Privacy Policy (Reference)

Effective Date: December 10, 2025

By creating an account or using the Service, you agree to this Privacy Policy and our Terms of Service. If you do not agree, you must not use the Service.

At EB App LLC ("EB.app," "we," "our," or "us"), your privacy is our priority. This Privacy Policy explains how we collect, use, and protect your information when you use EB.app.

At a Glance

• Age: Service is 18+ only; under-18 accounts are not permitted.
• Free tier: Use "AI Budget Creation" (Bring Your Own AI) where you process data locally and we do not receive your raw bank data. Offers tab displays affiliate recommendations. Optionally click "Try AI Analysis" to send a budget summary (NOT transaction history) to Google AI for personalized offers.
• Premium tier: Bank linking via Plaid for AI Budget Creation and transaction reconciliation. Offers tab hidden by default (can be enabled in Settings without AI). Plaid data is NEVER used for Offers.
• Downgrade protection: If you cancel premium and downgrade to free-tier, budgets created from Plaid data are permanently protected from Offers AI Analysis.
• Marketing analytics: We use Google Ads conversion tracking and UTM parameters to measure advertising effectiveness. You can opt out via the "Your Privacy Choices" link in our footer or Google Ad Settings. When you click affiliate links, you leave our app and Amazon's tracking applies (see Affiliate Offers & Third-Party Tracking).
• Control: Free-tier users choose whether to click "Try AI Analysis" for personalized offers. Premium users can optionally enable Offers tab (without AI) in Settings.

1. Your Consent

By creating an account and using Essential Budget, you consent to our collection, processing, and storage of your data as described in this Privacy Policy. You can withdraw consent at any time by deleting your account through Settings or by emailing us at legal@eb.app.

2. Our Privacy Commitment

We believe in:

• Minimal data collection - We collect only the information necessary to operate and improve our service
• Your control - You own and control your budget data
• Limited marketing tracking - We use Google Ads conversion tracking to measure the effectiveness of our advertising campaigns and UTM parameters to understand which marketing channels bring users to our site. We do not use this data to serve you targeted ads within our app. Offers shown in-app are first-party recommendations based on your budget data, not external ad network targeting. When you click affiliate links, Amazon's tracking applies after you leave our app.
• Transparency about promotions - The Offers tab is visible by default to free-tier users. Premium subscribers have the Offers tab hidden by default but can enable it in Settings. Users may optionally click "Try AI Analysis" to get personalized offer recommendations, provided their budget does not contain Plaid-linked data. This is entirely optional and user-initiated.
• Privacy by default - Maximum privacy is the default setting
• Transparency - We're clear about our practices

Clarification: Offers are first-party, contextual/budget-aware recommendations shown inside EB.app; they are not cross-context behavioral advertising. The Offers tab is visible by default to free-tier users and hidden by default (but can be enabled) for premium subscribers.

3. Definitions

• "Service" refers to the EB.app application and all related services provided by EB App LLC.
• "Personal Information" means any information that identifies or can reasonably be linked to an individual, such as your name and email address.
• "Budget Data" refers to the financial information you enter into the Service, such as income, expenses, transactions, and categories, including any data derived from AI processing.
• "We," "us," or "our" refers to EB App LLC.
• "You" refers to the individual using our Service.
• "Offers" means in-app recommendations of our products or affiliate/partner offerings displayed in the Offers tab.
  
  For Free-tier users: The Offers tab is visible by default.
  
  For Premium subscribers: The Offers tab is hidden by default but can be optionally enabled in Settings.
  
  By default, Offers are generated using deterministic, in-app analysis of your Budget Data without AI processing. Users may optionally click "Try AI Analysis" to send a budget summary (item names, amounts, categories, account balances, and balance projections - NOT detailed transaction history) to Google AI (Gemini API) for personalized offer recommendations. This "Try AI Analysis" feature is permanently disabled for any budget that contains (or has ever contained) Plaid-linked data. This action is entirely optional and user-initiated. Google's processing is governed by the Google Cloud Privacy Notice and Gemini API Terms of Service.
• "Authorized Financial Account Holder" means a natural person who is a legal owner of, or an authorized signer on, a financial account and who has authority to grant EB.app read-only access to that account's data via a bank-link provider (e.g., Plaid).

