Privacy Policy for the "Subtrack" Mobile App

Last updated: November 8, 2026

This document sets out the rules for processing personal data by MatCode Mateusz Arczyński (ul. Portowa 10, 86-200 Chełmno, Poland, NIP 875-156-25-99, REGON 383604557, e-mail: matcode.help@gmail.com) - hereinafter the "Administrator". It has been prepared in accordance with Regulation (EU) 2016/679 ("GDPR").

1. In short

• Subtrack does not require an account, sign-in, or registration. The App operates in offline-first mode.
• Your subscriptions, prices, currencies, custom exchange rates, billing cycles, notes, and notification settings are stored strictly on your device in a local SQLite database (powered by Drift). The Administrator has no access to them.
• The App does not connect to your bank account, credit cards, or financial institutions. No banking credentials or transactions are accessed.
• Payment reminders are scheduled purely on your device using native iOS and Android notification systems. No financial or reminder data is sent to external push servers.
• Backups: you can manually export and import your data anytime using a standard JSON backup file via the native system share sheet and file picker. The file remains entirely under your control.
• The App contains no first-party analytics or crash-reporting and does not transmit telemetry data to the Administrator's servers.
• The App displays Google AdMob ads (banners and frequency-capped interstitials). This is the only module that may process device identifiers - and only after you provide consent (via the UMP form in EEA/UK and the ATT prompt on iOS).
• The App does not access GPS location, camera, microphone, or contacts.

2. Glossary

User - a natural person installing or using the "Subtrack" mobile application (hereinafter: "App").

Service - the App's functionality, including tracking subscriptions and recurring expenses, calculating cost forecasts, managing multi-currency conversions and manual exchange rates, scheduling local payment reminders, expense analytics, and JSON backup export/import.

3. Scope and purposes of data processing

• Subscription and Financial Data (service names, amounts, currencies, billing countries, renewal dates, cycles, notes, and payment methods) is stored locally in the device's SQLite database. The Administrator does not receive this data and therefore does not process it under the GDPR.
• Local Notifications - the App requests system notification permissions (`POST_NOTIFICATIONS`, `SCHEDULE_EXACT_ALARM` on Android and notification permissions on iOS) to schedule local alerts for upcoming renewal dates. No renewal dates or pricing data leave the device.
• Backup (JSON Export / Import) - exporting and importing your backup file is performed entirely locally on your device using native platform dialogs (`share_plus`, `file_picker`). You choose where the backup file is saved or shared.
• Advertising (Google AdMob) - the App serves banner and interstitial ads through Google AdMob. The Google Mobile Ads SDK may process device advertising identifiers (GAID on Android, IDFA on iOS), IP address, diagnostic data, and ad-interaction telemetry to display ads, measure performance, and combat fraud. Legal basis: Art. 6(1)(a) GDPR (consent), collected via the Google User Messaging Platform (UMP) form and the App Tracking Transparency (ATT) prompt on iOS. Where consent is withheld, only non-personalized ads are requested.
• Support Correspondence - if you email us at matcode.help@gmail.com, we process your email address and message contents solely to answer your inquiry; legal basis: Art. 6(1)(f) GDPR (legitimate interest in responding to user inquiries).

4. Data recipients

• Google LLC / Google Ireland Ltd. - for Google AdMob, Google Mobile Ads SDK, and Google UMP.
• Apple Inc. and Google LLC - operating the App Store and Google Play platforms that distribute the App.

5. Data retention

Local data remains in your device's SQLite database until you reset app data, overwrite it with a new backup import, or uninstall the App. Support emails are retained only for as long as necessary to resolve your request and protect against legal claims.

6. Your privacy rights

You have the right to withdraw or modify your ad consent at any time:

• on iOS: via system Settings → Privacy & Security → Tracking;
• on Android: via system Settings → Google → Ads;
• via Google Ads settings at adssettings.google.com.

Regarding support emails, you have the right to access, rectify, delete, or restrict processing of your personal data. You also have the right to lodge a complaint with your local data protection supervisory authority.

7. Data security

We implement appropriate technical measures. Your subscription and financial data is protected by the native sandboxing mechanisms of iOS and Android. Network traffic generated by Google AdMob is protected by industry-standard TLS encryption.

8. Children's privacy

The App is not directed at children under 13 and does not knowingly collect any personal data from children.

9. Changes to this Policy

The current version is always available at https://matcode.eu/hub/subtrack/policy-en.html. Any modifications will be indicated by the updated date at the top of this document.

For questions or support, contact us at: matcode.help@gmail.com.