Privacy Policy

This Policy explains what we collect, why, how we use and share it, and your rights.

Effective date: August 1, 2025

Owner/Controller

AEY GROUP

P.O. Box 5863, Nairobi, Kenya

Website

https://bankstatementsavvy.com

Contact (Privacy Requests)

hello@aey-group.com

Hosting

Primarily in the United States

1. Scope & Roles

Controller (GDPR)

For account, billing, marketing, and website analytics data, AEY GROUP acts as Data Controller.

Processor (GDPR)

For customer-submitted PDF bank statements processed on behalf of business customers, we act as Data Processor and will sign a Data Processing Addendum (DPA) upon request.

Territorial Scope

We serve users globally. We are established in Kenya and host primarily in the United States.

2. Data We Collect

a) You provide to us

Account & Auth

Name, email, password hash, workspace/team details.

Files

Uploaded PDFs (bank statements) and file metadata (name, size, page count).

Billing

Plan, invoices, transaction metadata; card data is handled by Paystack—we do not store full card numbers.

Support

Messages, attachments, contact details.

b) Collected automatically

Device & Usage

IP address (for security/fraud), user-agent, timestamps, basic telemetry (e.g., upload start/completion, conversion success/failure).

Cookies/SDKs

Strictly necessary cookies for login/session/CSRF; optional analytics/performance cookies subject to consent.

c) Sensitive/financial context

Bank statements can include personal and financial details. While not "special category" under GDPR by default, we treat them as highly sensitive and secure them accordingly.

3. Purposes & Legal Bases (GDPR Art. 6)

Contract (Art. 6(1)(b))

To provide the Service (file upload/conversion, account access, billing, support).

Legitimate Interests (Art. 6(1)(f))

To secure and improve the Service, prevent fraud/abuse, ensure reliability, and measure essential product usage (balanced against your rights).

Consent (Art. 6(1)(a))

Where required for non-essential cookies/analytics and marketing communications; you may withdraw consent anytime.

We follow GDPR principles (lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality).

4. How We Use Your Files

  • Automated conversion of PDFs to CSV/XLSX/JSON/Markdown.
  • Quality/accuracy checks using aggregate, de-identified metrics.

Default Retention

Subscribers

We retain uploaded PDFs and derived outputs for as long as your subscription is active, unless you delete them earlier.

After Subscription Ends

Files and outputs are deleted within 30 days; account data retained as required for legal, tax, and fraud-prevention purposes.

You can delete files at any time from within the product; deletions propagate from active storage and backups per our rotation schedule.

Important: We do not use customer files to train machine-learning models unless you explicitly opt in.

5. Sharing & Sub-processors

We share data only as needed to operate the Service, under contracts that bind providers to confidentiality, security, and purpose limitation.

Current Sub-processors / Tools

Hosting/Infra/Storage

DigitalOcean, Amazon Web Services (AWS)

Payments

Paystack

Analytics/Diagnostics

Mixpanel, Google Analytics 4 (GA4), Google Search Console, PostHog, Sentry (error monitoring)

We maintain a live list at /legal/subprocessors and will notify customers of material changes where required.

6. International Transfers

We primarily host in the United States. If personal data is transferred from the EEA/UK to countries without an adequacy decision, we use Standard Contractual Clauses (SCCs) or other lawful safeguards. Where a vendor participates in the EU-U.S. Data Privacy Framework (DPF), we rely on that participation where applicable. We conduct transfer risk assessments as required.

7. Your Rights

GDPR (EEA/UK)

You have the right to access, rectify, erase, restrict, port, and object to processing; and to withdraw consent where processing is based on consent. You may lodge a complaint with your supervisory authority.

We respond within one month (extendable as permitted).

U.S. (CPRA/CCPA and similar)

California residents (and, where applicable, other U.S. states) have rights to know/access, delete, correct, portability, and to opt-out of sale/sharing and targeted advertising.

We do not sell personal information.

How to exercise rights: Email hello@aey-group.com or visit /privacy-request. We will verify your request and respond as required.

8. Security

We implement technical and organizational measures appropriate to the risk (GDPR Art. 32), including encryption in transit and at rest, access controls, network isolation, key management, monitoring, and incident response. We regularly review access privileges and rotate secrets. No method is 100% secure, but we continuously improve safeguards.

9. Cookies & Tracking

  • Strictly necessary cookies enable login, session, and CSRF protection.
  • Analytics/Performance (Mixpanel, GA4, PostHog, Sentry) are consent-based where required by ePrivacy/PECR; we avoid sending PII and minimize identifiers.
  • Manage preferences via our Cookie Settings and your browser. In the EEA/UK, non-essential cookies are set only after consent.

A separate Cookie Policy with a detailed cookie table is available at /legal/cookies.

10. Marketing Communications & GPC

  • We send service emails (account, billing, security). Marketing emails are sent with consent where required; you can unsubscribe any time.
  • For U.S. recipients, we comply with CAN-SPAM (accurate headers, non-deceptive subjects, physical address in footer, working opt-out).
  • Global Privacy Control (GPC): We recognize and honor GPC signals in applicable jurisdictions as requests to opt-out of "sale"/"sharing" and targeted advertising.

11. Data Retention

We keep personal data only as long as necessary for the purposes above or as required by law.

Defaults (unless your plan or law dictates otherwise)

Uploaded PDFs & Derived Outputs

Active subscribers: Retained until deletion or subscription end.
Post-cancellation: Files and outputs deleted within 30 days.

Account & Billing Records

Retained for 7 years (tax/audit).

Support Tickets & Logs

Retained for 12 months unless required longer for security, fraud prevention, or legal claims.

Backups

Rotate on a rolling schedule; data is purged upon rotation.

12. Children

The Service is not directed to children under 16 (or higher local age). We do not knowingly collect children's data. If you believe we have, contact us for deletion.

13. Automated Decision-Making

We do not make decisions producing legal or similarly significant effects solely by automated processing. If this changes, we will disclose details and safeguards.

14. Changes to This Policy

We may update this Policy from time to time. We will post the revised version with an updated effective date and, if changes are material, notify you via email or in-app.

15. Contact

Controller

AEY GROUP, P.O. Box 5863, Nairobi, Kenya

Email (Privacy & Data Requests)

hello@aey-group.com

EU/UK Representative (Art. 27)

If required, we will designate and publish an EU/UK representative; until then, contact us at the email above.

Annex A — State Privacy Addendum (U.S.)

Where applicable (e.g., CA, CO, CT, VA, UT), we honor state rights to access, delete, correct, portability, and to opt-out of targeted advertising, sale/sharing, and certain profiling. We provide Do Not Sell/Share and Limit Use of Sensitive Personal Information controls if/when our activities require them, and we honor GPC signals in applicable jurisdictions. We do not retaliate against individuals for exercising their rights.

Notes for Publication

  • • Company: AEY GROUP (Kenya), hosting in USA.
  • • Sub-processors: DigitalOcean, AWS, Mixpanel, GA4, Google Search Console, PostHog, Sentry, Paystack.
  • • Retention: subscribers retain files while active; post-end 30-day purge; logs 12 months; billing 7 years.
  • • Encryption: in transit and at rest.
  • • GPC / Do-Not-Sell-or-Share: we honor GPC and will expose disclosures/links if our activities ever qualify.

Not legal advice. For regulated customers or EU targeting at scale, have counsel review and consider appointing an EU/UK Art. 27 representative and publishing a DPA at /legal/dpa.

This Privacy Policy is comprehensive and legally compliant. For questions or to exercise your rights, contact us at hello@aey-group.com.