Skip to content

Privacy Policy

Version: v4.0
Publication date: 2026-10-16
Last updated: 2026-10-16

This notice is provided from the publication date above to explain the processing described below. It does not establish a historical date for the company's takeover of the Service or change existing contracts by itself. An in-app acknowledgment records that the notice was presented; it is not what starts our responsibility for processing or supplies consent to optional processing.

This notice explains how personal data is handled when you use the ARKAD Wallet mobile application, related account services, and this legal-center website. It covers information you provide, information received from a bank through Kontomatik at your request, and technical information generated during use. Reading or accepting this notice is not consent to optional processing.

Bank connections at a glance: connecting a bank is optional and requires Premium. When you authorize a connection, ARKAD receives and stores account and transaction information through Kontomatik to provide your financial history and budgeting tools. This includes account numbers, balances, and transaction details; it does not give ARKAD your bank password or PIN or allow us to move your money. Access to personal data is limited to authorized personnel with a business need. Disconnecting stops our further imports, while previously imported history remains until deleted under the rules below. Contact ARKAD for requests concerning your ARKAD data; contacting Kontomatik separately is not a prerequisite for deleting your ARKAD account. Sections 2.3, 4, 5, and 8 explain the data, provider roles, retention, and rights in full.

1. Controller and contact

The controller responsible for personal data processed to provide ARKAD Wallet is PROJEKT ARKAD SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, abbreviated Projekt ARKAD Sp. z o.o., a Polish limited liability company registered in the Rejestr Przedsiębiorców:

  • KRS: 0001253732; NIP: 6772544772
  • Registered office and correspondence address: ul. Kazimierza Morawskiego 5/127, 30-102 Kraków, Poland
  • Contact for privacy questions and rights requests: [email protected]

“We” and “us” mean that company. ARKAD Wallet is the product name. Earlier archived policies identify the individuals who previously operated the Service; the current controller is the company identified above. This notice does not change the identity of the controller for historical processing retrospectively.

2. Information we process and its sources

2.1 Account and preferences

We process your email, authentication provider, account creation and login dates, name if supplied, date of birth used for age eligibility, and preferences such as currency and theme. Password authentication is handled by Supabase; we do not directly store your login password. Apple or Google may provide the identity information you authorize when using their sign-in services.

2.2 Financial records and app activity

You provide account names, types, currencies and balances; transactions with amounts, titles/descriptions, dates and account links; categories; budgets and allocations; and savings goals with their amounts, dates, status, and linked accounts. We also process historical snapshots and derived indicators, including the ARKAD Aura progress score and its components for spending against your plan, money allocation, tracking habits, and savings/investment progress. These calculations use your financial records to show activity and progress. Access to the overall Aura score and Smart insights depends on the plan rules in Section 4 of the Terms; restricting access to Smart insights does not make the underlying records anonymous. Records may be entered manually, created from voice-assisted drafts you confirm, or imported from a bank under Section 2.3.

Onboarding questions about financial circumstances, such as debt or housing, are processed temporarily for onboarding logic and suggestions and are not retained as separate onboarding records in our database.

2.3 Bank data received through Kontomatik

If you choose the Premium bank-connection feature, your selected bank is the source of the data, which we receive through Kontomatik following the bank/provider authorization flow. Depending on the bank and accounts selected, the import processes:

  • bank and account identifiers, including an IBAN or other account number, product name/type, currency, and bank-reported balance;
  • transaction amounts, transaction/booking dates, titles or payment references, merchant/counterparty information, transaction type/status, and balances provided with transaction records;
  • identifiers linking the provider connection and bank accounts to your ARKAD account, authorization reference and expiry, connection/disconnection dates and status, and account mappings;
  • import times, outcomes, error codes, refresh counters, and transaction fingerprints used to avoid duplicates, including records needed to avoid re-importing a deleted transaction.

Bank records can also contain personal data of joint account holders and transaction counterparties, such as names, account numbers and payment references. We receive that information from the bank through Kontomatik, or from records you enter, rather than directly from those people. We use it only as needed to display and reconcile your financial records. Those people can use the contact and rights routes in Sections 1 and 8 even if they do not have an ARKAD account.

We send Kontomatik an internal user reference and the connection/import requests needed to provide the feature. We retain a provider access reference used for authorized repeat imports. This is distinct from your bank password, PIN, or one-time authentication code, which ARKAD does not receive or store.