4. Information We Collect

Personal Information

When you sign in with Google, we collect:

• Email address - For account creation and communication
• Name - From your Google account profile
• Avatar/Profile picture - From your Google account profile
• Timezone information - When you first create an account or sign in, we automatically detect your device's timezone using your browser's timezone API (Intl.DateTimeFormat) and include it in a secure HTTP header. This IANA timezone identifier (e.g., "America/Denver" or "Europe/London") is stored in your user settings to ensure that all dates and times within the app are displayed and processed correctly in your local timezone (for example, when viewing schedule dates, due dates, or searching timestamped items). This information only provides your general time zone, not precise location data. You can update this setting at any time in your account preferences. We do not use your timezone for tracking, analytics, or advertising purposes. This data is deleted when you delete your account.

We don't collect your phone number or any other personal details beyond what Google provides during authentication.

Marketing Data

We use Google Ads to measure advertising effectiveness. This data is aggregated and not linked to your personal identity. See Advertising & Cookies in Section 5 for details and opt-out controls.

Email Marketing Data

If you subscribe to our newsletter or download resources (e.g., Budget Starter Kit), we collect your email address and optional first name. Our email provider (MailerLite) tracks email opens and clicks. This data is stored separately from your EB.app account.

Budget Data

• All budget information you enter (income, expenses, categories, etc.)
• AI-derived budget data created from your bank statements (Premium tier users only, when AI is enabled)
• Temporary technical records of AI processing events (e.g., job IDs, timestamps), which do not contain your Budget Data and are deleted after 30 days
• AI preferences and settings
• Transaction resolution status (which items you've marked as paid)
• "Bring Your Own AI" Data - Free-tier users can use the "AI Budget Creation" (Bring Your Own AI) feature. This feature is designed for you to process your bank statement data locally using an external AI of your choice. We do not receive, send, or store the original bank statement file or raw data you use for this process. The resulting budget data that you import or paste back into the Service is then stored as part of your Budget Data.
• Offers analysis (Optional) - Users may optionally click "Try AI Analysis" in the Offers tab to send a budget summary (item names, amounts, categories, account balances, and projections - NOT transaction history) to Google AI (Gemini API) for personalized offer recommendations. This is entirely optional and user-initiated. This feature is permanently disabled for any budget containing Plaid-linked data.

Support Communications

If you contact us for help (including by email at support@eb.app), please do not include any sensitive information in your message. This includes, but is not limited to, financial account numbers, routing numbers, credit or debit card numbers, passwords, government identification numbers, tax documents, medical information, or any other highly sensitive personal data.

We are not able to securely receive or process this type of information through support channels. You are responsible for redacting or removing any sensitive details before sending us a support inquiry. If we receive a message containing sensitive information, we reserve the right to delete the message immediately to protect your privacy.

We process the information you provide in support communications solely for the purpose of responding to your request and improving our services.

Bank Linking (Premium Feature)

Premium Feature: Bank linking via Plaid is available exclusively to premium subscribers. This feature enables automatic budget creation and transaction reconciliation.

PRIVACY FIRST: Bank linking is ALWAYS OPTIONAL. The default configuration after account creation is maximum privacy with NO bank connections. You maintain control.

If you choose to link your bank:

• Connection is handled by certified third-party providers (Plaid)
• We receive only transaction data you authorize
• Transaction data is processed by Google AI (Gemini API) to generate budget items (income, expenses, transfers)
• Transaction data is used for reconciliation (matching transactions to budget item events to determine if events should be marked as resolved)
• Bank credentials are never stored by us
• You can disconnect at any time
• Disconnecting immediately stops all data access

Account Authority: You may link only accounts for which you are an Authorized Financial Account Holder. You must not link accounts that you do not own or for which you lack legal authority.

See also Terms of Service – Authorized Accounts.

