Privacy Policy

This Privacy Policy explains what information Tooclear collects, why we use it, when it may be shared, and the choices available to you.

Tooclear is operated by Damilola Ibukun Shofoluwe, an individual (Tooclear is not a registered company). Damilola Ibukun Shofoluwe decides how personal information is processed for the purposes described in this Policy and is the data controller. You can reach the controller at damilolashofoluwe01@gmail.com.

1. Information We Collect

Account information

When you create an account, we may collect:

• Name
• Email address
• Profile information
• Authentication identifiers
• Preferred language
• Country or region
• Currency preferences
• Account settings

Financial information

When you use Tooclear, you may provide:

• Manual financial account names and balances
• Income and expenses
• Transaction descriptions
• Budgets
• Savings goals
• Bills and subscriptions
• Financial categories
• Household contributions
• Financial notes

In Version 1, Tooclear does not require you to connect your bank account, and it never asks for bank login details.

Uploaded financial documents

If you use document import features, we may process:

• Receipt images
• Bank transaction screenshots
• Bank statements
• PDF documents
• CSV files
• Extracted transaction information

These documents may contain sensitive financial and personal information. Please avoid uploading unnecessary information. Card numbers found in extracted text are reduced to their last four digits.

AI interactions

When you use Tooclear’s AI features, we may process:

• Questions and messages
• Transaction descriptions
• Relevant financial context
• Uploaded receipts and statements
• Audio recordings submitted for transcription
• AI-generated responses and suggested actions

Device and usage information

Depending on the technologies enabled, we may collect:

• Device type
• Operating system
• App version
• Error diagnostics
• Performance information
• Basic usage events
• IP address
• Approximate location derived from technical information

We do not require precise GPS location for ordinary expense tracking.

Payment information

Subscription payments may be handled by Paddle, Apple, or Google.

We may receive payment-related information such as subscription status, transaction identifiers, billing plan, currency, and renewal dates.

We do not receive or store complete payment card numbers. Card details are entered on the payment provider’s own checkout.

Feedback and bug reports

If you send feedback or report a problem in the app, we collect:

• What you write: the type of feedback, a title, a description, and any steps or expected result you add
• How much the problem affects you
• Screenshots, if you choose to attach them (up to three)
• Messages you send about your report, and your answer when we ask whether a fix worked
• Technical details sent with the report: the page you were on (without anything you typed into it), the app version, your platform, browser and operating system names, your screen size, the time, and — if a problem occurred in the last 30 minutes and you leave it selected — a short random error reference

The form shows these technical details before you send. We do not attach your balances, transactions, receipts, statements or AI conversations to a report. Screenshots can show whatever was on your screen, so please crop out or avoid balances, account numbers and other private details before attaching them.

2. How We Use Information

We process information to:

• Create and manage accounts.
• Record and organize financial transactions.
• Calculate balances and budget progress.
• Track savings goals.
• Provide AI-assisted features.
• Analyze receipts and statements.
• Generate financial insights and reports.
• Enable authorized household collaboration.
• Manage subscriptions.
• Prevent fraud and misuse.
• Maintain security and reliability.
• Respond to support requests and investigate problems you report.
• Improve Tooclear based on the feedback you send.
• Meet legal obligations.

We do not use your financial information for unrelated advertising purposes without an appropriate legal basis and any required consent.

3. AI Processing

Tooclear uses third-party AI services to support features such as transaction interpretation, receipt scanning, document extraction, voice transcription, and financial explanations.

When you request these features, relevant information may be transmitted securely to an AI service provider for processing. We aim to limit the information shared to what is reasonably necessary for the requested feature. For example, insight summaries are written from compact figures rather than your full transaction list.

AI-generated information may be inaccurate and should be reviewed before being relied upon. Nothing the AI prepares is saved to your records until you confirm it.

AI providers we currently use:

• Anthropic (Claude models, currently Claude Opus 5.5): the assistant, receipt scanning, statement import and written insights.
• OpenAI (currently its gpt-transcribe model): voice transcription.

We use both through their business APIs. Each provider handles the information it receives under its own terms and privacy policy (Anthropic, OpenAI). We have not made separate agreements with them about how long they keep information or whether it may be used to train models, so we don’t make promises about that here.

4. Financial Documents and Receipts

When you upload a receipt or bank statement, we store the file in private storage and process it to extract relevant financial information.

Extracted information may be used to prepare transaction drafts, identify duplicates, suggest categories, and update your financial records after confirmation.

What happens to the original files:

• Receipts stay attached to your transaction until you delete the receipt or your account.
• Statement files are deleted after the import finishes, unless you choose to keep them.

When you delete your account, all files you uploaded are deleted from our storage.

You may delete eligible uploaded documents yourself in the app, or ask us to.

5. Voice Information

If you use voice features, audio is sent to our transcription provider. The resulting transcript may be processed to interpret your financial request.

By default, audio is processed and not stored on our servers. You can choose in Settings to keep recordings. Transcripts are kept by default so you can review them in Settings → Voice history, where you can delete one or all of them or stop keeping them.

Recordings waiting to be sent while you’re offline stay on your phone and are deleted when you sign out.

We do not use microphone access to record conversations without an action or permission that authorizes recording. Tooclear has no always-on listening.