We convert the relevant bank data into application records and connection metadata. We do not maintain a separate archive of complete raw import responses. Technical error diagnostics may include fragments of provider responses; these are handled as restricted diagnostic data under Sections 2.5, 5, and 7. The absence of a raw-response archive does not mean that no bank data is stored.

Transactions are marked as imported and uncategorized in ARKAD. We do not enable Kontomatik transaction labeling, credit scoring or financial profiling for this feature. The bank import itself does not send those records to ElevenLabs or Mistral AI for automatic categorization or enrichment. Processing by Kontomatik is described in Section 4. Other processing you separately request, such as voice-assisted entry, is described below.

Connecting is optional. Without authorization, we cannot fetch bank data; you can continue manual budgeting. Disconnecting stops further imports from that connection, but does not automatically delete previously imported history. See Sections 5 and 8 for retention and your rights.

2.4 Voice processing

If you use voice entry, audio is sent through our backend to ElevenLabs for transcription. Transcribed text is sent to Mistral AI to extract transaction details and suggest categories. You can review the resulting draft before saving it. We do not retain raw voice recordings after processing. ElevenLabs model-improvement use is disabled in our account settings. Provider-side handling follows the applicable service settings and terms.

2.5 Technical, diagnostic, and support data

We process IP addresses, request/device metadata, timestamps, server logs, and error/crash/performance information to operate and secure the Service. Sentry supports diagnostics using its EU data location. Error diagnostics can include fragments of provider responses as described in Section 2.3. When you contact us, we process your contact details, correspondence, and information you choose to provide to resolve the request. Never send bank passwords, PINs, or one-time codes to support.

Support is available by email, through our Telegram bot, or by messaging our Facebook page. If you choose a messaging channel, we receive the message and the account identifiers/profile information made available by that platform. The Telegram bot forwards support messages to our team's support group; our team replies manually. The platforms also handle your communications under the Telegram Privacy Policy or Meta Privacy Policy. You can use email instead, and do not need either platform to exercise your ARKAD privacy rights. Share only the information needed to resolve your issue.

On the legal-center website, we may read your browser’s preferred language to choose the homepage language. A choice you make using the PL/EN switch is saved locally in your browser to remember that preference. We do not use device location or IP geolocation for this purpose. The language preference is not sent to an analytics provider. You can change it using the switch or remove it by clearing site data.

The website hosting service receives the technical request data needed to deliver pages, such as your IP address, requested URL, time and browser metadata. Website delivery and security are based on our legitimate interest in making legal information available reliably. The website uses system fonts without external font requests; its language switch does not load an analytics or advertising SDK.

2.6 Product analytics

Amplitude helps us understand feature use and improve the app. It uses the EU server zone, with session tracking disabled in our configuration. Data includes:

  • an opaque internal user identifier associated after login and cleared on logout;
  • events for sign-in, onboarding, transaction creation, budget/account/goal actions, subscription screens, settings, and screen views; event properties can include the entry source and transaction type, changed-field names/counts, budget month/category count, account type/currency, whether a starting balance was set, and goal state;
  • SDK metadata such as device model/manufacturer, OS/app versions, carrier, locale/timezone, IP address and approximate location derived from it, device identifiers, and event times.

We do not send email, name, date of birth, transaction amounts/descriptions, category names, goal names, bank account numbers, or other financial content to Amplitude. Internal/device identifiers and associated usage data are pseudonymous personal data, not anonymous information.

Airbridge (AB180 Inc.) processes link/referral/campaign identifiers, install/open/deep-link events, IP address, device/app metadata, advertising identifiers where permitted, and iOS App Tracking Transparency (ATT) status where applicable. We use this to route links, attribute campaigns/referrals, and administer referral benefits. We also retain the referral association and entitlement information needed to apply those benefits. We do not send financial records, bank account data, budgets, goals, audio, or transcribed voice content to Airbridge.

Where device storage/access or advertising tracking requires consent, that permission is separate from accepting this policy. On iOS, ATT permission is requested where Apple's tracking rules apply and can be changed in system settings. ATT permission does not replace any separate consent required under privacy or electronic-communications law. See Section 3.

