Privacy Policy

1. Introduction

Welcome to Setlino.

Setlino is a mobile application that helps individuals and groups manage shared expenses, split costs, track balances and record repayments.

Setlino can be used by friends, roommates, families and travel groups to organize their shared expenses.

This Privacy Policy explains what personal information we collect, how we use and protect it, who may access it and what rights you have regarding your personal data.

2. Data Controller

Setlino is independently developed and operated by:

Črt Grohar is responsible for determining how and why personal data is processed through Setlino. No data protection officer has been appointed; privacy requests go directly to the contact address above.

For questions about privacy, personal information, account deletion or data protection rights, contact groharcrt@gmail.com.

3. Personal Information We Collect

Setlino collects and processes information necessary to provide its expense-sharing functionality.

3.1 Account Information

When you register for Setlino, we process:

• Email address
• Password credentials handled through Supabase Authentication
• Unique account identifier
• Optional display name
• Account creation date
• Authentication and session information
• The declarations you make when you register: that you confirmed you are at least 16 years old, that you accepted the Terms of Use and Privacy Policy, and the date of that acceptance

Passwords are handled by Supabase Authentication and are stored as secure password hashes rather than plaintext passwords in Setlino's application database. Setlino never receives or stores your plaintext password.

If you do not provide a display name, the application may use the part of your email address before the @ symbol as your display name. Your display name may be visible to other members of groups you join.

Setlino does not collect your phone number, postal address, date of birth, photographs, contacts or precise location, and there is no social login.

3.2 Group Information

When you create or join a group, we may process:

• Group names and descriptions
• Group creation dates
• Group memberships
• Member roles
• Invitation codes and expiration dates
• Membership information

This information allows users to organize shared expenses and manage access to groups.

3.3 Expense Information

When users add shared expenses, Setlino processes:

• Expense titles
• Optional descriptions
• Expense amounts
• Expense dates
• Expense creators
• Members who paid expenses
• Members participating in each expense
• Individual expense shares
• Calculated balances

This information is required to calculate how much group members owe one another.

3.4 Settlement and Repayment Information

When users record repayments, Setlino may process:

• Payment sender and recipient
• Payment amount
• Payment date
• Optional payment notes
• Payment confirmation status
• Payment rejection or cancellation status
• Settlement reversal requests
• Reversal approvals, rejections and cancellation records

Repayment records are used to maintain accurate group balances.

Setlino does not require credit card numbers, bank account credentials or IBAN information to provide its functionality.

Users should avoid entering unnecessary sensitive personal or financial information into expense descriptions and payment notes.

3.5 Technical Information

When you use Setlino, its infrastructure providers may process certain technical information necessary to operate and protect the service, including:

• IP addresses
• Authentication events
• Request timestamps
• Connection metadata
• Security-related information
• Technical error logs

The current Setlino application does not include advertising SDKs, third-party analytics SDKs or advertising tracking. The app itself does not send analytics events or crash reports. The only personal record the app stores on your device is your session token, which is kept in the app's private storage, refreshed only while the app is open, and removed when you sign out or delete your account.

Setlino does not require access to your contacts, precise location, camera, microphone or photo library for its existing features.

4. How We Use Your Information

We use personal information to:

• Create and maintain user accounts
• Authenticate users securely
• Enable users to create and join groups
• Record and organize shared expenses
• Calculate individual and group balances
• Record and confirm repayments
• Maintain payment history
• Process settlement corrections and reversals
• Provide password reset functionality
• Respond to support and privacy requests
• Protect the application against unauthorized access
• Maintain application reliability and security

We do not sell personal information.

We do not use personal information for targeted advertising.

5. Legal Bases for Processing

Where the General Data Protection Regulation (GDPR) applies, personal information is processed on appropriate legal grounds.

Performance of a contract – Article 6(1)(b)

Processing necessary to provide user accounts, group management, expense splitting and repayment tracking.

Legitimate interests – Article 6(1)(f)

Processing necessary for service security, prevention of misuse and maintenance of shared financial records, where these interests are not overridden by individuals' rights and freedoms.

Legal obligations – Article 6(1)(c)

Processing required to comply with specific applicable legal obligations, including responding to legally valid data protection and consumer requests.

Where we rely on legitimate interests, we have considered whether those interests override your rights and freedoms, taking into account the limited nature of the data and the safeguards described in this policy. You may object to that processing at any time using the contact details in section 15.

