Privacy Policy

1. Data Controller

2. Personal data we collect

We collect only the data strictly necessary to provide the service:

3. Processing purposes

• Manage registration, authentication and access to the app via email and password.
• Provide the personal finance management, wealth tracking and investment analysis service.
• Manage Neto PRO subscriptions via the Apple App Store (iOS) or Google Play (Android), depending on the platform, and RevenueCat.
• Send transactional communications: password reset, security alerts, legal changes.
• Retrieve public market price data from external providers (no personal data is sent to those providers).
• Automatically log your Google Pay expenses on Android, only if you enable that feature and grant notification access (see section 10b).
• Maintain service security via IP-based rate limiting (anonymised).
• Measure, in pseudonymised form, how the app is used in order to improve it (Amplitude), unless you turn it off in Settings.
• Know which person or content creator invited you, if you tell us or arrive through their link, to measure recommendations and campaigns.
• Send you logging reminders adapted to how you use Neto, as often and at the time that suit you best (see section 10c).
• Answer the questions you send us through the website support chat (Crisp), only if you open it.
• Understand what you dictate (in the app or with Siri) to fill in a transaction, only when you use that feature (see section 10d).

4. Legal basis (GDPR)

5. Data retention

• We retain your data while your account remains active.
• You may request full account and data deletion at any time from within the app or by emailing hello@netoapp.es. See the detailed steps in Delete your account and data.
• After a deletion request, we will erase your data within 30 days, unless a legal retention obligation applies.
• PRO subscription data is retained for the minimum period required by Spanish tax and commercial law (at least 5 years).
• Anonymised IPs used for rate limiting are automatically deleted after 24 hours.
• Invitation data is stored with your account and deleted with it. If the person who invited you deletes their account, their code is also removed from yours.
• Usage data sent to Amplitude is kept while your account is active. If you delete your account or ask us at hello@netoapp.es, we request Amplitude to erase the data linked to you.
• The history of reminders sent is kept for up to 400 days. If your account has had no activity for more than a year, we stop sending you reminders.
• Support chat conversations are kept for as long as they are useful to answer your question. You can ask us to delete them at hello@netoapp.es.

6. Recipients and data processors

We do not sell, rent, or share your personal data with third parties for commercial purposes. Our data processors are:

7. International data transfers

The core service (backend and database) is hosted within the European Union (Frankfurt, Germany) and does not involve any transfer outside the EEA.

For providers located outside the EEA (Resend, RevenueCat, Amplitude, Google, Expo and Twelve Data), transfers are covered by the Standard Contractual Clauses (SCC) approved by the European Commission via Implementing Decision 2021/914 of 4 June 2021. You may request a copy of the applicable safeguards by writing to hello@netoapp.es.

The market price providers (Marketstack, Financial Times, CoinGecko, Twelve Data and Yahoo Finance) only receive the symbol or ISIN of the asset being queried (e.g. "AAPL" or a fund ISIN), with no personal user data.

To suggest the category of a payment logged automatically through Wallet or Google Pay, Neto first uses the one you chose before for that merchant and, if there is none, the one other users choose most for that same merchant, in aggregated and anonymous form: it only counts when at least three different people agree, nobody sees what someone else chose, and your choice is deleted when you delete your account. It all happens on Neto's servers; nothing is sent to any third party.

8. Your rights (GDPR)

To exercise your rights, email us at hello@netoapp.es, including proof of identity. We will respond within one month (extendable by two further months for complex cases).

If you believe your data is being processed unlawfully, you may lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

9. Cookies and similar technologies

This website sets no cookies when you visit it. None of ours and none from third parties: there are no session, authentication, analytics or advertising cookies, and we store nothing in your browser except in the two cases explained below, the second one only if you ask for it.

To measure traffic we use Umami, cookieless analytics that writes nothing to your device and creates no identifier that could follow you across sites. That is why we do not ask for prior consent to set cookies: visiting the site sets none.

