Privacy Policy

1 Our Privacy Philosophy

• Single purpose: We collect your information solely so that the application can work for you. There is no other purpose.
• Your data is yours: We do not sell, rent, or share your information with third parties, advertisers, or data brokers. Ever.
• No advertising: Ventidue does not display ads or use your data for advertising profiling.

2 Information We Collect

To provide the service, we collect only what is necessary:

• Registration data: Name and email address, used to create and manage your account.
• Google Sign-In data (optional): If you register or sign in with Google, Google shares with us your email address, your name, your profile picture, and a unique identifier of your Google account. We use that data solely to create, identify, and authenticate your account in Ventidue (see § 15).
• Financial data: The information you voluntarily enter: transactions, balances, accounts, cards, budgets, subscriptions, brokers, and categories. We never access your actual bank accounts.
• Payment and subscription data: When you subscribe to a Premium plan, we collect the email you paid with (which may differ from your account email), the subscription identifier assigned by the processor, the payment status, and the next payment date. We do not store or access your credit or debit card data; these are processed directly by MercadoPago or dLocal Go under their own policies (see § 5).
• AI feature data: When you use these features, we collect the text, voice transcription, image, and/or PDF you submit, the names and identifiers of your accounts, cards, and categories, the recent conversation context, and, when you query your finances through the conversational assistant, the financial data needed to answer them (amounts, merchants, balances, and card usage). Details are in § 4.
• Imported Mercado Pago data (optional, Premium): If you enable the Mercado Pago integration, we import your account movements to record them; we keep only the information necessary for that. Details are in § 6.
• Quote data: Currency prices (ARS, USD, crypto) obtained from third-party public APIs (DolarAPI, Binance). This data is public and does not identify you.
• Technical data: IP address and device/browser type, collected automatically for the security and proper functioning of the service.

3 How We Use Your Information

• Service provision: We use your financial data to display charts, calculate totals, generate reports, and maintain your history within the app.
• Security and authentication: Your email is used to send you verification codes (OTP) and security alerts about your account.
• Subscription processing: When you subscribe to or manage a Premium plan, we use the data needed to set up the recurring charge, verify the payment status, and keep you informed about your subscription.
• AI processing: When you use the AI features, we send the data described in § 4 to the external AI provider to interpret your entry or query and return a movement suggestion or a response (see § 4).
• Mercado Pago integration: If you enable it, we use read-only access to import your account movements into a review tray within the app (see § 6).
• Service improvement: We may use aggregated and anonymous technical data to identify errors and improve the performance of the app.
• Never for advertising: We do not use your information to show you ads, for commercial profiling, or to share with third parties for marketing purposes.

4 Data Processing by AI Features

Ventidue offers AI-assisted features (recording movements via text, voice, image, or PDF, and a conversational financial assistant). To process them we use the artificial-intelligence models of Google (Gemini API). Processing occurs server-side: requests are sent to Google from our backend, not directly from your device.

What data is sent to the AI provider and for what purpose. Depending on the feature you use and the query you make, we may send Google:

• The text you enter (your query or the description of the transaction to record), to interpret it and generate a response or a draft transaction.
• The recent conversation context (the last chat messages), so the assistant maintains coherence in the dialogue.
• The names and identifiers of your accounts, cards, and categories, to correctly assign the transactions.
• Financial data needed to answer your query: when you ask for information about your data (for example, "how much did I spend this month?"), the model receives the data required to respond, which may include amounts, names or merchants of transactions, balances, and card usage. This data is sent only to the extent necessary to answer that specific query.
• Images or PDF documents you attach (for example, an invoice or a card statement): the file is sent to Google to extract the transactions it contains.
• Limited reference searches: occasionally, to obtain context data (for example, inflation or the dollar exchange rate), the provider may perform a limited web search through Gemini's grounding feature (Grounding with Google Search). In that case, only the query terms needed to obtain the data are sent to Google Search, with no additional personal data.

Voice dictation, if you use it, is transcribed by your own browser or operating system, not by our backend or by Google through us. Attached images and PDFs are also processed by sending them to Google.