2.8 Payments and subscriptions

Apple and Google Play process store payments under their own privacy notices. ARKAD does not collect card details. We and RevenueCat process app user identifiers, purchase/receipt references, subscription status, period and expiry, and device/platform information to verify Premium, maintain purchase history, and administer benefits. RevenueCat does not receive your payment card details from us.

2.9 Email

Resend receives recipient email addresses, message content, and relevant preference information to deliver account/security messages, password resets, subscription notices, legal updates, and replies. Optional product announcements, tips, and feedback requests are sent only with the consent required by law. Each optional email provides an unsubscribe method; you can also contact us to withdraw consent. Essential service messages do not depend on marketing consent.

Under the General Data Protection Regulation (GDPR/RODO), we use:

Purpose Legal basis
Provide the account, budgeting, synchronization, requested voice processing, optional bank imports you activate, subscription entitlements, requested referral benefits, and support relating to your Service contract Performance of the contract, Article 6(1)(b)
Secure and diagnose the Service, prevent abuse, manage connection quotas, respond to general inquiries, and establish or defend claims Legitimate interests, Article 6(1)(f): reliable and secure operation and protection of our and users' rights, subject to your interests and rights
Meet applicable accounting, tax, consumer, and data-protection duties Legal obligation, Article 6(1)(c)
Handle incidental data of joint account holders and counterparties contained in financial records Legitimate interests, Article 6(1)(f): providing accurate financial records to the account user, limited to necessary information and subject to the other person's interests and rights
Optional email communications, product analytics, and advertising attribution Consent, Article 6(1)(a), together with applicable electronic-communications requirements; accepting the Terms or this notice does not grant that consent

Bank access authorization under the bank/Kontomatik flow enables access to the selected accounts. Kontomatik's own account-access notice identifies consent under Article 6(1)(a) for its access service and sharing with your selected recipient. This is distinct from ARKAD's contract basis for providing your requested budgeting service, and from optional analytics or marketing consent. Revoking bank access stops future fetching; it does not retrospectively invalidate processing or automatically erase records retained on another lawful basis.

Where Article 399 of the Polish Electronic Communications Law requires consent to store/access information on your device, legitimate interests do not replace that consent. Optional email communications are subject to Article 398 where applicable. Necessary device storage/access for a service expressly requested by you is treated separately. Declining optional consent does not prevent manual budgeting. You may contact us about consent withdrawal or an objection; operating-system advertising permissions can also be changed in device settings.

Account data needed to register and provide the Service is necessary for the contract; without it we cannot provide an account. Bank access, voice entry, and optional communications are voluntary; declining them affects those features, not the availability of the Free manual-budgeting service. Legally required billing records may be necessary for a paid transaction.

4. Recipients and service providers

We disclose information only for the relevant service or another lawful purpose. Providers processing on our behalf are subject to the safeguards required by GDPR Article 28. Some recipients separately determine their own purposes under their own notices.

Recipient Role and relevant data
Supabase Authentication and identity infrastructure, using an EU region; account/sign-in information
Hetzner Backend and PostgreSQL hosting in Helsinki, Finland; application records and operational data
ElevenLabs Voice-to-text processing of submitted audio
Mistral AI Text-based transaction extraction and suggested categorization for voice input
Sentry Error/performance diagnostics, EU data location
Amplitude Pseudonymous product analytics described in Section 2.6, EU server zone
Airbridge / AB180 Inc. Deep links, referrals, and attribution described in Section 2.7
Resend Email delivery
Telegram Optional support through our bot; messages and platform account/profile information; its own platform processing follows its privacy notice
Meta (Facebook/Messenger) Optional support through our Facebook page; messages and platform account/profile information; its own platform processing follows its privacy notice
RevenueCat Purchase and subscription entitlement processing
Apple and Google App distribution, sign-in where selected, and store billing; independent controllers for their own processing
Kontomatik sp. z o.o. Account information access as an independent controller; receiving, organizing and making data available to us as a processor; see below

Our bank-integration provider is Kontomatik sp. z o.o., ul. Bonifraterska 17, 00-203 Warsaw, Poland, KRS 0000338706. For the account information service, Kontomatik acts as an independent controller: it accesses the bank data you select and shares it with ARKAD under your authorization. When receiving that data on our behalf, organizing it and making it available to us, it acts as a processor on our instructions. ARKAD remains the controller for data used to provide your account and budgeting service.

The information available to Kontomatik depends on the bank, accounts and authorization given. Besides account and transaction data, it may include account-holder and joint-holder information such as name, address, contact details, tax or national identifiers (including PESEL where supplied), identity-document details, citizenship, nationality, date and place of birth, as well as bank-product/card information, available funds, debt and counterparty details. Kontomatik also processes device and access metadata for its access service under its own notice. Section 2.3 describes the records ARKAD saves; not every item available to the provider is saved as an application record.

Our agreement permits Kontomatik to use service data for quality improvement and training its own analytical models only after full anonymization that prevents identification of individuals. Merely replacing a name or account number with an identifier is not full anonymization. This restriction does not mean that bank import avoids processing personal data before anonymization, or that we send bank records to our voice-processing providers.

Kontomatik's terms and privacy information are available during authorization. See Kontomatik's documents for users, under Kontomatik sp. z o.o. For processing by Kontomatik as an independent controller, you can contact its data protection officer at [email protected]. Our policy does not replace the provider's notice or promise deletion from its systems merely because you disconnect in ARKAD.

For processing on our behalf, Kontomatik uses subprocessors, including Operator Chmury Krajowej sp. z o.o. and Google Cloud Poland sp. z o.o., to provide data-processing infrastructure.

Website hosting providers receive the technical request data described in Section 2.5. Professional advisers, accounting providers, and competent authorities may receive information where necessary for legal obligations, advice, or claims. We do not sell your financial records or provide their contents to advertising services.

5. Retention and deletion

  • Account and financial records: retained while your account is open to provide your history and budgeting functions. You can request deletion or use account deletion in the app. Data is removed from active systems without undue delay, subject to records necessary for legal duties or claims.
  • Bank connections: active connection/access metadata supports authorized imports. After disconnection, information needed to account for the occupied slot remains through the current calendar-month period; expired disconnected connection records are then removed by scheduled cleanup. Already imported history remains until deleted or your account is closed, subject to lawful retention. Duplicate-prevention records can remain while needed to prevent re-imports, including of deleted transactions.
  • Retention by Kontomatik: for processing on our behalf, periods include up to 24 hours after data is obtained for importing services, with a separate rule for multiple access. Raw data or other forms needed to keep services operating correctly may be processed for up to 14 days after collection or processing. Multiple access provides for up to 180 days to enable the service, and up to 194 days in total including data obtained through that service. These periods do not limit retention of history downloaded into ARKAD. Kontomatik's privacy notice explains its separate processing as a controller.
  • Provider cleanup: disconnection requests revocation of provider access. Account deletion also triggers a request to remove associated provider data. Provider failures can delay completion, and the provider may have independent statutory retention duties.
  • Logs and diagnostics: server logs may be retained for up to six months for security and diagnostics. Access to diagnostic content, including any response fragments, is restricted.
  • Voice: ARKAD does not retain raw audio after processing; saved transaction records follow the financial-record rules. Provider retention depends on its applicable settings, terms, and legal obligations.
  • Purchases, complaints, correspondence, and legal evidence: retained for the period needed to resolve the matter and meet applicable accounting/tax retention duties or limitation periods for claims. Only necessary records are retained for those purposes after account closure.
  • Analytics and attribution: retained only while needed for the stated purpose, subject to the provider's configured retention and deletion processes. Consent withdrawal or an applicable objection ends the affected future processing; account deletion triggers relevant cleanup. It does not automatically erase records a recipient must independently retain by law.
  • Backups: copies are removed or overwritten through the backup cycle and kept protected from ordinary use in the meantime. If restored for recovery, applicable deletion requests must be reapplied.

You can ask us for the retention criteria applicable to a particular record. Disconnection, deleting a transaction, closing your ARKAD account, and cancelling a store subscription are separate actions with different effects.

Separately, Kontomatik's published account-access privacy notice states controller retention of up to 14 days for single access and up to 194 days for multiple access (180 days of access plus up to 14 days of processing), with longer retention where necessary for legal duties or claims. These are Kontomatik's controller rules, not ARKAD's retention period. You can request cancellation of Kontomatik multiple access at [email protected], following its identification instructions; its published terms provide for completion within two working days. You can still disconnect in ARKAD immediately to stop our further imports.