6. Who Can Access Your Information?

Other Group Members

Setlino is designed for shared expense management.

Members of a group may be able to view relevant information about other group members, including:

• Display names
• Shared expenses
• Individual expense shares
• Group balances
• Recorded repayments
• Payment confirmation status
• Settlement reversal history
• Notes attached to shared financial records

This sharing is necessary for the application's collaborative functionality.

Nobody outside a group can read that group's expenses, payments or balances. Access is enforced in the database itself, not only in the app interface: every table uses row level security, so a signed-in user can read only rows belonging to groups they are a member of, and every change is made through a server-side function that checks membership and role.

Service Providers

Setlino uses third-party infrastructure providers that process data on our instructions.

• Supabase — authentication, database hosting and backend services. supabase.com
• Google (Gmail SMTP) — used through Supabase Authentication to deliver transactional emails, including email confirmation and password recovery messages. Google Privacy Policy
• Apple — distribution through the App Store and TestFlight, under Apple's own privacy policy. Apple Privacy Policy

We do not sell personal information to advertisers.

These providers may use further subprocessors. Supabase publishes its current subprocessor list at supabase.com/legal/customer-resources/subprocessor-list.

7. Where Your Data Is Stored

Setlino uses Supabase to store and manage application data.

The confirmed primary database location is:

The Supabase region you select determines where the project's primary data is stored and primarily processed. Our project is hosted in Ireland. Supabase's data processing terms allow it and its subprocessors to process data where they maintain facilities, subject to a commitment that, where a region has been selected, data is stored and primarily processed in that region, apart from limited operational or legal exceptions. Email delivery is handled by Google and may involve processing outside the European Union (see section 13).

8. How Long We Keep Information

Setlino retains personal information only for as long as necessary for the purposes described in this Privacy Policy, subject to applicable legal requirements.

Account information

Account information — email address, password hash, account identifier and session records — is retained while your account remains active.

Groups and memberships

Group information is retained while the group exists. Once you have recorded an expense in a group, or been part of a recorded payment, you cannot leave that group inside the app, because removing you would change or break the other members' balances. In that situation your membership remains until the group's records are removed, or until you delete your account (which replaces your identity with a pseudonymous record, as described below).

Invitation codes

Invitation codes expire after seven days and are invalidated earlier when a group owner generates a new one.

Expense and settlement records

Shared expenses and splits are retained while the associated group exists. Recorded payments and settlement reversals are retained for as long as the service operates: they form the payment history other members rely on, and a group that contains any expense or recorded payment cannot be deleted inside the app, even by its owner. Confirmed payments cannot be edited or deleted; corrections are recorded as separate reversal entries.

This means that in practice, financial records in a group with activity are kept for an extended period rather than deleted on a schedule. We keep them because other members' balances and payment history depend on them, and we limit them to what those records require.

Information after account deletion

When an account is deleted, direct account identifiers and authentication credentials are removed or invalidated according to the implemented deletion process. Certain shared expenses, settlements and reversal records may remain because other members' balances depend on them.

These retained records reference a pseudonymous identifier rather than your name or email address, and they are displayed in the app as “Deleted account”. They are kept for as long as the group's financial records exist, and we do not currently set a separate deletion date for them.

Retained records may still contain contextual information — for example a description or note that mentions you, or the pattern of who paid whom. Other group members might therefore still be able to infer the former participant's identity from earlier shared activity. Pseudonymization does not necessarily make information anonymous under data protection law.

Technical logs and backups

On our current Supabase plan, API and database logs are retained for 1 day and authentication audit logs for 1 hour. If we change plans, these periods change with the plan and the then-current Supabase documentation applies.

Our Supabase plan does not provide automated backups that we can access or download. Supabase's data processing terms state that it takes daily backups of customer projects by default and that backups are retained for a limited period; the exact period is not published for our plan. Any backup that exists may contain copies of data that has since been deleted, for as long as Supabase retains it.

9. Account Deletion

You can request account deletion directly inside the Setlino application.

To delete an account:

Profile → Delete account

You confirm the request with your password, then confirm it once more in a final destructive dialog. Account deletion is not the same as logging out.

The implemented deletion process:

• invalidates your authentication credentials;
• terminates active sessions and refresh tokens;
• removes your email address, phone field, password hash, recovery and confirmation tokens, and two-factor factors;
• removes your linked sign-in identities;
• prevents access to the deleted account, so it can never be signed in to again;
• removes memberships in groups where you have no financial history;
• removes the invitation codes you created;
• transfers ownership of groups you own to another member, and deletes a group outright only when you were its only member and it has no expenses or payments;
• keeps shared financial history where removing it would change another member's balance, replacing your identity with a “Deleted account” record;
• records that the account was deleted in a pseudonymous ledger containing no personal data.

