Personal Budget Tracker — Privacy Notice
DRAFT FOR REVIEW / NOT PUBLISHED
Status: Internal draft only. Do not publish, submit as a live policy URL, or use it to authorize a bank connection.
Current status
The tracker is a local MVP. No real bank account has been connected and no personal bank transactions have been read through it. The approved first trial, if separately made ready and started, is limited to one personal Revolut account and one completed-month pull of transactions only. It excludes balances, payment initiation, and access to anyone else’s account.
The intended provider route is Enable Banking in Production restricted-own-account mode. The current pinned Securo path has safety gaps and is not ready to read live data. No account connection should proceed until the software path, requested permissions, consent screen, and data handling have been reviewed and shown to match this narrow scope. These statements describe an intention, not an active service or a claim of readiness.
Who is responsible
- Owner/controller identity and role: [TO COMPLETE; obtain legal review]
- Privacy/data-protection contact email: alejandro@kairon.xyz (provided by the owner for publication in this notice; notice remains an unpublished draft)
- Representative or data protection officer, if required: [REVIEW]
Whether a formal controller, representative, or data protection officer designation is required has not been determined.
What information may be involved
If the planned trial is later implemented and authorized, the tracker is intended to receive transaction information for the selected completed month from the linked account. This may include transaction date, description or payee, amount and currency, transaction status, and identifiers or category information returned by the bank/provider. The exact fields, account metadata, connection records, and technical logs must be verified against the final API requests and stored data before any live use.
The trial does not authorize balance retrieval, payment initiation, or another person’s account. No actual live transaction data is currently held by this tracker as a result of a bank connection.
Why it would be used
The intended purpose is to prepare a private household budget view for the account owner. No commercial service, public sharing, advertising, or third-party account access is part of the approved scope. Any additional purpose requires a separate review and approval.
Providers, access, and disclosure
Enable Banking is the intended account-information access provider, and Revolut is the intended account provider. Their roles, the precise data flow, any subprocessors, data locations, retention, and applicable provider notices must be confirmed before connection. The account holder’s bank/provider authorization is separate from this draft. Review the providers’ own terms and privacy information as well.
No other person is authorized to access the trial data under the approved scope. The tracker’s hosting and any technical service providers have not been selected or documented; complete this section before use.
Storage, retention, and deletion — unresolved
- Hosting and storage locations (including any cloud services): [TO COMPLETE]
- Retention period and criteria, including database, logs, credentials/tokens, exports, and backups: [TO COMPLETE]
- Deletion process and completion window, including after consent is revoked: [TO COMPLETE]
- Backup and recovery behavior: [TO COMPLETE]
Do not assume that “local,” ignored files, or a development workspace means encrypted storage or a verified deletion/backup process.
Security — unresolved
- Exact safeguards for the signing key, access control, encryption, logs/errors, backups, and deletion: [TO COMPLETE AND TEST]
- Incident/contact procedure: [TO COMPLETE]
The current pinned integration has known safety gaps and has not been cleared for live account data. This draft makes no claim that particular controls are deployed or that the tracker is secure for live use.
Choices and requests
Before any trial, document how the account owner can review and withdraw provider authorization, request access or correction, request deletion, and contact the responsible person. The actual steps and any applicable legal rights or complaint route remain [TO COMPLETE / LEGAL REVIEW]. Do not promise a response time or deletion deadline until the process is established.
Legal review and applicability
The applicable privacy laws and any required disclosures have not been determined. Obtain legal review for the owner’s location, provider arrangement, storage locations, and intended use before publication or live processing. In particular, assess whether GDPR Article 13 or other rules apply; this draft is not a conclusion that they do or that this notice complies with them.
Official references reviewed
- Enable Banking: linking own accounts for restricted production use
- Enable Banking Terms of Service, including “Restriction of Use”
- Enable Banking Control Panel application requirements
- EU GDPR, Article 13
These sources inform the draft but do not establish the tracker’s legal status, provider approval, or readiness for live data.