Privacy Policy

This Privacy Policy explains how ATZERO SALES, MARKETING & TECHNOLOGY LIMITED ("we", "us", "our") collects, uses, and protects your personal data when you use the Yours platform.

1. Data Controller

ATZERO SALES, MARKETING & TECHNOLOGY LIMITED is the data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Protection Contact: support@yoursfinance.co.uk
Address: First Floor, 85 Great Portland Street, London, England, W1W 7LT

2. Data We Collect

We collect and process the following categories of personal data:

Account Data:

• Name and surname
• Email address
• Company information (merchants only)

Technical Data:

• Device type and operating system
• IP address
• App version and crash reports (via Sentry)

Transaction Metadata:

• Transaction timestamps and amounts
• Wallet addresses (public, on-chain data)
• Payment reference keys

We NEVER collect:

• Private keys or seed phrases
• Biometric data (Face ID / fingerprint data is processed locally on your device and never transmitted to our servers)
• Bank account or credit card details
• Passwords in plain text

3. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contract Performance: To provide and maintain the Yours platform
• Legal Obligation: To comply with UK law, including anti-money laundering regulations
• Legitimate Interests: To improve platform security, prevent fraud, and enhance user experience
• Consent: For optional features such as push notifications and marketing communications

4. How We Use Your Data

Your data is used to:

• Provide, operate, and maintain the Yours platform
• Process and display transaction information
• Prevent fraud, abuse, and security threats
• Comply with legal and regulatory requirements
• Send service-related notifications
• Improve platform performance and user experience
• Provide customer support

5. Third-Party Services

We use the following third-party service providers who may process your data:

• Supabase (Database & Authentication) — EU/US servers
• Sentry (Error Tracking & Crash Reporting) — EU servers
• Solana RPC Providers (Blockchain Interaction) — Distributed
• Expo / EAS (App Build & Distribution) — US servers
• Apple Push Notification Service / Firebase Cloud Messaging — US servers
• OpenAI (AI Business Assistant) — US servers

Each provider is bound by data processing agreements and complies with applicable data protection laws.

6. AI-Powered Features & Third-Party Data Sharing

Our app includes an AI business assistant feature powered by OpenAI, Inc. When you use the AI chat feature:

• Data shared: Your chat messages and basic business profile information (business name, business type) are sent to OpenAI's API to generate personalised responses.
• Who receives it: OpenAI, Inc. (openai.com) processes this data under their API data usage policy. OpenAI does not use API data to train their models.
• Your control: You are asked for explicit consent before any data is shared with OpenAI. You can decline, and the AI chat feature will not be available without consent.
• Data retention: Chat messages are stored in our secure database (Supabase) for your chat history. You can delete your chat history at any time from within the app.

No other personal data is shared with third parties except as described in this policy.

7. International Data Transfers

Some of our third-party providers operate outside the UK. Where data is transferred internationally, we ensure appropriate safeguards are in place, including:

• UK Adequacy Decisions
• Standard Contractual Clauses (SCCs)
• Supplementary security measures where required

8. Data Sharing

We may share your data with:

• Law enforcement or regulatory authorities where legally required
• Analytics and error tracking providers (anonymised where possible)
• Compliance and fraud prevention providers

We do not sell, rent, or trade your personal data to any third party.

9. Data Retention

We retain your data for the following periods:

• Account data: Duration of account plus 2 years after deletion
• Transaction metadata: 7 years (UK tax compliance requirements)
• Technical/crash logs: 90 days
• Customer support records: 3 years

Data is securely deleted or anonymised after the retention period expires.

10. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• AES-256 encryption for sensitive data at rest
• TLS 1.2+ encryption for data in transit
• Row-level security on database access
• Regular security audits and monitoring

11. Biometric Data

The Yours app uses Face ID and fingerprint authentication for device-level security. All biometric processing occurs locally on your device using the operating system's secure enclave. We never receive, store, or have access to your biometric data.

12. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.

13. Your Rights Under UK GDPR

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request restriction of processing
• Portability: Request your data in a portable format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Where processing is based on consent

To exercise any of these rights, contact us at support@yoursfinance.co.uk. We will respond within 30 days.

14. Complaints

If you are not satisfied with our handling of your data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

Website: ico.org.uk
Phone: 0303 123 1113

15. Children's Privacy

Yours is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification. The "Effective Date" at the top will be updated accordingly.

17. Contact

For privacy inquiries:

Email: support@yoursfinance.co.uk
Address: First Floor, 85 Great Portland Street, London, England, W1W 7LT