Where necessary for referential integrity, a disabled or pseudonymized technical account record remains. Retained information is limited to what is necessary to keep other members' records correct, and is described in section 8.

If a payment or a settlement reversal involving you is still awaiting a decision, the app will not complete deletion until it is resolved. Both actions take one tap, and leaving them open would strand the other member.

If you cannot complete account deletion in the app or need further assistance, contact groharcrt@gmail.com. You can also ask us to delete specific records, although we may be unable to remove shared financial history that other members' balances depend on without affecting their records.

10. Your Data Protection Rights

Under the GDPR, where applicable, you may have the right to:

• access personal information held about you;
• request correction of inaccurate information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing activities;
• request data portability;
• lodge a complaint with a competent supervisory authority.

To exercise your rights, contact groharcrt@gmail.com. Requests are reviewed and answered within the time limits established by applicable law, normally one month. We may need to verify that a request comes from the account owner.

Some requests cannot be met in full: where records are needed to keep another group member's balance correct, we may be able to correct or restrict the personal identifiers but not to erase the financial row itself. We will explain what we can do in our reply.

The relevant data protection supervisory authority in Slovenia is:

11. Children's Privacy

Setlino is an expense-sharing application intended for people aged 16 or over.

The intended App Store content rating is 4+, subject to Apple's assessment. That rating describes the suitability of the app's content; it is not the age at which a person may create an account, and it does not establish legal capacity to agree to these terms.

When you register, the app asks you to confirm that you are 16 or older and to accept the Terms of Use and Privacy Policy; we record that declaration and the date it was made. Setlino does not operate a verified parental-consent process, and we do not independently verify a user's age: the confirmation is a statement by the user, not proof. Accounts are not intended for children under 16, and registration by a child under 16 is not permitted. If you believe a child under 16 has created an account, please contact groharcrt@gmail.com and we will review the request and delete the account.

Where the law of your country sets a higher age for independent consent to online services, or requires parental authorisation, that rule applies instead. If you are under that age, please do not register.

12. Information Security

Setlino uses technical measures intended to protect user information.

• Encrypted HTTPS/TLS connections for all app and website traffic.
• Supabase Authentication, with passwords stored only as hashes.
• Database row level security on every table, scoped to group membership.
• Server-side authorization checks on every write, inside database functions.
• No direct insert, update or delete permission for the app on any table.
• Confirmed payments and resolved reversals are immutable; corrections are recorded as separate rows.
• Session management, with tokens refreshed only while the app is open.
• Only a publishable API key ships in the app; no secret or service-role key is present.
• Security testing of database access rules and financial operations.

No application or online service can guarantee complete security.

If you suspect unauthorized access to your account, contact us at groharcrt@gmail.com.

13. International Data Transfers

The primary Supabase database is located in Ireland, within the European Union. Our contract for the database and authentication services is with Supabase Pte. Ltd. (Singapore), which processes data on our behalf.

Supabase's data processing terms incorporate the European Commission's Standard Contractual Clauses (Module Two for controller-to-processor transfers and Module Three for processor-to-processor transfers, governed by Irish law) for transfers of personal data outside the European Economic Area. Its subprocessors are bound by the same terms, and its current list is published on its website.

Transactional email is sent through Gmail SMTP, which is provided in the European Economic Area by Google Ireland Limited. Google states that it maintains servers around the world and that information may be processed outside the country where you live; it relies on the EU–US Data Privacy Framework (with Google LLC certified) and on Standard Contractual Clauses where required.

Apple processes App Store and TestFlight data under its own terms and privacy policy.

In each case, transfers rely on an adequacy decision or on appropriate safeguards under the GDPR. You can ask us for more information about the safeguards that apply to a specific transfer using the contact details in section 15.

14. Changes to This Privacy Policy

We may update this Privacy Policy when:

• application features change;
• new service providers are introduced;
• personal data processing activities change;
• applicable legal requirements change.

The updated policy will display a revised “Last updated” date.

Where the changes are significant, we will inform users in the app before they take effect. Continuing to use Setlino after a change takes effect means you accept the updated policy.

15. Contact Information

For privacy-related questions, account deletion requests or data protection inquiries: