Splixy - Privacy Policy

Last updated: December 1th, 2023

Scope

Welcome to Splixy’s Privacy Statement. Your right to privacy and online security is important. This Privacy Statement describes Splixy Inc.’s collection, protection, disclosure, and use of your information. This Privacy Statement applies to all of Splixy’s websites, mobile applications, and/or online services, that link to or reference this Privacy Statement. It covers your personal information that is provided or collected through the use of our services and how we use that information in connection with our services.

By using Splixy, you agree to this Privacy Statement. If you do not agree with any term in this Privacy Statement, please do not use our services.

Here's a quick overview:

Splixy is a shared ledger for friends. Expenses you add in Splixy are not public. Friends who are included on an expense can view that expense, and, if an expense is added in a group, other group members can view expenses shared on Splixy. You choose who you share your expenses with and what kind of expenses you want to share. Anyone shared on an expense or in a shared group has the ability to edit, delete, and undelete the expenses that have been shared with them.

In order to use Splixy, we ask that you create an account. When you sign up we'll ask for some registration information such as name, email address. We need this information to create an account so that we can contact you about your account, so that your friends can find you, and so you can access your account from anywhere.

In addition to sharing your registration information to set up your account, we collect some other information about you, such as the type of device you use. We may also collect information about the type of expenses you add, or the groups you create. We use this information to help improve and secure our service and to show ads based on your usage of our services.

You have control over the type of information you provide and how we use it. We don’t share your registration or personal information for marketing purposes. We will never share your information with other parties for use other than what’s laid out in this policy without your consent. If you have any questions please contact us at tylyodev@gmail.com.

Splixy or its partners or service providers may maintain operations in the United States or any other country, and therefore your personal information may be processed outside the country where you are located. By using and providing information to us, you agree and consent to the transfer, storage, and processing of your information in other countries, including for example outside the European Economic Area. Countries that we transfer your information to may not have data protection laws similar to those of where you are located.

Splixy is not intended for use by children under 13 years of age or minors. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us at tylyodev@gmail.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files immediately.

DATA WE COLLECT

When you use Splixy, we may collect the following information about you:

Information you provide to us:

Registration information: When you sign up for an account with Splixy, you will be asked for registration information, such as your name, email address and a password. We require you to provide an email address in order to use Splixy so that we can contact you about your account, and so that you can access your data from any device. Friends will be able to add you using your email address. We require you to provide a name for your account, this is the name your friends will see when adding expenses with you.
User-generated content: We also collect and store the information you provide to us when using our service to share expenses, payments, and communicate with others. This data includes, for example, group names, expense descriptions and amounts, payments and their confirmation numbers, comments and reminders, receipt images, notes, and memos, in addition to any other information that you attach or share while using Splixy. You may share this information with contacts you specify in the course of using the Service. For example, if you add an expense with a group of roommates, those roommates will be able to see that bill, while users who are not the roommates group will not. You are solely responsible for which contacts you share this information with.
- User-generated invitations / Adding users to a group: Invitations to a specifically chosen friend or set-of-friends to join Splixy in general, or a specific relationship or group, can be sent at your request on your behalf. When you invite a friend or contact to Splixy using these functions, Splixy will collect from you the contact information of the person(s) being invited by asking you to provide a name, email, phone number and/or an internal Splixy identifier. A few messages will be sent to these contacts through the chosen communication channel or a link will be provided for you to send the invitation yourself. Your name, the contact name, and the name of the associated group may also be incorporated in invitation messages sent by Splixy, as applicable.
- Contact Book / Address Book data: On our mobile applications for Android and iOS, our app uses on-device contact book data (when you give permission in the relevant operating system) to locally display your list of contacts. This also allows you to auto-fill the full name, email address and/or phone number of a given contact to whom you are sending an invitation to Splixy, or inviting to a relationship or group. If you give Splixy this contact book permission, only contacts you specifically interact with in the user interface will have their name, email and/or phone number collected by Splixy for the purpose of sending these invitations and creating a profile in your group or friendship. Some additional contact book metadata about contacts may be collected by Splixy, such as the total number of phone numbers for a contact you select.
The way you use our service: We collect information about how you use and interact with Splixy. Such as the types of expenses you add, the features you use, the actions you take, and the time, frequency and duration of your activities. For example, we log when and how often you add images to a bill and may use that information to improve our service or suggest new features we offer.
Information Shared By Others: Other Splixy users may share information with you using your contact information (such as email or phone number), and that information will be stored in the course of using Splixy. For instance, if a contact of yours shares a bill with you or adds you to a group using your email address, Splixy may notify you and store that information under your account according to your preferences.
Device and Location information: When you download or use Splixy, we may receive information about your device and location, which allows us to provide increased account security and regulatory compliance. It also allows us to provide location-based services such as targeted advertising, search results, and other personalized content. We also collect information about your interaction with Splixy including, but not limited to, your computer browser type, pages visited, advertisements clicked on, average time spent on our Sites, your IP address, unique identifiers of your device, the operating system version and app version.
Information related to Third Party Integrations: Splixy may collect information about you from third parties to help improve our service, or for security and support reasons. If you choose to use some of the optional integrations the third party services that we offer we may collect information about you from those services. For example, if you choose to send payments to your friends using one of the payment services we integrate with we may collect information from that payment service (i.e. your username for that service, the status of that payment).
- Google/Apple accounts: As part of using Splixy, you may be presented with the option to link one or more parts of your Google account to your Splixy account. If you authorize Splixy to use your Google/Apple Account to login to Splixy, your name, contact information (usually an email address) and other basic account details (profile picture, name) may be shared with Splixy at your discretion. Sharing this data is not required to start a Splixy account. These details will be stored by Splixy and will generally be treated as if you had manually provided that data to Splixy under this privacy policy (for instance: to sign in with Google in the future, to contact you, display your profile picture, reset your password, set a default currency).
Information from other sources: We may use publicly available information about your name, email address or other demographic data to help you during support, to address fraud or security concerns, or to personalize your experience, including by providing ads or offers. For instance, if you have a public avatar stored on a service such as Gravatar associated with your email, we may automatically populate your user avatar on Splixy. We may also collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records, and to better customize the Service for you.
Other information: We may request or receive other information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service.