We explicitly do NOT collect or store:

• Bank account numbers or routing numbers
• Bank login credentials (never stored by us, even with linking)
• Complete bank statements (unless you optionally upload)
• Credit card numbers

How Plaid Transaction Data is Used:

• AI Budget Creation: Transaction data is sent to Google AI (Gemini API) to generate structured budget items (income, expenses, transfers) that can be imported into Essential Budget
• Reconciliation: Transaction data is matched against budget item events to automatically determine if scheduled items should be marked as resolved
• Historical Reporting: Transaction data is stored to provide balance history and trends
• Account Metadata: Account names, types, and current balances are displayed in your budget

Data Usage Commitments:

• We do not sell, rent, or share Plaid transaction data with third parties for advertising, marketing, or profiling purposes
• Plaid data is NEVER used for Offers (affiliate recommendations) - only free-tier users see Offers, and they do not have access to Plaid
• Plaid data is used solely for budgeting, reconciliation, and AI budget creation
• You can disconnect Plaid at any time, which immediately stops all data access

Protection for Downgraded Users:

If you cancel your premium subscription and downgrade to free-tier, any budgets you created from Plaid data or that contain bank-linked accounts are permanently marked as containing Plaid data. This ensures your Plaid transaction data is never sent to Google AI for affiliate recommendations.

• These budgets will NOT be eligible for Offers AI Analysis, even as a free-tier user
• You will see a message: "AI analysis not available for budgets with bank-linked data"
• This protection applies even if you disconnect Plaid accounts or manually edit items - once a budget contains Plaid data, it remains protected
• You can create new budgets from uploaded files (free-tier AI Budget Creation) which will be eligible for Offers AI Analysis

This data is yours and only used to provide our budgeting service.

5. Information Collected by Third Parties

Firebase (Google LLC)

We use Firebase (a service provided by Google LLC) for hosting and authentication. When you visit our site or sign in, Firebase automatically processes certain information such as:

• IP address and device identifiers
• Browser type and settings
• Authentication data (e.g., email, login method)
• Application identifiers and usage logs

This information is used by Google to operate and secure the Firebase infrastructure and is processed in accordance with Google's Privacy Policy: https://firebase.google.com/support/privacy

Advertising & Cookies

We use Google Ads conversion tracking to measure advertising effectiveness. Google may collect device and browsing information and set cookies to attribute conversions to ad clicks. This data is aggregated and anonymous - we do not receive personally identifiable information. Google processes this data in accordance with their Privacy Policy.

We also use first-party cookies and local storage for security, authentication, and core functionality on our domains (eb.app, my.eb.app).

Your Controls: Use the "Your Privacy Choices" link in our footer to disable marketing cookies, or visit Google Ad Settings to opt out of personalized advertising.

Affiliate Link Tracking: When you click affiliate links in the Offers tab, you leave our app and Amazon's practices apply. See Affiliate Offers & Third-Party Tracking for details.

AI Budget Creation (Both Tiers)

Both free-tier and premium users can use AI Budget Creation to generate budget items from transaction data:

• Premium users: Link your bank via Plaid OR upload bank statement files. This transaction data is sent to Google AI (Gemini API) for AI Budget Creation and reconciliation (matching transactions to budget item events).
• Free-tier users: Use the "AI Budget Creation" (Bring Your Own AI) feature. This feature processes data locally on your device, and no data is sent to Google AI via our servers. You are responsible for any data you copy and paste into an external AI provider.
• AI Budget Creation runs only when you submit the AI Budget Creation modal by clicking the confirmation/checkmark after completing the required fields
• Until you submit the modal, no transaction data is sent to Google AI
• We do not retain the AI input or output after processing; only minimal technical metadata (e.g., job IDs, timestamps) may persist for up to 30 days, then deleted
• Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

Offers AI Analysis (Optional Feature)

The Offers tab is visible to free-tier users and optionally to premium users (if enabled in Settings). By default, offers are generated using in-app analysis without AI processing.

