Privacy Policy

This Privacy Policy explains how AS/point Software und Beratungsgesellschaft mbH ("we," "us," or "our") collects, uses, stores, discloses, and otherwise processes information when you access or use Splitly (the mobile application) and the Splitly website at https://splitlymobile.com, and any related pages or services that link to this Privacy Policy (collectively, the "Service").

Please read this Privacy Policy carefully. By accessing or using the Service, you acknowledge that you have read and understood the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Service.

1. About the Service

Splitly is an offline-first bill splitter and shared-expense calculator for Android. It calculates shares, tracks who paid what, and suggests transfers to settle up. It does not move money: settlements are recorded by hand once they happen outside the app.

The Splitly app is designed to work without an internet connection. There is no account, no sign-in and no sync. The only network use in the app is displaying the in-app Privacy Policy and Terms of Service pages.

2. Scope of This Privacy Policy

This Privacy Policy applies to information processed by us in connection with the Service. It does not apply to independent third parties such as the Google Play Store, your mobile network operator, or other services you may use alongside the app, which maintain their own privacy policies.

3. Information We Collect

The information we can collect is limited, because the Service is designed to keep your data on your own device.

3.1 Information You Provide Directly

The only personal information we routinely receive is what you choose to send us when you contact us by email, for example to request support, report a bug, submit feedback, or make a privacy request. This may include your email address, your name (if you include it), and any information contained in your message or attachments.

Please avoid sending sensitive personal information unless it is necessary for us to address your request.

3.2 Technical Information When You Visit the Website

When you access the website, our hosting provider may automatically process standard technical information necessary to deliver the site and maintain its security, such as your IP address, browser type, operating system, referring URL, pages viewed, and the date and time of access. This information is processed only to operate, secure, and troubleshoot the website. We do not use it to build advertising or behavioral profiles.

3.3 Information Stored in the App

All content you create in the Splitly app — bills, splits, tips, groups, people, expenses, settlements, history, and preferences such as currency, default tip, and default head count — is stored locally on your device and is not transmitted to us. We have no access to this data. If you uninstall the app or clear its data, this information is removed from your device.

4. Information We Do Not Collect

The Service is designed so that we do not collect or process:

• account or registration information (there are no accounts);
• analytics or crash-reporting data from the app (no analytics SDKs are used);
• advertising or attribution identifiers (the app and website carry no advertising);
• precise location data;
• financial account details, payment card details, or payment information (Splitly does not process payments);
• contacts, photos, or other device content beyond what you type into the app yourself; or
• the bills, groups, or balances you record in the app (these never leave your device).

5. How We Use Information

We may use the limited information described above to:

• respond to your messages and provide support;
• investigate bugs and troubleshoot technical problems;
• operate, secure, and improve the website;
• communicate with you about matters you have contacted us about; and
• comply with applicable law and enforce our terms.

We do not use your information for behavioral advertising, profiling, or automated decision-making that produces legal or similarly significant effects.

6. Legal Bases for Processing

Where privacy laws requiring a legal basis apply (such as the GDPR), we process information:

• based on your consent, when you voluntarily contact us or where consent is otherwise required;
• based on legitimate interests, to operate and secure the Service, respond to requests, and protect our legal rights; and
• to comply with legal obligations, where applicable law requires it.

You may withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

7. How We May Disclose Information

We may disclose the limited information we process in the following circumstances:

• Service providers. Vendors that host our website or assist with email delivery may process technical or correspondence information on our behalf, only as necessary to provide their services.
• Legal and safety disclosures. When we reasonably believe disclosure is necessary to comply with law, respond to lawful requests, or protect the rights, safety, and property of users or others.
• Corporate transactions. If AS/point Software und Beratungsgesellschaft mbH is involved in a merger, acquisition, or similar transaction, information may be transferred as part of it, subject to applicable law.
• With your direction or consent. Where you specifically request or authorize a disclosure.

We do not currently use analytics providers or advertising providers for the Service.

8. We Do Not Sell Personal Information

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, because the Service does not use advertising or tracking technologies.

9. Cookies and Similar Technologies

The website does not use cookies for analytics, advertising, or tracking. The app stores your records and preferences locally on your device using standard on-device storage. Details are described in our Cookie Policy.

10. Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy. Support correspondence is retained as necessary to resolve your request and maintain appropriate records. Technical logs held by our hosting provider are retained for limited periods for security and diagnostics. Information stored in the app is retained on your device until you delete it or uninstall the app.

11. Data Security

We use reasonable administrative, technical, and organizational safeguards to protect information against unauthorized access, accidental loss, misuse, alteration, and unauthorized disclosure, including encrypted communications and restricted administrative access. However, no method of transmission or storage can be guaranteed to be completely secure, and we cannot guarantee absolute security.

12. Age Restrictions and Children's Privacy

The Service is a general-audience utility and is not directed to children under 13 (or the age of digital consent in your jurisdiction). We do not knowingly collect personal information from children in violation of applicable children's privacy laws. If you believe a child has provided personal information to us, please contact us at rfloresauoeft@gmail.com and we will take reasonable steps to delete it where appropriate.

13. Your Privacy Choices and Rights

Depending on your location and applicable law, you may have rights concerning your personal information, including the rights to access, correct, delete, restrict or object to processing, withdraw consent, and receive a portable copy of certain information. These rights are not absolute and may be subject to exceptions under applicable law. We may need to verify your identity before processing certain requests, and we will not discriminate against you for exercising your rights.

Because the app stores your records on your device only, you can exercise direct control over that data yourself: uninstalling the app or clearing its data removes your records. Requests concerning information we hold (for example, support correspondence) can be sent to:

Email: rfloresauoeft@gmail.com

14. International Data Transfers

We, our service providers, or other recipients of information may operate in countries other than the country in which you reside. Where applicable law requires safeguards for international transfers, we may rely on mechanisms such as adequacy decisions, Standard Contractual Clauses, or other legally permitted transfer mechanisms. You may contact us for additional information about applicable safeguards.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the Service, technologies we use, or legal requirements. When we do, we will revise the "Last Updated" date at the top of this page. We encourage you to review this Privacy Policy periodically.

16. Contact Us

If you have questions, concerns, complaints, or requests regarding this Privacy Policy or our privacy practices, please contact:

AS/point Software und Beratungsgesellschaft mbH
St.-Jobser-Str. 49, 52146 Würselen, Germany
Phone: +4915217497356
Application: Splitly
Website: https://splitlymobile.com
Email: rfloresauoeft@gmail.com

Important Service Disclosure

Splitly is a calculator and record-keeping tool for shared costs. It does not move, hold, or transmit money; it does not process payments; and it is not a banking, payment, or money-transfer service. Your records are stored on your device and are not uploaded to us.

For questions concerning this Privacy Policy, contact rfloresauoeft@gmail.com.