Privacy policy

Version of 14 November 2026

This privacy policy explains which personal data the DUO Wallet app and its server process, why, for how long, and which rights you have. We keep it short and concrete: we only collect what is needed to make the app work. There is no advertising, tracking or analytics software in the app, and we do not sell data.

1. Who is responsible

[Naam aanbieder] is the controller within the meaning of the General Data Protection Regulation (GDPR):

[Naam aanbieder]
[Straat en huisnummer, postcode, plaats, land]
Chamber of Commerce (KvK): [KvK-nummer]
Email: [contact@jouwdomein.nl]

For questions about privacy, or to exercise your rights, email [contact@jouwdomein.nl].

2. Three ways to use the app

Without an account. Everything you enter stays on your own device. We receive nothing, except when you use the receipt scanner or prices (see below).
With an account. Your data is stored on our server, so that it is available on more devices and you can share it with your partner in a joint household.
With your own dashboard. If you connect the app to your own server, your data goes to that server and not to us. This policy then only applies to the app itself.

3. Which data we process, and why

Account

Email address, to send you a sign-in code and to recognise your account.
With Sign in with Apple: a fixed, anonymous user code from Apple and, if you allow it, your name and email address (this may be a relay address from Apple). If we also store a key from Apple, we only use it to revoke Sign in with Apple when you delete your account.
Name that you enter yourself.
Session data: when you signed in and when your session was last used, and the kind of app (for example iOS). We only store sign-in codes, session keys and invite codes in unreadable (hashed) form.

Legal basis: performance of the contract with you (Article 6(1)(b) GDPR).

Your financial data

Everything you enter in the app yourself: income, fixed costs, transactions, budgets, assets, debts, investments, goals, trips and notes, and the names and email addresses you provide in the settings. This is kept in one document per household.

We only use this document to show it to you and the members of your household and to synchronise it between your devices.
We do not look into it, do not analyse it and do not use it for advertising or to train models.
Everyone who is a member of your household (two people at most) can see and change the whole document.

Legal basis: performance of the contract (Article 6(1)(b) GDPR).

If you enter data about someone else, for example your partner, make sure that person knows about it.

Receipt scanner

When you scan a receipt, the app sends the photo to our server. The server has the photo read by an AI model from Cloudflare (Workers AI) and sends back the shop, date, amounts and lines. The photo is only used for that single request and is not stored, not by us and not by Cloudflare for training. The result is a suggestion that you check yourself before you save it. No automated decision-making takes place.

Legal basis: performance of the contract (Article 6(1)(b) GDPR).

Prices and exchange rates

For investments and currencies the app requests prices through our server. Only the name, ticker or ISIN of an investment or a currency code is sent along, never your amounts or your account. Our server retrieves the prices from external data suppliers without sending along any data about you.

Security and preventing abuse

To prevent break-ins and abuse we briefly count sign-in attempts per email address and per IP address, and receipt scans per user. Our hosting provider keeps technical log files (such as IP address, time, address of the request and error messages), which we only use to trace malfunctions and abuse.

Legal basis: our legitimate interest in a secure service (Article 6(1)(f) GDPR).

Subscription

You buy subscriptions through the App Store. Apple processes the payment; we do not get to see your payment details. The app checks with Apple, on your device, whether you have a subscription. From Apple we only receive anonymised sales figures. Apple's privacy policy applies to the processing by Apple.

What stays on your device only

Face ID or Touch ID: this is handled by iOS. The app never gets to see your face or fingerprint, only whether unlocking succeeded.
Reminders and notifications are scheduled on your device. We do not send push notifications from our server.
Preferences such as language, currency and theme.
Backups that you make yourself are stored wherever you want.

4. How long we keep data

Account and household: as long as your account exists. If you delete your account, we immediately erase your account data, sessions and memberships. If you were the last member of a household, we also erase the document of that household.
If your partner remains a member of the household, the joint document continues to exist for your partner, including what you put in it. If you want your data to disappear from it, delete it in the app first or ask your partner.
Sign-in codes are valid for 10 minutes, invite codes for 7 days. A session expires 90 days after it was last used.
Log files are kept for 7 days at most.
Database backups: our hosting provider can restore the database up to 30 days back. Deleted data may therefore remain in those restore points for up to 30 days. We only use them to recover from a malfunction or a data breach.
Receipt photos are not kept.

5. Who we share data with

We do not sell data and only share it with:

The members of your household, because you invite them.
Cloudflare, Inc. (hosting, database, email with sign-in codes and the AI for the receipt scanner). Cloudflare is our processor and has a data processing agreement with us. Your account data and households are stored in data centres in the European Union. Requests may be routed through the nearest Cloudflare data centre, also outside the EU, and the receipt scanner may run outside the EU.
Apple, if you use Sign in with Apple or a subscription. Apple is itself responsible for that.
Authorities that may legally demand it, only if we are obliged to.

Transfers outside the EU

Cloudflare is an American company. For transfers to the United States, Cloudflare is certified under the EU-US Data Privacy Framework, and in addition the standard contractual clauses of the European Commission from the data processing agreement apply.

6. Security

All connections are encrypted (HTTPS).
Data on the server is stored encrypted.
On your device, your keys are in the iOS keychain and the local copy is encrypted by iOS. You can additionally lock the app with Face ID or Touch ID.
Codes and session keys are only stored as a hash in the database, and the number of sign-in attempts is limited.
The document is not end-to-end encrypted: our server can technically read it in order to store and synchronise it. Only those who need access for administration can reach it, and we only do so if you ask for it or if it is necessary to resolve a malfunction.

If we notice a data breach that poses a risk to you, we report it to the supervisory authority and, if the risk is high, also to you.

7. Your rights

You have the right to:

access your data;
have incorrect data corrected (most of it you can change yourself in the app);
have your data erased: delete your account in the app via Settings › Account › Delete account;
take your data with you: via Settings › Data › Download backup you download all your data as a JSON file;
have the processing restricted;
object to processing based on our legitimate interest.

Send your request to [contact@jouwdomein.nl]. We respond within one month. We may ask you to confirm that it concerns your account.

If you do not agree with how we handle your data, you can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or with the supervisory authority in the country where you live. If you live in Colombia, you have the rights under Ley 1581 de 2012 and you can turn to the Superintendencia de Industria y Comercio. We would like to hear from you first, so that we can resolve it.

8. Age

The app is intended for people aged 16 and over. We do not knowingly collect data from younger children.

9. Cookies

The app uses no cookies and no tracking. Neither do these web pages. Only if you connect the app to your own dashboard does the app store the sign-in cookie of that dashboard to keep you signed in.

10. Changes

If we change this policy, we update the date at the top. For important changes we let you know in the app in advance.