Optional AI Analysis: Users (both free and premium) may optionally click "Try AI Analysis" to get personalized offers, so long as the budget they are viewing does not contain Plaid-linked data.

• When you click "Try AI Analysis," a modal explains what data will be sent: budget summary including item names, amounts, categories, account balances, and balance projections (NOT detailed transaction history)
• You must explicitly confirm to proceed. No data is sent until you confirm.
• Your budget summary is sent to Google AI (Gemini API) to generate personalized offer recommendations.
• This feature is permanently disabled for any budget that contains (or has ever contained) Plaid-linked data. This protection applies to all users, even if you downgrade from premium to free-tier.
• We do not retain the AI input or output after returning results; only minimal technical metadata (e.g., job IDs, timestamps) may persist for up to 30 days, then deleted.
• Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

6. How We Use Your Information

Your Email

We use your email to:

• Create and manage your account
• Send essential account security emails (email verification, password resets, email change confirmations)
• Send security alerts
• Notify you of Terms or Privacy Policy updates
• Send optional service updates (new features, maintenance notices)

Your Budget Data

• Display and calculate your budgets
• Generate reports and forecasts
• Enable data export
• Provide customer support (only when you request it)

Marketing and Analytics Data

We use marketing and analytics data to:

• Measure the effectiveness of our advertising campaigns
• Understand which marketing channels bring users to our service
• Optimize our marketing spend and strategy
• Attribute account sign-ups to specific campaigns

We do NOT use this data to:

• Serve you personalized ads within our app
• Sell to third parties for their advertising purposes
• Make decisions about your account or service access

We NEVER:

• Sell or share your personal information as those terms are defined under the CPRA. If we ever introduce an optional feature that would qualify as a "sale" or "sharing," it would be strictly opt-in with clear disclosures and a Do Not Sell or Share My Personal Information control at launch.
• Use your Budget Data for third-party advertising or cross-site behavioral ads. (Users may optionally use Budget Data for in-app Offers by clicking "Try AI Analysis.")
• Allow human access by our staff to your Budget Data, except (i) when you explicitly request support, (ii) to comply with law, or (iii) to prevent fraud, abuse, or security incidents
• Share your Budget Data with third parties for their advertising. We only share Budget Data with Google AI (Gemini API) to provide: (i) AI Budget Creation when you submit the AI Budget Creation modal; and (ii) Offers AI Analysis when users click "Try AI Analysis" (optional, user-initiated only, and not available for Plaid-linked budgets).

Offers

The Offers tab displays affiliate recommendations of our products or partner offerings.

Free-tier users:

• The Offers tab is always visible
• By default, offers are generated using deterministic, in-app analysis of your Budget Data without AI processing
• You may optionally click "Try AI Analysis" to send a budget summary (NOT transaction history) to Google AI for personalized recommendations
• Before sending data, a modal (titled "Better Offers with AI") explains exactly what will be sent and asks for confirmation
• This is entirely optional and user-initiated - no data is sent to Google AI until you confirm
• Protection for budgets with Plaid data: The "Try AI Analysis" feature is permanently disabled for any budget that contains (or has ever contained) Plaid-linked data. This protection applies even if you downgrade from premium to free-tier, ensuring Plaid-derived data is never sent to the Offers AI. You will see: "AI analysis not available for budgets with bank-linked data"

Premium subscribers:

• The Offers tab is hidden by default
• You can optionally enable the Offers tab in Settings to view offers generated by in-app analysis (without AI)
• If enabled, you may also use the optional "Try AI Analysis" feature, but only on budgets that do not contain Plaid-linked data. The "Try AI Analysis" feature is permanently disabled for any budget containing Plaid data, as described in the "Protection" clause above.

What we don't do:

• We do not sell or rent your data for external advertising
• All offer matching and recommendations occur within EB.app using your local Budget Data
• Plaid transaction data is NEVER used for Offers AI Analysis. The "Try AI Analysis" feature is permanently disabled for any budget containing Plaid-linked data.

