Privacy Policy

1. Controller

The data controller responsible for your personal data is:

SaveShore UG (haftungsbeschränkt)
Antwerpner Str. 5
13353 Berlin, Germany
hello@saveshore.com

2. Data We Collect

Account data. Your name, email address, and hashed authentication credentials. Device biometric data (Face ID, Touch ID, or equivalent) is stored exclusively on your device and is never transmitted to our servers.

Identity verification data. Document type, verification outcome, date of birth, and liveness check result. This data is collected and processed by FinAPI GmbH on our behalf solely for the purpose of identity verification. We store only the outcome (passed / failed), the verification reference ID, and the timestamp of completion. No raw identity document data is retained by Saveshore.

Bank account data. Your IBAN, transaction history (up to 90 days), account balances, and derived signals including salary patterns and spending categories. This data is retrieved read-only via FinAPI under PSD2 AISP authorisation. Saveshore cannot initiate payments or access your banking credentials.

Saving and platform data. Your saving configuration, pot allocation state, transfer history, Shore AI conversation logs, and financial behaviour signals derived from your transaction data.

Device and usage data. App usage events collected for product improvement and security purposes. No advertising identifiers are collected or processed.

3. Legal Bases

We process your personal data on the following legal bases under the GDPR:

• Art. 6(1)(b) — performance of contract: account management, saving engine operation, and subscription administration
• Art. 6(1)(a) — your explicit consent: open banking connection and automated financial analysis
• Art. 6(1)(c) — compliance with legal obligations: identity verification and anti-money laundering requirements under the German Money Laundering Act (GwG)
• Art. 6(1)(f) — legitimate interests: fraud prevention, platform security, and product improvement

Where we rely on consent as the legal basis, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Withdrawing consent for open banking will pause saving engine functionality, as that data is required for the service to operate.

4. Automated Processing

Saveshore uses automated analysis of your bank transaction data to generate personalised saving suggestions and spending insights. This constitutes automated processing under Article 22 GDPR. Your explicit consent is obtained during onboarding before any analysis begins.

No automated action is executed without your explicit confirmation. You may withdraw consent for automated analysis at any time from Settings, which will pause saving engine functionality.

5. Data Storage and Infrastructure

All personal data is stored exclusively on Microsoft Azure infrastructure located in the EU Frankfurt (Germany) region. No personal data is transferred outside this region. No personal data leaves the European Economic Area under any circumstances.

6. Data Sharing

We share your personal data only with the following processors, under written data processing agreements in accordance with Art. 28 GDPR:

• FinAPI GmbH — open banking data retrieval and identity verification
• Anthropic, PBC — AI conversation processing. Only your financial context payload is transmitted. No raw bank transaction data is sent to Anthropic.

We do not sell, rent, or share your personal data with advertisers, data brokers, or any third party not listed above.

7. Data Retention

Data Category
Retention Period

• Active account data — Duration of subscription plus 30 days following confirmed deletion
• Bank transaction data — 90-day rolling window, refreshed on each sync
• Identity verification records — 5 years after account closure (GwG requirement)
• Financial event ledger — 10 years for accounting purposes (HGB § 257)
• Rejected KYC accounts — Deleted within 30 days of rejection

Following account deletion, all personal data not subject to a statutory retention obligation is purged within 30 days.

8. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

• Access — the right to obtain a copy of the data we hold about you
• Rectification — the right to correct inaccurate or incomplete data
• Erasure — the right to request deletion, subject to statutory retention obligations
• Portability — the right to receive your data in a structured, machine-readable format
• Restriction — the right to limit how we process your data in certain circumstances
• Objection — the right to object to processing based on legitimate interests

To exercise any of these rights, contact us at hello@saveshore.com or use the data export and deletion tools available in Settings. We will respond within 30 days of receiving your request.

9. Security

We implement the following technical and organisational measures to protect your personal data:

• TLS encryption for all data in transit
• Encryption at rest for all stored personal data
• JWT-based session management with 7-day expiry
• Biometric authentication stored on-device only, never transmitted
• Rate limiting and brute-force protection on all authentication endpoints
• Access controls limiting internal data access to those with operational need

10. Supervisory Authority

You have the right to lodge a complaint with the competent supervisory authority at any time:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
datenschutz-berlin.de

11. Changes to This Policy

We will notify you of material changes to this Privacy Policy by email and in-app notification at least 14 days before they take effect. The effective date at the top of this document will be updated on each revision.

If you have questions about this policy or how we handle your data, contact us at hello@saveshore.com.

SaveShore UG (haftungsbeschränkt) · Antwerpner Str. 5 · 13353 Berlin · Germany