Privacy Policy

1. Who We Are

Budget Planner by Bottomline ("Bottomline," "the app," "we," "our," or "us") is provided by KD incubator UG (Haftungsbeschränkt). For the purposes of the General Data Protection Regulation (GDPR), KD incubator UG (Haftungsbeschränkt) is the controller responsible for the processing described in this Privacy Policy.

2. Scope of This Policy

This Privacy Policy explains how we handle personal data when you use the Bottomline iOS app, visit this website, purchase or manage a subscription, use optional online features, send feedback, or contact us by email. Apple services, including the App Store and iCloud, are operated by Apple and are also subject to Apple's own terms and privacy practices.

3. Data You Add to Bottomline

Depending on how you use the app, you may add financial and planning information such as:

• transactions, amounts, dates, notes, and categories;
• income, expenses, budgets, and recurring items;
• savings goals, balances, spending limits, and progress data;
• voice input transcripts and transaction drafts when you use voice transaction parsing;
• custom categories, preferences, and app settings;
• onboarding responses, display name, currency, and notification preferences;
• export files you choose to create from the app.

This information is used to provide the budgeting and personal finance features you choose to use. We do not use it to make credit, loan, insurance, employment, or similar eligibility decisions about you.

4. Local Storage and iCloud Sync

Bottomline is designed so your app data is stored locally on your Apple device. If you enable iCloud for the app, Apple may sync your data across devices signed in to your Apple ID. iCloud sync is controlled by your Apple device settings and your Apple account.

You can stop iCloud sync through iOS settings. Deleting the app or deleting data inside the app may not automatically delete every copy that Apple stores in iCloud backups or device backups, so you should also review your Apple iCloud and backup settings if you want to remove synced or backed-up copies.

5. Voice Input and AI Transaction Parsing

If you choose to use voice input, the app may ask for microphone and speech recognition permission. The app records your speech only while the voice input interface is active.

To turn your words into a transaction draft, Bottomline may send the transcript and the minimum context needed to understand it to our servers and a third-party AI provider. We do not intentionally send raw microphone audio to the AI provider for this feature.

Voice-generated results may be incomplete or wrong. You should review any transaction draft before saving it.

6. App Store Purchases and Subscriptions

If Bottomline offers paid features, subscriptions, trials, or other in-app purchases, purchases are processed by Apple through the App Store. Apple may process your Apple ID, payment method, billing information, tax information, purchase history, and subscription status according to Apple's policies.

We do not receive your payment card number or full billing details. The app may receive technical purchase information needed to unlock features, validate entitlement status, restore purchases, prevent fraud, and provide customer support.

For some paid or online features, we may validate that you are eligible to use the feature before processing the request.

7. Security and Abuse Prevention

To protect Bottomline, our users, and our online features, we may process technical information needed for security, fraud prevention, abuse prevention, debugging, and service reliability. This may include identifiers, request information, device or app signals, IP address, timestamps, and usage limits.

8. Contact, Support, and Feedback

If you email us or send feedback through the app, we process the information you provide, such as your email address, name, message content, feedback text, screenshots, logs, or other details you choose to include. We use this data to answer your request, troubleshoot issues, maintain records of support conversations, improve the app, and protect our legal interests.

Please avoid sending sensitive financial details unless they are necessary for your request. We will never ask you for banking passwords, card PINs, or Apple ID passwords.

9. Website Data

When you visit this website, basic technical information may be processed automatically by the hosting infrastructure, such as IP address, browser type, device information, requested URL, date and time of access, referrer, and server logs. We use this information to deliver the website, maintain security, diagnose technical problems, and understand whether the website is working properly.

We use Google Analytics and Microsoft Clarity to understand how visitors find and use the website, including page views, App Store link clicks, referring pages, approximate device and browser information, heatmaps, and session recordings. We use this information to improve the website and measure whether it helps visitors reach the App Store.