Affiliate Disclosure: As an Amazon Associate, we earn from qualifying purchases. See Affiliate Offers & Third-Party Tracking for details about what happens when you click affiliate links.

7. How We Share Your Information

We do not sell or share your personal information as those terms are defined under the CPRA. If we ever introduce an optional feature that would qualify as "sell" or "share," it would be strictly opt-in, with clear disclosures and a Do Not Sell or Share My Personal Information control at launch. Otherwise, we may share certain data with service providers who help us operate our business:

Service Providers We Use

Google Cloud (Infrastructure Provider)

• Purpose: Hosting, authentication, database, and security
• Data Shared: All user data necessary to provide our service
• Processing: Data is processed according to Google Cloud Privacy Notice

Google AI (Gemini API) - AI Budget Creation (Both Tiers)

• Purpose: To generate budget items from transaction data
• Data Shared:
  • Premium users: Plaid transaction data OR uploaded bank statement files when you submit the AI Budget Creation modal
  • Free-tier users: This feature uses a "Bring Your Own AI" model; no raw data is sent to or shared with Google AI via our servers.
• Your Control: No transaction data is sent to Google AI until you submit the AI Budget Creation modal by clicking the confirmation/checkmark
• Processing: Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

Affiliate Offers & Third-Party Tracking (Amazon Associates)

As an Amazon Associate, we earn from qualifying purchases.

The Offers tab may display affiliate product recommendations through the Amazon Associates Program. When you click an affiliate link, you are directed to Amazon.com where Amazon's privacy practices apply.

What happens when you view the Offers tab:

• Offers are matched to your budget data using in-app analysis
• Your financial data is NOT shared with Amazon or any third party
• No tracking occurs until you click a link and leave our app

What happens when you click an affiliate link:

When you click an affiliate link, you leave our app and are directed to Amazon.com. Amazon (not EB.app) may collect information in accordance with their Privacy Notice, including:

• Browser type and device information
• IP address
• Cookie identifiers (set on Amazon's domains, not ours)
• Browsing and purchase activity on Amazon
• Transaction information (if you complete a purchase)

This data collection occurs on Amazon's systems after you leave our app. EB.app does not receive or have access to your Amazon browsing or purchase history. Amazon uses this information to:

• Attribute qualifying purchases to our referral
• Provide product recommendations
• Prevent fraud
• Calculate our affiliate commission

Your choices:

• You are never required to click affiliate links
• You can manage your Amazon privacy settings at amazon.com/privacyprefs
• You can use browser privacy settings to block third-party cookies
• Premium subscribers can hide the Offers tab entirely in Settings

Amazon's Privacy Notice:

Amazon processes data as an independent data controller. For complete information about how Amazon handles your data, please review: Amazon.com Privacy Notice

Commission Disclosure:

As an Amazon Associate, we earn from qualifying purchases made through affiliate links. This compensation helps support the free tier of Essential Budget. Amazon does not sell customer personal information.

What we do NOT share with Amazon:

• Your name or email address
• Your budget data
• Your bank account information
• Your Plaid transaction data
• Any information that directly identifies you

Cross-Context Behavioral Advertising: EB.app does not engage in cross-context behavioral advertising and we do not "share" your personal information with Amazon or advertisers for targeting purposes as defined by the CPRA. The offers shown in our app are matched using only your in-app budget data, which remains on your device and our servers—it is not shared with Amazon.

When you click an affiliate link and leave our app, Amazon's own data practices apply. Amazon processes data as an independent controller subject to their own Privacy Notice.

Google AI (Gemini API) - Offers AI Analysis (Optional Feature)

• Purpose: To provide personalized offer recommendations (optional, user-initiated)
• Data Shared: Budget summary (item names, amounts, categories, account balances, projections) - NOT detailed transaction history
• Your Control: Users must explicitly click "Try AI Analysis" and confirm in a modal before any data is sent. This feature is permanently disabled for any budget containing Plaid-linked data.
• Data Retention: We do not store the AI input or output after returning results; only minimal technical metadata (job IDs, timestamps) may persist for up to 30 days, then deleted
• Processing: Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

Legal Disclosures

We may disclose your information when required by law:

• To comply with legal obligations or court orders
• To protect our rights, property, and safety
• In connection with a business transfer (merger, acquisition)

We require all service providers to protect your data and use it only for the purposes we've specified.