• Google as processor / sub-processor: Google acts as a data processor (sub-processor) regarding the data we send to provide these features, processing it on our behalf and according to our instructions. Google's processing is additionally governed by its own terms, available in the Gemini API Terms of Service and the Google Privacy Policy.
• Not used to train models: We use the Gemini API on its paid tier. Under that tier, Google does not use the data we send (text, queries, images, or PDFs) to train or improve its artificial-intelligence models.
• Retention — conversational assistant history: It is stored only on your device (local browser storage), is limited to the last messages, and is deleted when you log out or when you clear the conversation. We do not retain the chat content on our servers.
• Retention — entries sent to the AI: We do not retain the text, audio, images, or PDFs sent to the model beyond the time required to process the request and return the result.
• Internal usage metrics: We retain aggregated and/or anonymous metrics about the use of these features (for example, query type or number of transactions created), in order to improve the service and prevent abuse. These metrics are not shared with third parties, nor used to identify you, nor for advertising purposes.
• Legal basis: Since using the AI features is optional and at your request, the primary legal basis is your consent, expressed by activating and using these features, complemented by the performance of the service you request (contractual necessity), within the framework of Personal Data Protection Law 25.326.
• International transfer: Google processes this data primarily in the United States (Google LLC) and at other data centers. This constitutes an international transfer of personal data under article 12 of Law 25.326, based on your consent when using these features and on the contractual data-protection terms offered by Google.
• Your rights: You retain the rights of access, rectification, update, deletion, and objection over your data, in accordance with Law 25.326 (see § 10). You can delete the conversational assistant history directly by clearing the conversation or logging out.
• Your control: Using the AI features is optional. If you do not want this data processed through artificial intelligence, you can refrain from using the AI features: the rest of the application works normally without sending data to AI providers.
• Data controller and users outside Argentina: The data controller is Javier Nicolás Sosa (contact details in the Terms & Conditions and in § 16). If you use Ventidue from outside the Argentine Republic and your local legislation grants you additional rights (for example, the GDPR in the European Union or the LGPD in Brazil), we will endeavor to honor them to the extent applicable.

5 Payment and Subscription Data

To process Premium plan subscriptions, Ventidue works with two external payment processors:

• MercadoPago: Processes payments in Argentine pesos for users in Argentina.
• dLocal Go: Processes international payments in U.S. dollars.
• What we share with the processor: Your email, the chosen plan and its amount, and an internal identifier of your Ventidue account to reconcile the payment.
• What we receive back: The subscription identifier, the payment status (authorized, pending, cancelled, failed), the email you paid with, and the estimated next billing date.
• What we do NOT store: Card number, expiration, security code, or any other sensitive payment data. These are processed and stored solely by the processor under its own privacy policy and PCI-DSS standards.
• Legal basis: We process this data based on contractual necessity (managing your subscription) and, where applicable, legal obligation (accounting records and fraud prevention). By subscribing to a paid plan, you expressly consent to the transfer of the necessary data to the chosen processor.

6 Mercado Pago Integration (movement import)

If you enable the optional Mercado Pago integration (available on the Premium plan), Ventidue accesses —through Mercado Pago's official authorization system (OAuth) and with read-only permissions— the movements of your account to import them into a review tray. The connection does not allow operating your account or moving money; the access tokens are stored encrypted (AES-256-GCM). This integration is distinct from your subscription billing (see § 5).

What data we receive. For each movement, Mercado Pago provides us with the full record of the operation. This may include:

• Transaction data: amount, currency, date and time, status, operation type (payment, subscription, transfer, or top-up), description, merchant name, category, Mercado Pago internal identifiers, fees, and taxes.
• Payment method data: type and network used (credit, debit, account money, or CVU; Visa, Mastercard, etc.) and, when the operation was by card, the last 4 digits, the first 6 digits (BIN), the issuing bank, the expiration, and the name and document (DNI/CUIT) of the cardholder.
• Identifiers and third-party data: your Mercado Pago user identifier and, in received transfers, the email and CUIT/CUIL of the person who sent you the money, as well as, in some movements, the IP address of the operation.

• What we store: From that record we keep only the information necessary to record the movement: amount, currency, date, movement type (income or expense), payment method and network, the last 4 digits where applicable, and the description or merchant. We do not store the full record (raw) nor the data we do not use, such as the cardholder's name and document, the BIN, the email or CUIT of third parties, or the IP address of the operation.
• Third-party data: The record we receive may contain data of third parties who are not Ventidue users (for example, someone who sent you a transfer). That information is processed transiently, solely to build your movement, and is not stored. You are responsible for having a legitimate basis regarding the third-party data you choose to keep when confirming a movement (see Terms & Conditions).
• Legal basis: Your consent, expressed when enabling the integration, and the performance of the service you request, within the framework of Law 25.326. With respect to third-party data, we act as a processor on your behalf.
• Security: The connection is read-only and the access tokens are stored encrypted with AES-256-GCM. Ventidue cannot operate your Mercado Pago account.
• Revocation and deletion: You can disconnect the integration and revoke access at any time from the app or from Mercado Pago (Your account → Security → Apps with access); revocation prevents future imports. You can delete imported movements you have not confirmed from the review tray.

