Privacy Policy
Budfinix Privacy Policy (v2026.09.11). How we collect, use, share, and protect personal data under PDPA and GDPR.
Updated 2026-10-13 · TH
Document version: v2026.09.11
Effective date: 11 September 2026
This Privacy Policy explains how Budfinix (“we”, “us”) processes personal data when you use our websites and apps. It is designed for users in Thailand and the EU/EEA and aims to meet transparency duties under the Thai PDPA and the GDPR.
Placeholders — replace before production: controller legal name, address, privacy email, and DPO contact (if appointed).
1. Data controller
Controller (placeholder): [LEGAL_ENTITY_NAME]
Address (placeholder): [REGISTERED_ADDRESS]
Privacy email (placeholder): [PRIVACY_EMAIL]
DPO (placeholder, if appointed): [DPO_EMAIL]
2. Data we process
Depending on how you use Budfinix, we may process:
| Category | Examples |
|---|---|
| Account | email, username, name, password hash, preferred locale/currency/timezone, profile image |
| Security | sessions, IP address, user agent, 2FA secrets/recovery codes, verification tokens |
| Financial records you enter | wallets, transactions, categories, budgets, assets, debts (payoff plans, refinance), loans, goals, reports/exports, receipts/slips |
| Sharing | wallet collaborators, family invites, shared bills, PromptPay/bank fields you enter, guest bill tokens |
| Billing | Stripe customer ID, plan, invoices/billing history metadata |
| Support & feedback | tickets, messages, attachments, page URL on feedback |
| Device preferences | language cookie, theme, report filters, guest bill owner token (local) |
| Technical | Cloudflare edge country hints, server logs |
We do not currently run third-party advertising pixels or analytics SDKs in the product. AI/OCR features mentioned in marketing are not live processing activities unless separately launched and disclosed.
3. Sources of data
- You — registration, profile, financial entries, uploads, support/feedback.
- Your device — cookies/local storage described in the Cookies Policy.
- Other users — when they share a wallet, bill, family seat, or lending link with you.
- Processors — Stripe (payments), email provider (transactional mail), hosting/storage providers.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR Art. 6 / PDPA equivalent) |
|---|---|
| Create and operate your account, wallets, and core features | Contract |
| Authentication, fraud prevention, session security | Legitimate interests / contract |
| Subscriptions, invoices, tax-related billing records | Contract / legal obligation |
| Transactional emails (password reset, family invite, security/warning notices) | Contract / legitimate interests |
| Product improvement using anonymous aggregated statistics | Legitimate interests (LIA documented) |
| Budfinix news and promotions | Consent (optional) |
| Personalised marketing / profiling for offers | Consent (optional) |
| Interest in partner offers (internal audience building only) | Consent (optional) |
| Disclosure/sale of personal data to a named marketing partner | Separate partner-specific consent before each disclosure |
| Cookie preferences beyond strictly necessary | Consent (cookie banner) |
| Respond to support/DSAR requests | Legal obligation / contract |
| Soft-delete grace period and dispute/tax retention | Legitimate interests / legal obligation |
Important: Accepting the Terms and acknowledging this notice at signup is not consent to marketing or partner data sales. Optional consents are unticked by default and can be refused without losing core Service access.
5. Marketing, profiling, and partners
- Budfinix promotions — email or in-product offers about Budfinix, only if you opt in.
- Personalised marketing / profiling — using account and usage signals to tailor Budfinix offers, only if you opt in. We do not use this as a basis to sell raw transaction ledgers.
- Partner interest — signals that you are open to relevant partner offers. This preference alone does not authorise sending your personal data to any partner.
- Partner-specific disclosure — before sharing or selling personal data to a partner, we will name the partner, data categories, purpose, and destination country, and obtain a fresh opt-in. You may withdraw at any time in Settings → Privacy & data.
We do not sell raw transaction amounts, payee notes, receipt images, PromptPay/bank identifiers, or other directly identifying financial records as “aggregate marketing data”. Aggregate products use data that has been anonymised with minimum cohort sizes and contractual bans on re-identification.
6. Recipients and processors
We use service providers under contracts (processors), including:
- Cloudflare (hosting/CDN/Workers, R2 object storage, edge network)
- PostgreSQL database host (region per deployment)
- Stripe (payments)
- Transactional email (SMTP / Mailtrap or successor)
- Browser push vendors (when you enable web push)
- Frankfurter (FX rates — no user personal data sent)
Staff with admin roles may access account and support data as needed to operate the Service, under access controls and audit logging.
7. International transfers
Because we use global cloud infrastructure, data may be processed outside your country (including outside Thailand or the EU/EEA). Where GDPR applies, we rely on appropriate safeguards such as Standard Contractual Clauses and vendor assessments. Where PDPA applies, we follow applicable transfer requirements.
8. Retention
| Data | Retention |
|---|---|
| Active account & financial records | While account is active |
| Account deletion request | Soft-disabled immediately; 30-day grace to cancel |
| After grace period | Financial/content data purged or irreversibly anonymised; object storage cleaned where practicable |
| Consent / legal event records | Kept as proof of compliance for a limited period after deletion (placeholder: confirm with counsel) |
| Billing / tax records | As required by law |
| Sessions / verification tokens | Short-lived (see Cookies Policy / security settings) |
| Ownerless guest bills | Default 7 days |
| Free-plan history lookback | Product limit (~12 months) may restrict display; deletion follows account rules |
9. Your rights
Subject to applicable law (PDPA / GDPR), you may:
- access and receive a copy of your data;
- rectify inaccurate data;
- erase data (including account deletion);
- restrict or object to certain processing;
- withdraw consent (does not affect prior lawful processing);
- data portability for data you provided (where applicable — wallet/report CSV exports are available; full-account self-service export may be limited);
- lodge a complaint with a supervisory authority (Thailand PDPC; EU/EEA DPA where you live or work).
To exercise rights, email [PRIVACY_EMAIL] or use in-app Settings where available. We may need to verify your identity. GDPR responses are generally within one month.
10. Children
The Service is not directed to individuals under 18. We do not knowingly collect children’s data.
11. Security
We use encryption in transit, hashed passwords, optional 2FA, access controls, and least-privilege admin roles. No method is 100% secure; notify us promptly of suspected compromise.
12. Automated decisions
Budfinix may show rule-based insights or health scores. These do not produce legal or similarly significant effects solely by automated means without human involvement in the sense of GDPR Art. 22 for core account decisions.
13. Changes
We may update this Policy. Material changes will show a new document version. We may require acknowledgement of a new Privacy Notice version in-app before continued use.
14. Contact
Privacy requests: [PRIVACY_EMAIL]
Controller: [LEGAL_ENTITY_NAME], [REGISTERED_ADDRESS]