We may promote our own products or direct partner offerings within our application, but we do not share your personal information with these partners for advertising purposes.

8. Data Storage and Security

Where We Store Data

• All data is stored in the United States using Google Cloud
• We use Firebase Auth and Hosting, along with Google Cloud services for database and infrastructure

How We Protect Data

• SSL/TLS encryption for all data transmission
• Encryption at rest for all stored data in Google Cloud
• Google Sign-In with OAuth 2.0 for secure authentication
• Support for Google's 2-Step Verification when enabled on your Google account
• Automatic security updates through Google's authentication infrastructure
• Secure token-based session management handled by Firebase Auth
• No passwords stored by our application - authentication managed entirely by Google

Breach Notification

In the event of a data breach that affects your personal information, we will notify you and any applicable regulatory authorities in accordance with applicable law. Notifications will be made without undue delay and, where required by law, within 72 hours of becoming aware of the breach. We will provide information about the nature of the breach, the data affected, and steps being taken to address the incident.

Data Retention

We are committed to data minimization.

• Active accounts: Data retained while account is active
• Inactive accounts: Scheduled for deletion after 12 months of no login, provided there is no active subscription associated with the account. We will email a reminder before deletion, giving you an opportunity to reactivate your account
• Deleted accounts: Budget data deleted from active systems within 24 hours; may persist in encrypted backups for up to 90 days.
• Plaid-sourced transactions: Retained as part of your Budget Data for as long as your account is active and deleted on account deletion consistent with the timelines above.
• AI processing metadata: Minimal technical logs (e.g., job IDs, timestamps) may persist for up to 30 days, then are deleted. We do not retain AI inputs or outputs.
• AI usage metrics: Aggregated and anonymized after 30 days
• Support records: May be retained longer for legal compliance
• Service discontinuation: In the event EB.app discontinues the Service, all user data will be deleted upon closure after providing at least 30 days' notice (unless prohibited by law or technical limitations) to allow users to export their data

9. Your Rights and Controls

Access Your Data

You can:

• View all your data in the app
• Export your data as JSON or CSV anytime

Update Your Data

• Modify your budget data anytime in the app
• Update your email in account settings

Delete Your Data

• Delete specific budget entries in the app
• Delete your entire account through settings or by emailing us
• When you delete your account, we will permanently delete your personal data from our active production systems within 24 hours. This data may persist in our secure, encrypted disaster recovery backups for up to 90 days, after which it will be permanently erased. (We do not retain AI inputs/outputs; only minimal technical metadata, if any, may persist as described below.)

Communication Preferences

• Opt out of non-essential emails in account settings
• Essential security and account emails (verification, password resets) are automatically sent by Firebase and cannot be disabled

10. Third-Party Services

We use third-party services to operate our application. These services may collect and process your data according to their own privacy policies. We have agreements in place with our service providers that obligate them to protect your data and use it only for the purposes we've specified.

Google Cloud Services

We use various Google Cloud services to host, process, and secure data within our product. These services may include infrastructure, database, AI/machine learning, and image processing capabilities. All Google Cloud services are provided by Google LLC and are subject to the Google Cloud Privacy Notice: https://cloud.google.com/terms/cloud-privacy-notice

Google Cloud services automatically handle certain functions like sending essential account emails (verification, password resets) on our behalf. These services may collect technical information as described in their privacy policies. We've configured these services to minimize data collection where possible.

Amazon Associates Program (Affiliate Marketing)

As an Amazon Associate, we earn from qualifying purchases.

Our Offers tab may contain affiliate links to products on Amazon.com through the Amazon Associates Program.

