1. What this policy covers
This Privacy Policy applies to the FreeLife website, the FreeLife mobile app for iOS and Android, related AI features, subscriptions, support, website pages, and other features that directly refer to this Policy.
This Policy does not apply to third-party websites, platforms, app stores, or services that have their own terms and privacy policies.
2. What data may be processed
2.1. Account and sign-in data
- email address;
- user identifier;
- display name;
- data received when signing in through Google or Apple;
- technical data required for authentication and account protection.
2.2. Financial user data that you enter yourself
- accounts, wallets, balances, and holdings;
- categories, budgets, limits, and budget groups;
- income, expenses, transfers, transactions, comments, and notes;
- goals, debts, deadlines, interest, amounts, and progress;
- data about your selected currency and exchange-rate conversions;
- any other data that you voluntarily enter into the app.
2.3. Images and files
If you voluntarily add images, photos, screenshots, receipt photos, statements, or other files and materials to the app, such data may be stored, processed, and used to operate the relevant features.
2.4. AI data
If you use FreeLife AI features, metrics derived from your records, aggregated financial data, prompt text, attached text, images, screenshots, receipt photos, files, voice input, other audio data, transcribed speech, AI reports, analytical conclusions, and technical service data reasonably required to generate, deliver, review, moderate, secure, and store AI responses may be processed.
This may include transfer of relevant data to third-party AI providers, backend providers, cloud providers, storage providers, moderation providers, and other infrastructure providers to the extent reasonably necessary to operate the feature that you request.
If you separately confirm consent for EVA inside the EVA chat, only data related to your EVA interactions may additionally be used to personalize and improve EVA. This may include your request, the EVA reply, related images, receipt photos, files, voice input, transcribed speech, and your indication of whether the reply was correct. A yes rating may be used for personalized memory inside your app and to better understand your phrasing. A no rating may be used for error analysis and improvement of EVA.
2.5. Subscription and purchase data
To operate subscriptions, free access, plan changes, prices, entitlements, paid feature access, and AI usage conditions, subscription status, entitlement status, technical purchase identifiers, product identifiers, storefront or platform information, country or region, renewal status, billing notices, cancellation status, plan changes, free-version limits, AI limits, and other service data reasonably required to verify, apply, administer, and update access conditions may be processed.
2.6. Technical data
- IP address;
- device type, operating system, and app version;
- system language, technical logs, error data, and diagnostics;
- push token and notification settings;
- permission states, including camera, microphone, photo, notification, storage, and biometric or local-auth states;
- stability, performance, crash, and diagnostics data;
- data required for security, abuse prevention, and technical support.
2.7. Advertising and advertising SDK data
The free version of FreeLife may display third-party ads through Google AdMob / Google Mobile Ads SDK. Standard and Premium subscriptions remove in-app advertising display where the subscription entitlement is active.
For ad delivery, measurement, fraud prevention, performance, diagnostics, and ad improvement, Google AdMob / Google Mobile Ads SDK and related advertising technology providers may collect or process data such as IP address, approximate location derived from the IP address, device identifiers including advertising identifiers where available and permitted, app or product interactions such as app launches, taps and ad views, advertising data such as ads shown to the user, crash logs, diagnostic information, performance data such as app launch time, hang rate or energy usage, and other technical data required to deliver and measure ads.
Advertising data may be used for third-party advertising, analytics, fraud prevention, ad performance measurement, security, compliance, and service improvement. Where applicable law or platform rules require consent or a tracking permission, such consent or permission may be requested through the app, the operating system, or Google/AdMob consent tools.
3. Sources of data
We may receive data directly from you, from authentication providers, app stores, subscription and billing providers, AI and backend providers, cloud infrastructure, push-notification providers, third-party APIs, and automatically from the device, website, or app while they operate.
