete your account, or sooner if you request erasure where applicable
- Auth sessions: until expiry or sign-out
- AI conversations: retained while your account exists (or until you delete them / the account)
- Analytics events: per PostHog/Vercel retention settings while consent is active
- Acquisition fields: retained with the account for product measurement
After account deletion we remove or anonymize personal data within a reasonable period, except where law requires longer retention.
8. Your rights
If you are in the EEA/UK (and similar regimes), you may have rights to access, rectification, erasure, restriction, portability, and objection, and the right to withdraw consent.
In-app: Settings → delete account (GDPR right to be forgotten for account data we control).
You may lodge a complaint with a supervisory authority (in Germany, typically your Landesdatenschutzbehörde / BfDI).
9. Children
Violetly is not directed at children under 16. Do not use the Service if you are under the age required in your country.
10. Changes
We may update this policy. The Last updated date above will change. Material changes may also be communicated in-product or by email when appropriate.
11. Contact
Privacy questions: brozek.yarego@gmail.com