• Service Type: Affiliate marketing and commission attribution
• Data Collected by Amazon: See Affiliate Offers & Third-Party Tracking section above
• When Collection Occurs: Only after you click an affiliate link and leave our app to visit Amazon.com
• Privacy Notice: Amazon.com Privacy Notice
• Controller Status: Amazon processes data as an independent data controller
• Data Selling: Amazon does not sell customer personal information

EB.app does not transmit your personal information to Amazon. Any data Amazon collects is gathered directly by their systems when you click an affiliate link and visit Amazon.com.

MailerLite (Email Marketing)

We use MailerLite to deliver email communications, including lead magnets, newsletters, and educational content about budgeting.

• Service Type: Email marketing and automation platform
• Data Collected: Email address, first name (if provided), subscription preferences, email engagement data (opens, clicks), and signup source information
• When Collection Occurs: When you subscribe to our newsletter, download a lead magnet (e.g., Budget Starter Kit), or opt in to receive email communications
• Purpose: To deliver requested content, send educational emails, and provide updates about budgeting tips and our service
• Data Retention: Your email data is retained until you unsubscribe or request deletion. Inactive subscribers (no engagement in 60+ days) may be moved to a re-engagement segment or removed
• Privacy Policy: https://www.mailerlite.com/legal/privacy-policy
• Controller Status: MailerLite acts as our processor/service provider for email delivery. EB.app remains the controller of your personal information

Your Controls:

• Every email includes an unsubscribe link
• You can update your preferences or unsubscribe at any time
• To request deletion of your email data, contact us at legal@eb.app

What We Track: MailerLite automatically tracks email opens and link clicks to help us understand what content is valuable to our subscribers. This data is used to improve our email content and is not shared with third parties for advertising purposes.

Payment and Billing Information

Our premium subscriptions are handled by our Merchant of Record, Paddle.

As the legal seller (Merchant of Record) for all transactions, Paddle is responsible for payment processing, invoicing, tax remittance, and refund execution. When you purchase or request a refund, your transaction and payment data are processed directly by Paddle under their Buyer Terms. We receive only limited, non-sensitive data such as your name, subscription status, and transaction ID to manage your account. The information you provide to them is subject to Paddle's Privacy Policy, which you can review here: https://www.paddle.com/legal/privacy.

We do not collect or have access to your full payment card details. For details on refund eligibility, timelines, and cancellation procedures, please refer to our Billing Policy.

Paddle may process limited billing information for refund issuance and dispute resolution in accordance with their Privacy Policy.

AI Services

Processor Role: For AI Budget Creation and Offers AI Analysis, Google acts as our processor/service provider via the Gemini API. EB.app remains the controller of your personal information.

A. AI Budget Creation (Both Tiers)

AI Budget Creation generates structured budget items (income, expenses, transfers) from your transaction data.

Available to Both Tiers:

• Premium users: Link your bank via Plaid OR upload bank statement files. Transaction data from either source is sent to Google AI (Gemini API) to generate budget items and for reconciliation.
• Free-tier users: Use the "AI Budget Creation" (Bring Your Own AI) feature. This processes data locally on your device. No raw data is sent to Google AI via our servers for this free-tier feature.

When AI Processing Occurs:

• AI processing begins only when you submit the "AI Budget Creation" modal by clicking the confirmation/checkmark
• While the modal may be shown as part of the budgeting workflow, no data is transmitted to Google AI until you explicitly submit the modal
• This explicit submission constitutes your authorization for processing

Data Handling:

• Free-tier users: The "Bring Your Own AI" feature processes data locally. We do not receive, store, or transmit your original bank statement files. We only store the resulting budget data you import back into the app.
• Premium users: Plaid transaction data or uploaded bank statement files are sent to Google AI for budget creation and reconciliation. Uploaded files are discarded after processing. Only the final derived budget items are stored in your account.
• We do not log or store the raw transaction content. Only minimal technical logs (e.g., job IDs, timestamps) may persist for up to 30 days, then are deleted
• Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

B. Offers AI Analysis (Optional Feature)

The Offers tab is visible by default to free-tier users. Premium subscribers have the Offers tab hidden by default but can enable it in Settings. By default, offers are generated using in-app analysis without AI processing.