The one exception is the /download/ page, the link some creators use to recommend the app: it generates a random identifier and saves it to your browser's localStorage so the same click doesn't get counted twice if you reload the page before the store opens. It isn't a cookie, it doesn't identify who you are, it goes nowhere except that one click record, and it disappears if you clear your browser data.

Support chat. There is a button in the corner of every page to write to us. Until you click it, nothing from a third party loads. When you click it, Crisp (Crisp IM SAS, France) loads and stores cookies and localStorage data in your browser to keep the conversation going across pages and visits (for example, crisp-client/session). They are needed to provide the service you have just asked for, so they do not require prior consent (art. 22.2 of the Spanish LSSI). If you would rather nothing is stored, don't open the chat and email us at hello@netoapp.es. If you already opened it, clearing your browser data removes them, and you can ask us to delete the conversation at that same address.

The mobile app does store information on your phone in order to work (your transactions, your categories, your settings), but that is the app's own storage, not web cookies, and it is covered in the sections above.

10. Apple App Tracking Transparency (ATT)

10b. Automatic expense capture with Google Pay (Android only)

On Android devices, Neto offers an optional feature, switched off by default, called «Add expenses automatically», which logs your Google Pay payments so you don't have to enter them manually.

Legal basis: your explicit consent (art. 6.1.a GDPR), given when you enable the feature and grant the permission; you can withdraw it at any time without affecting the rest of the service. This feature is not available on iOS.

10c. Logging reminders adapted to how you use Neto

Neto may send you a notification such as "have you logged today's spending?" so you don't forget to record your expenses. It is not the same reminder for everyone: we adapt it to how you use Neto, so it arrives as often and at the time that suit you best, and it stops if it isn't useful to you.

Legal basis: legitimate interest (art. 6.1.f GDPR) in reminding you to use the service you yourself use, together with the notification permission you grant on your device. You can object at any time by turning it off as described above.

10d. Adding expenses by voice

Neto lets you log an expense or income by speaking: by tapping the microphone on the add screen, or by telling Siri, for example, “Note an expense in Neto”.

Legal basis: performance of the contract (art. 6.1.b GDPR). It is one more way to enter your transactions, active only when you use it. It adds no new data processor: speech recognition is provided by your device's operating system.

11. Security measures

• Passwords are stored using argon2 hashing, never in plain text.
• All communications are encrypted via HTTPS/TLS.
• The backend and database are hosted within the European Union (Frankfurt, Germany, Render Inc.). Core service data does not leave the EEA.
• The authentication token is stored securely and bound to the device: on iOS, in Apple Keychain with the kSecAttrAccessibleAfterFirstUnlockThisDeviceOnly attribute, preventing it from entering iCloud backups; on Android, encrypted with a key kept in the device's own Android Keystore.
• The app applies a neutral overlay in the app switcher so account balances are not visible in multitasking.
• IPs are anonymised before any storage (/24 for IPv4, /48 for IPv6).
• Sessions have time-based expiration and single-session enforcement.

In the event of a security incident affecting your personal data, we will notify you as required by GDPR articles 33 and 34.

12. Minors

Neto App is not intended for users under 16 years of age. We do not knowingly collect data from minors. If you are a parent or guardian and believe a minor has provided us with personal data, please contact us at hello@netoapp.es and we will promptly delete it.

13. Marketing communications

We only send transactional communications (password reset, security alerts, material legal changes). Occasionally, we may send a single communication announcing a major version release, considered essential service information and grounded in contract performance (art. 6.1.b GDPR). We do not run email marketing campaigns or newsletters without your explicit consent.

14. Changes to this policy

We may update this Privacy Policy to reflect legal, technical, or service changes. Substantial changes will be communicated through the app or by email with reasonable advance notice. The last update date is always shown at the top of this document.

15. Contact

For any privacy or data protection queries: hello@netoapp.es