KupaPay — Privacy Policy

DRAFT — not reviewed by a lawyer. Do not publish before review. Last updated: 2026-10-16

1. Controller

Sarussilberg, an individual in Israel (exempt dealer), operator of KupaPay. Address: Shlomo HaMelech 41, Lod 7136477, Israel. Contact for privacy: sarussilberg@gmail.com. This policy is written to meet Israel's Protection of Privacy Law, 5741-1981, as amended (including Amendment 13), and the EU GDPR. EU representative (GDPR Art. 27): [OPEN ITEM — see note at the end].

2. What we collect

Account data: email, display name, login identifiers (e.g. Apple/Google sign-in) [verify which].
Group and expense data: groups, members' names as entered by users, expenses, amounts, currencies, notes. This can include data about people who entered it about you.
Purchase data: subscription and Trip Pass status, transaction IDs, store, country (we never receive card details).
Usage and device data: app interactions, device model, OS, app version, anonymous app user ID, IP-based approximate location.
Crash and diagnostic data: error reports and performance data.
Advertising data (free version): device advertising identifiers (IDFA/GAID, only where permitted), ad interactions. We don't ask for sensitive data. Please don't enter it in notes.

3. Purposes and legal bases (GDPR)

| Purpose | Legal basis | |---|---| | Running the app: account, groups, balances, sync | Contract (Art. 6(1)(b)) | | Purchases and Pro access | Contract; legal obligation for records | | Crash reports, security, fraud prevention | Legitimate interests (Art. 6(1)(f)) | | Product analytics | Legitimate interests, or consent where required [verify ePrivacy for device access] | | Personalized ads | Consent (Art. 6(1)(a)); ATT on iOS | | Non-personalized ads | Legitimate interests [verify; consent may still be needed for device storage access] | | Keeping shared expenses after deletion (anonymized) | Legitimate interests of other group members | | Legal claims and obligations | Legal obligation / legitimate interests |

4. Processors and where they are

| Service | Role | Country | |---|---|---| | Supabase, Inc. | Backend database, auth, hosting | USA; data region [verify, e.g. EU] | | Functional Software, Inc. (Sentry) | Crash and error reports | USA [verify region] | | PostHog, Inc. | Product analytics | USA / EU [verify cloud region] | | RevenueCat, Inc. | Subscription and purchase management | USA | | Google LLC (AdMob) | Rewarded ads | USA | | Apple Inc. / Google LLC | App stores, payments | USA / Ireland | | Vercel Inc. | Website hosting | USA | Google AdMob acts as an independent controller for some ad data; see Google's policy (policies.google.com/privacy).

5. Transfers abroad

Some processors are outside Israel and the EU. For EU data, we rely on the EU–US Data Privacy Framework where the provider is certified, or on Standard Contractual Clauses. For Israeli data, transfers follow the Privacy Protection (Transfer of Data to Databases Abroad) Regulations, 5761-2001 [verify]. You can ask us for a copy of the safeguards.

6. Ads

The free version shows rewarded ads through Google AdMob.

iOS: we only use the advertising identifier if you allow tracking in Apple's App Tracking Transparency prompt. If you decline, you get non-personalized ads.
EU/EEA/UK: before ads load, we ask for your consent through Google's consent tool (UMP). You can change your choice anytime in Settings → Privacy [verify the menu path].
Android: you can reset or delete your advertising ID in device settings. Pro users don't see ads.

7. Retention

Account data: until you delete your account.
Shared expenses: kept for the group after deletion, with your name replaced by an anonymous label.
Crash and analytics data: up to [90 days / 12 months — verify provider settings].
Purchase records: as required by tax law [verify; typically 7 years in Israel].
Backups: deleted on a rolling basis within [30] days.

8. Deleting your account

Settings → Delete account. We delete your account and personal data, except shared expenses (anonymized) and records we must keep by law. Deleting the app or account doesn't cancel a subscription; cancel in store settings.

9. Your rights

You can ask to access, correct or delete your data, and (in the EU) to restrict or object to processing, to data portability, and to withdraw consent at any time. Israeli law gives you rights to inspect and correct information. Write to sarussilberg@gmail.com; we reply within 30 days [verify Israeli deadline]. You can complain to the Israeli Privacy Protection Authority (הרשות להגנת הפרטיות) or to your local EU data protection authority.

10. Minimum age

KupaPay is not for children. You must be at least 16 [verify: EU member states range 13–16; Israel — verify]. We don't knowingly collect children's data; if we learn of it, we delete it.

11. Security

We use encryption in transit, access controls and row-level security on our database. No system is perfectly secure; we will notify authorities and users of serious breaches as the law requires.

12. Changes

We will notify you in the App of material changes.

13. Contact

Sarussilberg, Shlomo HaMelech 41, Lod 7136477, Israel, sarussilberg@gmail.com

Open item — EU Art. 27 representative: the controller is not established in the EU but targets EU users, so GDPR Art. 27 likely requires a written EU representative. The "occasional processing" exception is unlikely to apply to a continuing app service. Appoint one (commercial services exist) and add the details to §1 before EU launch.