Optional AI Analysis:

• Users (both free and premium) may optionally click "Try AI Analysis" to get personalized offer recommendations.
• This feature is permanently disabled for any budget that contains (or has ever contained) Plaid-linked data.
• Before sending data, a modal (titled "Better Offers with AI") explains what data will be sent: budget summary including item names, amounts, categories, account balances, and balance projections (NOT detailed transaction history)
• You must explicitly confirm to proceed. No data is sent until you confirm.
• Your budget summary is sent to Google AI (Gemini API) to generate personalized offer recommendations.
• We do not retain the AI input or output after returning results; only minimal technical metadata (e.g., job IDs, timestamps) may persist for up to 30 days, then deleted.
• Processing is performed via the Google Gemini API. In accordance with the Gemini API Terms of Service, Google does not sell your data to any third party or use it to train its AI models.

11. Children's Privacy

Our Service is intended for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. Because we use Google Sign-In, we do not request or receive date of birth as part of account creation; instead, by signing in and using the Service, you represent and affirm that you are 18 or older.

If we become aware that an account belongs to someone under 18, we will promptly delete the account and all associated personal information. If we learn that personal information about a person under 18 has been submitted to us through another user's account or otherwise, we will delete that information as well.

If you believe that a person under 18 may have used the Service or provided personal information to us, please contact us at legal@eb.app so we can investigate and take appropriate action.

12. Geographic Availability and International Users

Service Location and Data Transfers

Our Service is hosted and operated in the United States and is intended for residents of the United States. You may access your account while traveling in other locations; however, regardless of where you access the Service from, you consent to your personal information being transferred to, stored, and processed in the United States.

CCPA/CPRA Rights (California Users)

You have the right to:

• Know what personal information we collect
• Access your personal information
• Request deletion
• Non-discrimination for exercising your rights
• Opt-out of data sales (we do not sell personal information except if you actively opt in to an optional feature that clearly discloses any associated data exchange; if you opt in, you may opt out at any time)

We do not "share" personal information for cross-context behavioral advertising as defined by the CPRA. If a future optional feature would constitute a "sale" or "sharing" under CPRA, it will require your affirmative action to use it, and we will present clear disclosures and provide a "Do Not Sell or Share My Personal Information" control at launch.

Affiliate Links and CPRA: EB.app does not "sell" or "share" your personal information to Amazon or advertisers as those terms are defined under CPRA. The offer matching in our app uses your budget data locally; this data is not transmitted to any third party. When you click an affiliate link, you leave our app and Amazon collects data directly on their platform. Amazon's data collection is subject to their own privacy practices and CPRA compliance obligations. Amazon does not sell customer personal information. You can manage your Amazon privacy preferences at amazon.com/privacyprefs.

You can exercise these rights by contacting us at legal@eb.app or through your account settings. We will verify your identity before processing your request to protect your privacy and security.

Response Time: We will respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically unless you request otherwise.

Identity Verification: To verify your identity, we may ask you to provide information such as your email address, account details, or other information we maintain about you. The information we request will depend on the sensitivity of the request and the potential risk of fraud.

Other State Privacy Laws

Residents of certain U.S. states, including Colorado, Connecticut, Utah, and Virginia, have additional privacy rights under their respective state laws. These rights may include the ability to access, correct, delete, and obtain a copy of your personal information, as well as opt out of certain data processing activities. If we deny your request, you have the right to appeal our decision. To exercise your rights or submit an appeal, please contact us at legal@eb.app.

13. Contact Information

For privacy questions or to exercise your rights, contact us by email or by mail:

• Email: team@eb.app
• Legal Notices: legal@eb.app
• Mailing Address: 30 N Gould St #52260, Sheridan, WY 82801

Policy Updates

• November 26, 2025 – Added affiliate program disclosures.
• December 4, 2025 – Added support communications guidance.
• December 10, 2025 – Added Google Ads tracking, marketing attribution, email marketing (MailerLite), and privacy opt-out controls; updated affiliate program to Amazon Associates.