HOW WE USE DATA

WE WILL NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO ANY THIRD PARTY EXCEPT AS OUTLINED IN THIS POLICY OR WITH YOUR CONSENT.

We use your information for the following purposes:

To Provide the Splixy Service:

Splixy is designed to help people share expenses with friends. We process your information to provide, support, and secure our service (both automatically and manually). For example, we may use your information in some of the following ways:

To record informal records of expenses and payments.
To fulfill your requests for certain products and Services.
To help your Splixy contacts manage their Splixy relationship with you. For example, we may display your Splixy email address to your Splixy friends and group members so they may identify that they are sharing bills with the correct person.
Respond to your inquiries about our Services. For example, if you or a Splixy friend of yours contacts us for support, or as part of a random account audit, we may go into your account in "administrator mode" to help provide support to you or a friend.
To detect and protect against errors, fraud, or other criminal activity.
We may use your information for internal security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use identifying information to monitor suspicious activity. For example, if we detect that a single account on a Site is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.
To verify your identity in the event you contact us for assistance.
To pre-fill form fields or store preferences for your convenience.
To alert you to software compatibility issues and to improve our web design and functionality.
To communicate with you. For example, we will email you when we release new features, have important news, and when you have a notification generated by activity (including a monthly summary). Some emails, such as, updates to our Privacy Policy, information about your account, password resets, or other security issues are not optional.
To enforce our Terms of Service

With Third Party Services

We may receive and collect information about you from Third Parties and affiliates that help us provide, support, and secure our services. In general, data shared with Splixy in this manner will be treated under the same privacy restrictions as any other data shared with Splixy. For example:

If you choose to settle up via one of the third party payment integrations we offer we may collect information from the service. We will use the data you’ve supplied in your account to assist in completing that payment. We may use information from that Service to display the status of that payment to you. We may also use information about payments sent via third party services to address fraud, security, or support issues.
If you give Splixy access to your Google Contacts as part of using our service, this contact data may be used in a limited way: to send Splixy invitations on your behalf to friends (to individuals specifically authorized by you; not in bulk), to locate your friends who already use Splixy, to recommend friends to invite to Splixy, and to improve our services (for example, to identify common email spelling errors in user support). If you share access to your Google account contacts, Splixy may store some of this information for those purposes.

