PRIVACY POLICY

Last Updated: December 18, 2025

Appmentor OU ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, Waget (the "App").

Please read this Privacy Policy carefully. If you do not agree with the terms of this privacy policy, please do not access the application.

1. WHO WE ARE

The data controller responsible for your personal information for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws is:

Appmentor OU
Estonia/Europe
Email: hello@appmentor.co

2. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

A. Personal Data You Provide to Us

• Account Information: If you register for an account (e.g., via Apple ID, Google Sign-In, or email), we collect your email address and name.
• Financial Data: The core function of Waget is expense tracking. We process the data you input, including:
  • Transaction amounts.
  • Transaction categories (e.g., Food, Rent).
  • Transaction dates.
  • Wallet names and balances.
  • Notes and tags associated with transactions.
• Voice Data (Crucial): When you use the voice input feature ("Voice Tracking"), we process your voice recordings to convert speech into text and extract transaction details.
• Customer Support: Information you provide when you contact us for help.

B. Information Collected Automatically

• Device Information: We collect information about the device you use to access the App, including the hardware model, operating system and version, unique device identifiers (e.g., IDFA, Android ID, or Firebase Installation ID), and mobile network information.
• Usage and Log Data: We collect information about your interactions with the App, such as the features you use, the time spent on the App, and crash logs to improve stability.
• Location Data: We do not track your precise real-time location. We may derive approximate location (country/region) from your IP address for analytics and localization purposes (e.g., currency defaults).

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

1. To Provide Service: To manage your expenses, wallets, and analytics; to verify your identity; and to process your voice commands.
2. Voice Processing: To convert your spoken audio into text transaction data using AI and Natural Language Processing (NLP) technologies.
3. App Improvement & Analytics: To understand how users interact with Waget, measure the performance of our marketing campaigns, and improve usability using third-party analytics tools.
4. Communication: To send you administrative information, such as updates to this policy, security alerts, or support responses.
5. Legal Compliance: To comply with applicable laws and regulations.

4. VOICE DATA AND ARTIFICIAL INTELLIGENCE

Waget uses Artificial Intelligence (AI) to interpret your voice commands.

• Processing: When you tap the microphone button, your voice audio data is transmitted to our third-party speech-to-text and AI processing providers (e.g., OpenAI, Google Cloud Speech-to-Text, or Apple Speech API) solely for the purpose of transcription and entity extraction (identifying amount, category, and date).
• Storage: We do not retain your raw audio files permanently. Once the transaction is processed and saved to your ledger, the audio file is discarded.
• Privacy: We do not use your voice data for advertising purposes.

5. LEGAL BASIS FOR PROCESSING (GDPR)

If you are located in the European Economic Area (EEA), our legal basis for collecting and using the personal information described above depends on the personal information concerned and the specific context in which we collect it.

• Performance of a Contract: To provide the App services to you (e.g., tracking your budget).
• Legitimate Interests: To analyze App usage and improve our services via analytics tools.
• Consent: We ask for your consent to access your device's microphone for voice input. You can withdraw this consent at any time in your device settings.

6. DISCLOSURE OF YOUR INFORMATION

We do not sell, trade, or rent your personal identification information to others. We may share information with service providers who perform services for us:

• Analytics and Crash Reporting: We use third-party analytics tools, specifically Google Firebase Analytics and Crashlytics, to help us measure traffic and usage trends for the App. These tools collect information sent by your device, including the pages you visit, add-ons, and other information that assists us in improving the App. The information collected by these tools is generally anonymized and aggregated.
• Cloud Hosting: We use providers like Google Firebase and AWS to securely store and process your encrypted data.
• AI Providers: To process voice and text inputs for the core functionality of the App.
• Legal Requirements: If required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

7. DATA RETENTION

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

• Account Data: Retained as long as your account is active. You may request deletion at any time.
• Voice Data: Raw audio is not retained after processing.
• Usage Data: Retained for a shorter period for internal analysis purposes.

8. DATA SECURITY

We use administrative, technical, and physical security measures to help protect your personal information. Your financial data is stored in a secure cloud environment using industry-standard encryption (SSL/TLS) during transmission and at rest. However, please be aware that no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

9. YOUR DATA PROTECTION RIGHTS

Depending on your location, you may have the following rights:

• The right to access: You have the right to request copies of your personal data.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate.
• The right to erasure: You have the right to request that we erase your personal data ("Right to be forgotten").
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data.
• The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you.

To exercise any of these rights, please contact us at hello@appmentor.co.

10. INTERNATIONAL DATA TRANSFERS

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we may process the data, including Personal Data, in the United States or other jurisdictions where our cloud providers operate. We ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.

11. CHILDREN'S PRIVACY

Waget does not address anyone under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personally identifiable information from children. If we discover that a child has provided us with personal data, we immediately delete this from our servers.

12. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have specific rights regarding your personal information, including the right to request disclosure of data collection and sales practices (we do not sell your data) and the right to request deletion of your data. To exercise these rights, please contact us.

13. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

14. CONTACT US

If you have any questions about this Privacy Policy, please contact us:

• By email: hello@appmentor.co