6. Household Sharing

If you join or create a household, information you intentionally share may be accessible to authorized household members. Shared information may include:

• Household transactions
• Shared account records
• Household budgets
• Savings goals
• Bills
• Member contributions

Personal financial records remain separate unless explicitly shared or otherwise made accessible through an authorized feature. Household permissions determine what members may view or modify, and they are enforced by our database on every request.

You should carefully consider what you share with other members.

7. Service Providers

We use these service providers:

We may also share information with professional advisers, or with authorities where the law requires it.

We do not currently use third-party analytics, advertising or error-monitoring services. If that changes, we will update this Policy.

Service providers may process information on our behalf or act as independent controllers for certain activities, such as payment processing.

8. Legal Bases for Processing

Where applicable privacy law requires a legal basis, we rely on one or more of the following:

• Performance of a contract
• Compliance with legal obligations
• Legitimate interests, where permitted
• Consent, where required

The appropriate legal basis depends on the purpose and applicable law. Users may withdraw consent where processing is based on consent, subject to lawful limitations.

9. International Data Transfers

Tooclear is operated from Nigeria and uses service providers that process information in other countries, including the European Union (our database and file storage, in Ireland) and the United States.

We use these providers under their standard business terms. Where the law requires specific safeguards for a transfer, such as those under Nigeria’s Data Protection Act 2023, we will put them in place.

10. Data Security

We use technical and organizational measures intended to protect personal information, including:

• Encrypted connections (HTTPS) between the apps and our servers.
• Database access rules that let each person reach only their own records and the households they belong to.
• Private file storage, with images shown through short-lived links.
• Sign-in tokens kept in your phone’s secure storage (Keychain or Keystore).
• Information saved for offline use encrypted on your phone, and an optional app lock.
• Provider keys for AI and payments kept on our servers, never in the apps.

No system is completely immune to security incidents. If a personal data breach occurs, we will investigate and provide notifications where required by applicable law.

11. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Policy or as required by law.

Different retention periods may apply to account information, financial records, uploaded documents, AI conversations, audio recordings, security logs, subscription records and backups.

How it works today:

• Your financial records, AI conversations, receipts and voice transcripts stay until you delete them or your account. Statement files and audio follow sections 4 and 5.
• For each AI request we keep a short technical record (time, model, whether it succeeded, usage counts and how long it took), not the content of your messages. These records are deleted with your account.
• Feedback reports, their screenshots and the messages about them stay until your account is deleted. Screenshots are stored privately and can be seen only by you and Tooclear’s operator.
• Your subscription details are deleted with your account. A minimal log of billing events (event type and date) is kept without your identity, and a record that you asked to delete your account is also kept. As Merchant of Record, Paddle keeps its own payment records under its policies.
• Our providers keep their own service logs and backups for limited periods under their own policies. We have not set custom periods with them.

Where possible, eligible information will be deleted or anonymized when no longer needed.

12. Your Privacy Rights

Depending on your location and applicable law, you may have rights to:

• Access your personal information.
• Correct inaccurate information.
• Request deletion.
• Obtain a copy of your data.
• Object to certain processing.
• Restrict certain processing.
• Withdraw consent.
• Request data portability.
• Challenge certain automated decisions, where applicable.
• Lodge a complaint with a relevant data protection authority.

You can correct and delete records yourself in the app, export transactions as CSV, and delete your account in Settings. We will respond to valid requests within the period required by applicable law.

To exercise your rights, contact: damilolashofoluwe01@gmail.com

We may need to verify your identity before fulfilling certain requests.

13. Nigerian Data Protection Rights

Where Nigeria’s Data Protection Act 2023 and applicable regulations apply, we will process personal data in accordance with relevant legal requirements.

Users may have rights under Nigerian data protection law, including rights relating to access, correction, deletion, objections, and complaints. You may contact the Nigeria Data Protection Commission where applicable.

This statement does not constitute a claim that Tooclear has completed every applicable regulatory assessment or compliance obligation.

14. Children’s Privacy

Tooclear is only for people aged 18 or over.

We do not knowingly solicit personal financial information from children in violation of applicable law. If we discover that information has been collected unlawfully from a child, we will take appropriate action.

15. Cookies and Similar Technologies

Our website and web app use browser storage only for essential functions and preferences, such as keeping you signed in and remembering your theme. The web app also saves its own files (code, fonts and icons) in your browser so it opens quickly and can be installed on your home screen; these files contain no personal or financial information. We do not use advertising or analytics cookies.

Where required, we will request consent before using non-essential technologies. For details, see our Cookie Policy.

16. Marketing Communications

If we offer newsletters or promotional messages, we will provide appropriate choices and unsubscribe mechanisms.

You may opt out of marketing communications without losing access to essential service communications.

17. Account Deletion

You can delete your account in Settings, or ask us to.

Deletion may be subject to legal retention requirements, unresolved billing obligations, security considerations, or the preservation of legitimate shared household records. For example, records you added to a household stay with that household, and your name on them is replaced with “Former member”. We will explain any applicable limitations.

Deleting the app or your account does not cancel a paid subscription by itself. See our Subscription, Cancellation & Refund Policy.

18. Changes to This Policy

We may update this Policy to reflect product changes, new service providers, or legal requirements.

Material changes will be communicated where required. The effective date indicates the current version.

19. Contact

For privacy questions or requests:

Tooclear, operated by Damilola Ibukun Shofoluwe
Ring Road 3, Lugbe, Abuja, Federal Capital Territory 900107, Nigeria
Email: damilolashofoluwe01@gmail.com