Privacy Policy

Centmond is a personal finance app that runs in your web browser. We built it on a simple principle: your money is yours, your data is yours, and the optional assistant that helps you understand them is yours to switch on or leave alone. This policy sets out, for each thing we do with your data, what is processed, why, on what legal basis, who receives it and how long it is kept. Native iPhone and Mac apps are in development; this policy will be updated before they are released.

The short version

• The assistant is optional. When you use it, only the specific data your question needs is sent to our inference provider, never your whole account. It reads your data and can prepare changes to it, but it never applies one without your confirmation.
• Your financial data is encrypted in transit and at rest and stored on EU-hosted infrastructure. Access is restricted per user by database row-level security, and bank identifiers are additionally encrypted at the field level.
• We do not sell data, run advertising networks, or run cross-site trackers. We do use one cookie-free analytics tool, and it only loads if you allow it.
• Bank connections are optional. When you use them, a regulated third-party AISP (Enable Banking, registered in Finland) handles the bank login and holds your consent. We never see your online banking credentials.

Data controller

The controller responsible for processing your personal data under the EU General Data Protection Regulation (GDPR) is:

Seyedmani Hosseinighahroodi
Centmond (sole proprietor, Einzelunternehmen)
Germany
Email: mani.scs.gh@gmail.com

The full postal address required by § 5 DDG is on the Imprint page. We have not appointed a data protection officer: a one-person business below the thresholds of Art. 37 GDPR and § 38 BDSG is not required to, and the address above reaches the controller directly.

What we process, and why

Each card below is one processing operation. Anything not listed here we do not do, and if that changes, this page changes with it.

What we do not collect

• Assistant conversations for resale or profiling. Every query the assistant runs on your behalf is restricted by database row-level security to your own rows. When you ask a question, only the specific data that question needs is sent to our inference provider (never your whole account), and we never sell it or use it to profile you. Background jobs that run without you present (the nightly bank sync, the digest mailer) use a service role rather than your session, and are scoped in code to the one account they are working on.
• Receipt photos, unless you ask us to keep one. When you scan a receipt, in the browser or in the iPhone app, the photo is read entirely on your own device. It is never sent to an optical-character-recognition service, to an AI model, or to any other company: the reader runs inside your browser, which is the reason that page takes a moment to start the first time. By default nothing leaves your device but the handful of details you confirm on screen (the merchant, the date, the total), and the individual line items are read on your device and deliberately not saved anywhere. One further thing leaves with those details: a fingerprint of the photo (a SHA-256 hash, a fixed string of letters and numbers from which the picture cannot be reconstructed), which we store alongside the transaction for as long as it exists, so that picking the same photo again is recognised and does not create a second copy of the same purchase.
• The exception, and it is yours to make. The confirm screen offers “Keep the photo with this transaction”. It is off unless you turn it on, and it is the only thing in Centmond that puts a receipt image on a server. Tick it and a copy is stored in a private area of our storage that only your own account can read, attached to that one transaction. The copy is re-encoded before it is sent, which removes the EXIF metadata a phone writes into a photo, including the GPS coordinates of where it was taken. You can delete it from the transaction at any time, and it goes with the transaction and with your account.
• Device or behavioural profiles. We do not fingerprint your device, build a behavioural profile, or follow you across other sites. The bot check on the account forms reads an IP address and a user agent to tell a person from a script, and is not used for anything else.
• Your bank credentials. When you use the bank connection feature, you authenticate directly with your bank through Enable Banking's consent flow. Your username, PIN, and 2FA codes never touch Centmond's servers.

Bank connections

Connecting a bank account inside Centmond is optional. When you choose to connect a bank, we use Enable Banking Oy, a Finnish Account Information Service Provider (AISP) authorised and supervised by the Finnish Financial Supervisory Authority (FIN-FSA), as the regulated open-banking gateway.

Clicking Connect bank redirects you to your bank's own authentication flow via Enable Banking. Your bank credentials and any 2FA challenge live entirely inside that flow. Enable Banking holds the resulting consent under their AISP licence and is an independent controller for that part; Centmond never sees or stores your online-banking credentials.

You can disconnect a bank at any time from Accounts → Bank connections → Remove; that revokes the Enable Banking session and stops further fetches. Existing transactions stay in your dashboard unless you delete them. Enable Banking's own privacy policy applies in addition to ours and is available at enablebanking.com/privacy-policy.

Investments price data

If you record a holding in the Investments section, Centmond queries public market-data providers to keep its current price up to date. We only send each provider the public symbol of the asset (e.g. AAPL, BTC). We never send your identity, holdings, or any account-level data, so no personal data leaves the EU for this.