4. Why data is used
- to create and maintain the account;
- to sync and store user data;
- to display statistics, budgets, goals, debts, and other records;
- to operate AI analytics and AI reports;
- to personalize EVA inside your app, analyze incorrect replies, and improve EVA, if you separately confirmed such use inside EVA;
- to process images, files, screenshots, receipts, audio, and voice input within the features that you choose;
- to provide speech recognition, AI analytics, AI responses, and AI reports;
- to send service, security, and system notifications where enabled;
- to administer subscriptions, free access, plan changes, prices, entitlements, free-version limits, AI limits, and access conditions;
- to operate subscriptions, free access, Standard access, Premium access, and AI feature limits;
- to display, personalize where permitted, measure, limit, and improve ads in the free version and to prevent advertising fraud and abuse;
- to verify Standard or Premium entitlement status and remove ads for users with an active ad-free subscription entitlement;
- to ensure security and prevent fraud and abuse;
- to fix errors, provide technical support, and improve the service;
- to fulfill legal obligations, protect rights, and resolve disputes.
5. Legal bases for processing
If GDPR or similar law applies, we process data on the basis of contract performance, legitimate interest, user consent where required, and compliance with legal obligations where necessary.
6. Device permissions
The app may request access to the camera, photo library, device storage, microphone, notifications, or biometric / local authentication if this is necessary for a feature you choose. Such permissions are used only within the feature that you start yourself and may be revoked by you in your device settings.
7. Who data may be shared with
Data may be processed and, where necessary, transferred to the following categories of recipients to the extent reasonably necessary to operate the service:
- cloud infrastructure, database, and file storage providers;
- authentication and sign-in providers such as Google / Apple;
- AI and backend logic providers;
- speech recognition, file processing, moderation, and compute providers;
- subscription and billing providers, including RevenueCat, Apple App Store, and Google Play;
- advertising networks, advertising SDK providers, consent providers, and ad measurement providers, including Google AdMob / Google Mobile Ads SDK;
- third-party API providers, for example for exchange rates or infrastructure functions;
- push, messaging, and communication providers;
- public authorities and other parties where required by law or necessary to protect rights.
8. International data transfers
Data may be processed on servers and through providers located outside your country of residence, including countries outside the European Economic Area, where this is required to operate infrastructure, AI features, subscriptions, authentication, or support.
9. Data retention period
We keep data no longer than necessary for the purposes described in this Policy unless a longer period is required by law, security, protection of rights, fraud prevention, dispute resolution, or accounting and tax obligations.
After that, data may be deleted, de-identified, or anonymized.
10. Account and data deletion
You can delete your account and related data directly inside the app through the Settings menu, if this feature is available to you, or use the external account deletion page or send a request by email firmawerkkraft@gmail.com. Deleting the app from your device does not automatically delete your account.
We may retain certain data to the extent necessary to comply with the law, resolve disputes, prevent fraud, fulfill obligations, ensure security, and protect rights.
11. Security
We apply reasonable technical and organizational measures to protect data. However, no method of transmission or storage can guarantee absolute security, so absolute protection cannot be promised.
You are responsible for protecting access to your account and the security of your devices.
12. Your rights
Depending on applicable law, you may have the right to access, correct, delete, restrict processing, object to processing, data portability, and to lodge a complaint with a supervisory authority. To exercise such rights, use the email: firmawerkkraft@gmail.com.
13. Children
The service is not specifically intended for children and is not directed to a child audience. If you believe that a child’s data has been submitted without proper grounds, please contact us.
14. Changes to the policy
We may update this Policy from time to time. The current version may be published on the website and/or inside the app. Continued use of the website or app after a new version is published or otherwise presented means that you have reviewed the updated version unless mandatory law or platform rules require otherwise. Updates may relate to features, permissions, AI processing, subscriptions, prices, limits, advertising, ad-free subscriptions, third-party SDKs, or access conditions.
15. Contacts
Developer and service owner: Dmytro Moroz
Development studio: MOROZ
Studio website: https://www.moroz.sbs/
Address: Sontraer Str. 17, 60386 Frankfurt am Main
E-mail: firmawerkkraft@gmail.com