We do not intentionally use this website to collect your financial app data, and you should not enter financial details into website analytics tools or recordings.

10. Notifications, Diagnostics, Analytics, and Feedback Tools

If you enable notifications, Bottomline may use the notification features of your device to remind you about budgets, recurring items, or app activity. You can manage notification permission in iOS settings.

Depending on the app version and your settings, diagnostic, analytics, or feedback information may be processed to help identify crashes, performance problems, feedback themes, and feature usage. This may include device and app information, crash logs, error information, general usage events, and feedback content you submit. We use this information to keep the app reliable and improve the product.

11. Legal Bases Under GDPR

Where GDPR applies, we process personal data on the following legal bases:

• Contract performance: to provide the app, maintain subscriptions, unlock paid features, process optional feature requests, and respond to service requests.
• Legitimate interests: to secure and improve the app and website, prevent abuse, fix bugs, and communicate with users.
• Consent: where required, for optional features such as certain diagnostics, analytics, notifications, or other optional processing.
• Legal obligations: to comply with accounting, tax, consumer protection, and other legal requirements.

12. Sharing Data With Service Providers

We do not sell your data. We may share or make data available only when needed to operate Bottomline, comply with law, or protect our rights. Relevant service provider categories may include:

• platform providers, for app distribution, purchases, device permissions, sync, and operating system features;
• infrastructure and security providers, for serving the website, operating online features, and protecting the service;
• AI service providers, for optional AI-assisted features such as voice transaction parsing;
• payment and entitlement providers, for purchase validation and subscription status management;
• website analytics providers, for understanding website usage and App Store link clicks;
• support, email, diagnostics, analytics, and feedback providers, for receiving support requests, identifying issues, and improving the app;
• authorities, courts, or advisors, where legally required or necessary to protect legal claims.

Service providers are expected to process personal data only for the purposes we instruct or for their own legally defined roles.

13. International Transfers

Some service providers may process data in countries outside your country of residence. Where GDPR applies and personal data is transferred outside the European Economic Area, we rely on appropriate legal mechanisms such as adequacy decisions, Standard Contractual Clauses, contractual safeguards, or another lawful transfer basis.

14. Retention

App data stored locally or in iCloud remains under your control until you delete it, delete the app, change sync settings, or otherwise remove it through Apple's tools. Records for online features are kept only for as long as needed to operate, secure, debug, and improve those features unless longer retention is required for misuse investigations, legal reasons, or compliance. Support emails and feedback are kept only as long as needed to answer your request, maintain business records, resolve disputes, improve the product, and comply with legal obligations. Website logs are kept for a limited period needed for security, troubleshooting, and hosting operations unless longer retention is required to investigate misuse or comply with law.

15. Your Rights

Depending on your location, you may have rights to request access, correction, deletion, restriction, portability, or objection to certain processing of your personal data. Where processing is based on consent, you may withdraw consent at any time without affecting processing that happened before withdrawal.

To exercise these rights, email us at office@kdincubator.com. You also have the right to lodge a complaint with a competent data protection authority, especially in the EU member state where you live, work, or believe an infringement occurred.

16. Children

Bottomline is not intended for children under 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us personal data, contact us and we will take appropriate steps to delete it.

17. Security

We use reasonable technical and organizational measures to protect personal data we process. No app, website, device, or cloud service can be guaranteed to be completely secure. You can help protect your data by keeping your device updated, using a strong Apple ID password, enabling device passcodes or biometric protection, and reviewing your iCloud settings.

18. Changes to This Policy

We may update this Privacy Policy when the app, website, service providers, or legal requirements change. The updated version will be posted on this page with a new "Last updated" date. If changes are material, we will take reasonable steps to notify you, such as through the app or website.

19. Contact

For privacy questions, requests, or concerns, contact:

KD incubator UG (Haftungsbeschränkt)
Schonensche Str. 13, 10439 Berlin, Germany
office@kdincubator.com