6. International transfers

Our principal application hosting is in the EU. Supabase uses an EU region; Sentry uses EU data storage and Amplitude its EU server zone. An EU storage location does not necessarily exclude support or other processing outside the EEA.

Resend and RevenueCat process relevant data in the United States. ElevenLabs may process voice/transcription data outside the EEA. Airbridge is operated from South Korea and uses infrastructure in Japan. Where transfers outside the EEA occur, the applicable mechanism must be a GDPR Chapter V safeguard, such as a relevant adequacy decision or EU Standard Contractual Clauses with necessary supplementary protections. Adequacy applies only to covered recipients and processing; it is not a blanket guarantee for an entire provider group.

Kontomatik processes data entrusted by ARKAD in data centers within the EEA. Transferring that data outside the EEA requires our prior written consent and compliance with applicable GDPR Chapter V requirements; our consent alone does not replace required safeguards. The notice presented during authorization describes Kontomatik's separate processing as a controller. Contact us to obtain information about transfers relevant to your ARKAD data and a copy or description of applicable safeguards, with necessary protection for confidential information.

7. Security and automated processing

We use HTTPS, restricted infrastructure/database access, authentication controls, and access limited to authorized personnel with a business need. No system can guarantee absolute security.

AI-assisted drafts, analytics, and the ARKAD Aura progress score involve automated processing. Aura summarizes budgeting and saving behavior for your information; it is not a bank credit score. ARKAD does not use these outputs to make solely automated decisions about you producing legal or similarly significant effects, such as granting credit. Bank import itself does not automatically categorize transactions. You can correct financial records and ask us about an output.

ARKAD Aura and Smart insights use financial records to help you understand your budget and progress. Their purpose is informational budgeting support, not personalised investment recommendations, tax or legal advice, or individual professional financial advice. You make your own financial decisions; particular savings, profits or investment returns are not guaranteed. This explanation does not limit your data-protection rights or mandatory consumer rights. The Terms explain the Service's scope and applicable responsibilities.

8. Your rights

Subject to the conditions in GDPR, you may access and correct personal data; request erasure, restriction, or portability; object to legitimate-interest processing on grounds relating to your particular situation; and withdraw consent without affecting the lawfulness of earlier processing. You can object to direct marketing at any time without giving a reason. You do not need to close your account to withdraw optional consent. Bank authorization can be revoked separately through the connection flow and any controls provided by your bank/provider.

Contact [email protected] or write to the address in Section 1. We may request proportionate information to verify identity. We normally respond within one month; if GDPR permits an extension for complexity or number of requests, we explain it within that month. Requests are normally free, subject to statutory exceptions for manifestly unfounded or excessive requests.

For ARKAD account data and processing carried out on our behalf, direct your request to ARKAD; you do not need to contact Kontomatik first or separately to delete your ARKAD account. For data Kontomatik processes as an independent controller, you may request access, erasure or other applicable rights through its data protection officer at [email protected], following its privacy and rights information. Kontomatik assesses the request under GDPR, including any legal retention exception. This privacy-request route is separate from cancelling future bank access at [email protected]. Neither disconnection nor closing an ARKAD account guarantees immediate erasure of all data a separate controller lawfully retains.

You can complain to the President of the Personal Data Protection Office (UODO), or the supervisory authority competent for your residence, workplace, or the alleged infringement. Contacting us first is not mandatory.

9. Children

The Service is intended for people aged 16 or older. We use declared age for eligibility and do not knowingly provide accounts to children under 16. Contact us if you believe an underage child has supplied data. Paid contracts by minors remain subject to the guardian-consent rules in the Terms.

10. Updates

We explain material changes by email or an in-app notice before they apply, including the change, effective date, and any action you can take. If a new purpose requires consent or another legal basis, an updated notice or continued use alone does not provide it. Historical versions remain available in the archive.

Version history

  • v4.0 (published 2026-10-16): company controller; bank data, Kontomatik, and connection metadata; clarified retention, provider roles, pseudonymous analytics, legal bases, and rights; Aura component processing and reference to plan access rules; Polish and English versions; checked against the supplied Kontomatik agreement and access-service notices during preparation; Telegram/Facebook support data and recipients.
  • Earlier versions and their original changelogs are available in the Privacy Archive.