To Provide Personalized Advertisements

Where permitted by Applicable Law, we may use your email/phone, location, usage and expense information to show you specific advertisements or offers on our own site that we believe may be of interest to you. For instance, we may show ads for apartments cheaper than your current apartment based on the rent expense you share on our system.

HOW WE SHARE YOUR INFORMATION

We will not, without your permission, sell, publish, or share your personal information to third parties for their marketing purposes. We will not sell, publish or share the personal information you provided for the purpose of sending user-generated invitations to third parties for their marketing purposes.

We help you track and manage shared expenses with your friends by sharing your information in the following ways:

To Provide the Splixy Service

Splixy is designed to help you track and share expenses with your friends. We share some of your personal information (name, email address, user avatar) with your friends and groupmates on Splixy. Someone who knows your email addres will be able to add you as a friend and see your name, email address, and user avatar. They will not be able to see expenses that you’ve added with other friends unless you include them on those expenses or in a group.

Splixy allows you to keep track of expenses in groups. These groups are private, and information and expenses posted in a group is only visible to other members of the group. However, any user in that group may add additional members to the group, so it is the joint and sole responsibility of group members to safeguard who they invite into their group sharing platform.
Splixy lets friends add, edit, delete and undelete content shared privately.

For legal matters

We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:

to respond to subpoenas, court orders, or legal process;
in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites, or Services;
to respond to claims that any posting or other content violates the rights of third parties;
in an emergency, to protect the health and safety of our Sites' users or the general public; or
as otherwise required by any applicable law.

Business Transfer

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Statement and according to applicable regulations.

Non-identifiable information

We may disclose information that does not personally identify you in any other manner that we deem appropriate, including to third parties for their research, marketing, and promotional purposes and to help us determine how we can improve our Sites. We will also disclose non-personal information to our service providers and other third parties about how our users collectively use the Sites.

SECURITY

How we protect the information we collect

We take the security of your information seriously. We use technical and administrative security measures such as but not limited to encryption techniques and authentication procedures, among others, to maintain the security of your online session. Please understand, however, that while we try our best to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

We will contact you regarding any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal information to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Phishing:

Identity theft and the practice currently known as "phishing" are of great concern to Splixy®. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website at http://www.ftc.gov.

CHOICE AND ACCESS; DELETING YOUR ACCOUNT; DATA RETENTION

Choice and Access to your personal information:

You may access, review, and update the personal information you have submitted to us at any time. You can make changes to your personal information within the Account Page within the App accessible from the button on the top left of the home page. If you need help updating or correcting your information please contact us at tylyodev@gmail.com.
Deleting your account:

You may choose to close your account at any time. You can close your account within the Account Page within the App ,accessible from the button on the top left of the home page, or request that we close it for you by writing to us at tylyodev@gmail.com. When you delete your account you will not be able to recover the previous data.
Data Retention

In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. We may also retain personal information to comply with law, prevent fraud, resolve disputes, enforce our Terms of Service, and as permitted by applicable law.

If you would like to fully delete your account and the information in it, you can do it within the Account Page within the App accessible from the button on the top left of the home page.When you delete your data you will not be able to recover the previous data.
EU-US-SWISS PRIVACY SHIELD FRAMEWORK

Splixy complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

Splixy has certified to the Department of Commerce that we adhere to the Privacy Shield Principles, including those relating to Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. We commit to subject to the Principles all personal data received from the EEA in reliance on the Privacy Shield. These Principles include without limitation (i) the possibility for the individual to invoke binding arbitration and (ii) our liability in the case of onward transfer to third parties. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights an individual may have to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit https://www.privacyshield.gov

Splixy commits to resolve complaints about privacy and our collection or use of personal information in compliance with Privacy Shield Principles. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Splixy at tylyodev@gmail.com. Splixy further has committed to refer unresolved privacy complaints to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint. The services of JAMS are provided at no cost to the individual.

The Federal Trade Commission has enforcement authority regarding Splixy’s compliance with the Privacy Shield Principles.

CHANGES

Changes to this Privacy Statement

We may update this Privacy Statement periodically. Changes are effective immediately upon posting. The date last revised appears at the top of this Statement.

CONTACT US

Got Questions?

If you have questions or concerns regarding this Privacy Statement, our security practices, or our information handling practices please contact Splixy in writing:

Email: tylyodev@gmail.com