7 Storage, Security, and Infrastructure

We protect your information with industrial-grade security standards:

• Full isolation (RLS): We use Row Level Security in our database, which technically guarantees that no user can access another user's data.
• Encryption: All communication between your device and our servers is encrypted with SSL/TLS. Data at rest is also encrypted.
• Defense in depth: Database triggers prevent unauthorized modification of sensitive fields such as your subscription plan or payment status.

Your information is hosted and processed with the following providers:

• Supabase (on AWS): Database, authentication, and serverless functions.
• Google (Identity Platform): Optional authentication with a Google account ("Sign in with Google").
• Vercel: Web application hosting.
• Cloudflare: CDN, protection, and hosting of the public site.
• MercadoPago: Payment processing in Argentine pesos.
• dLocal Go: International payment processing.
• Resend: Transactional email delivery (OTP codes, Premium welcome, cancellation confirmation).
• Google (Gemini API): Processing of the AI features.
• DolarAPI / Binance: Public quotes (no user personal data is sent).

International transfer: By using Ventidue, you consent to the international transfer of your data to these providers, in compliance with article 12 of Argentina's Personal Data Protection Law 25.326. Such providers offer adequate levels of protection in accordance with their jurisdiction.

8 Local Storage (Offline Mode)

So that Ventidue works quickly and even without internet, we store part of your information on your own device:

• Technology: We use IndexedDB, a local browser/app storage, to securely save your data on your device.
• Sync queue: Changes made offline are stored locally and automatically synchronized with the cloud when you regain internet access.
• Your responsibility: It is the user's responsibility to protect physical access to their device. Do not manually clear your browser data if you have operations pending synchronization.

9 Communications

• Security emails: You will receive automatic security emails, such as OTP codes to verify your identity at sign-in.
• Transactional subscription emails: When you subscribe, renew, or cancel a paid plan, you will receive automatic emails confirming the operation. These emails are essential and cannot be disabled while you maintain an active subscription.
• News and tips: Occasionally we may send you information about new features or financial organization tips.
• Your control: You can disable news emails at any time from Profile Settings within the app. Security and subscription transactional emails cannot be disabled, as they are essential to protect your account and keep you informed about your plan.

10 Your Rights (Law 25.326)

In compliance with Argentina's Personal Data Protection Law 25.326, you have the following rights over your data:

• Access: You may request at any time what personal data we hold about you.
• Rectification: You may correct incorrect data directly from the app or by requesting it via email.
• Cancellation: You may request the deletion of your account and all your data from Settings > Delete Account, or by writing to soporte@ventidue.app.
• Opposition: You may object to the processing of your data for purposes other than the provision of the service.
• Response time: We will address your request within a maximum of 30 business days from receipt.

The NATIONAL DIRECTORATE OF PERSONAL DATA PROTECTION (Supervisory Authority) has the power to handle complaints and claims filed in connection with non-compliance with personal data protection regulations.

11 Deletion and Right to Be Forgotten

• Deactivation: When you request the deletion of your account, it enters a 30-day deactivation period. During that time you can reactivate it if you change your mind.
• Permanent deletion: After day 30, the system performs a physical and irreversible deletion of all your personal and financial information from our database.
• Cancellation of associated subscription: If you have an active Premium subscription when deleting your account, you must cancel it beforehand from the "Subscription" section of your profile to avoid future charges. Deleting your Ventidue account does not automatically cancel the subscription at MercadoPago or dLocal Go.
• Minimum retention: We do not retain data beyond the time necessary to provide the service, except for minimum payment records that may be retained for the period required by applicable tax regulations.

12 Minors

• Minimum age: Ventidue is intended for people over 18 years of age. We do not intentionally collect data from minors under that age.
• If you are a parent or guardian: If you detect that a minor has created an account, you can request its immediate deletion by writing to soporte@ventidue.app.

13 Changes to this Policy

We may update this Privacy Policy occasionally. We will notify you of any significant changes through a notice within the app or by email. Continued use of Ventidue after such changes implies your acceptance of the updated policy.

14 Governing Law

This Policy is governed by Argentina's Personal Data Protection Law 25.326 and its regulatory rules, without prejudice to the rights that may apply to you under the legislation of your country of residence.

15 Limited Use of Google User Data

Ventidue's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We do not sell the data obtained from your Google account.
• We do not use or transfer it for advertising purposes (no advertising).
• We do not use it to train machine-learning or AI models, whether our own or third-party (we do not train ML models with this data).
• Restricted human access: Only authorized personnel access this data, and solely to operate, maintain, or improve user-facing features, or when required by law.
• Revocation: You can revoke Ventidue's access to your Google account at any time from myaccount.google.com/permissions.

16 Contact

If you have questions about this policy, want to exercise your rights, or need to report a problem related to your data, contact us at:

Email: soporte@ventidue.app