• Finnhub for stock and ETF quotes, company logos, and symbol search.
• CoinGecko for crypto prices and coin icons. No API key, no account, plain HTTPS lookup by symbol.
• Alpha Vantage as a fallback for stock and ETF symbols Finnhub doesn't cover.
• Frankfurter for daily currency reference rates, so balances in several currencies can be shown in one.

Who receives your data

The complete list, with the role each provider plays, the data it receives, where it stores that data and the transfer mechanism that covers it, is on the Sub-processors page. Not all of them are processors acting on our instructions: Google, Apple and Enable Banking decide their own purposes for part of what they receive and are independent controllers for that part, which means their own policies govern it and we cannot instruct them on your behalf.

We do not use third-party advertising networks, third-party analytics platforms beyond the one named above, or any cross-site trackers, and we do not sell personal data to anyone.

International transfers

Our primary infrastructure (Supabase, Sentry, Enable Banking) is hosted in the EU, and the data there stays there. Four recipients are outside the EEA: Vercel, Cloudflare, Resend and Groq for the assistant, plus Apple and Google under their own terms.

For Vercel, Cloudflare and Resend the transfer is covered by the EU-US Data Privacy Framework, backed by Standard Contractual Clauses; for Groq, by Standard Contractual Clauses. The mechanism is named per provider on the Sub-processors page rather than described in general terms, and you can request a copy of the safeguards we rely on for any of them by emailing the address at the bottom of this page.

Cookies and the website

The Centmond website does not set advertising cookies and does not run third-party trackers. Cookies set on the marketing site are strictly necessary for basic site function. The signed-in dashboard sets an authentication cookie so we can keep you logged in. These are exempt from consent under § 25 (2) No. 2 TDDDG (the successor to the TTDSG, renamed in May 2024) and Art. 5 (3) of the ePrivacy Directive.

On top of the legal minimum, we show a cookie banner on your first visit. You can accept all categories, reject everything optional, or open the customise view to toggle individual categories, where every optional category is off until you turn it on. Your choice, the version of the notice it was given against, and the time you gave it are stored locally in your browser; you can change it any time via Cookie preferences in the footer, and if we change what a category covers we will ask again.

The only optional category that currently loads anything is Analytics, which enables Vercel Web Analytics and Vercel Speed Insights. Both are cookie-free and do not track users across sites. Separately from consent, every request to the site reaches Vercel's edge network and appears in its server logs with an IP address. That is unavoidable for any hosted website, is covered by the security-logs row above, and is not what the analytics category controls.

Automated decision-making

We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you, within the meaning of Art. 22 GDPR. Centmond does analyse your data: it suggests a category for a transaction, flags a subscription, forecasts a balance, and the assistant answers questions about it. But these are suggestions inside your own account. Nothing here decides your access to a service, your creditworthiness, or any right, and every change the assistant prepares waits for you to confirm it.

Data retention

Retention is stated per processing operation in the table above rather than as a single number, because it genuinely differs: a security log lives for days, a transaction for as long as you keep it. As a general rule we keep your data for as long as your account is active.

When you delete your account, the live data is removed from our backend within 30 days. Encrypted backups that still contain it age out on the backup schedule and are never restored in order to bring deleted data back. Where the law requires us to keep something longer, we restrict its processing instead of deleting it, and use it only for that legal purpose.

Your rights

From inside the app you can, at any time and without asking us:

• Export your data (JSON, CSV, PDF), which is also how the right to data portability is served.
• Delete your account, which removes your data from our backend within 30 days.
• Switch the assistant off, which withdraws the consent it runs on and stops any data reaching the inference provider.
• Disconnect any bank from the Accounts page, which revokes the Enable Banking session immediately.

Under the GDPR you also have the right to access (Art. 15), rectify (Art. 16), erase (Art. 17), restrict processing of (Art. 18) and port (Art. 20) your personal data, and the right to object (Art. 21) to the processing we base on a legitimate interest: the security logs and error monitoring above. Where processing rests on consent, you can withdraw it at any time, which does not affect what was lawful before the withdrawal. To exercise any of these, email mani.scs.gh@gmail.com; we answer within one month.

You also have the right to complain to a supervisory authority. The one competent for us is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany. You may instead complain to the authority where you live or work.

Children

Centmond is not offered to anyone under 18, and the Terms require you to be 18 to open an account. We do not knowingly collect data from anyone under that age; if you believe a minor has provided us with personal information, contact us and we will delete it and close the account.

Changes to this policy

If we make material changes, we will update the "last updated" date at the top of this page and, where appropriate, notify you in the app or by email. Where a change needs your consent, we will ask for it rather than assume it. We will not silently broaden how we use your data.

Contact

For any privacy question, request, or complaint, email mani.scs.gh@gmail.com.