Privacy
Privacy policy
Draft, not yet reviewed by a lawyer.
Highlighted items are still to be confirmed. This page is hidden from search engines until they are resolved.
In short
Capman is paid only by your subscription. We do not sell your data, show ads or run advertising trackers.
Capman can read your accounts but cannot move your money.
Statement text, transactions and account details are sent to an AI provider so the app can read and categorise them. Section 4 names every company that handles your data.
You can export your household's data in Settings, and you can ask us to delete your data. We do it within 30 days.
1. Who we are
Capman is run by [COMPANY NAME, legal form], [ADDRESS, COUNTRY] ("Capman", "we", "us"). We are the controller of your personal data under the EU General Data Protection Regulation (GDPR). Contact: [privacy@capmanlabs.ai: confirm the mailbox exists].
2. What we collect
When you sign in
Your name, email address and profile picture from Google, which we use to sign you in. Access is by invitation, so we also keep your household, your role (owner, member, accountant or viewer) and the invitations you send or accept.
What you add
Accounts, properties, vehicles and debts; balances and their dates; holdings; transactions; budgets; notes; and any statement or file you upload (PDF, CSV or Excel). These can include account numbers, names and amounts. Please do not upload documents containing passwords, card numbers or government identity numbers.
From bank connections
If you connect a bank through Plaid or Enable Banking, we receive account names, masked account numbers, balances, transactions and, where offered, holdings. Your bank login details go only to the bank or the connection provider. We never see or store them.
Technical data
Our servers keep logs of requests and errors, which can include your IP address and browser type, so we can keep the service running and secure. We also record an audit trail of important actions: connecting or disconnecting a bank, invitations, joining a household and role changes.
What we do not collect
We do not run advertising or analytics trackers on the app or on this website. [Confirm that Vercel Web Analytics and Speed Insights are switched off]
3. Why we use it, and our legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Provide Capman: sign you in, store and show your finances, read statements, categorise transactions, run the advisor and scenarios | Contract (6.1(b)) |
| Connect your bank and refresh your data | Contract, and your consent when you authorise the connection (6.1(a)) |
| Keep the service secure, prevent abuse, keep an audit trail, fix faults | Legitimate interests (6.1(f)) |
| Meet legal duties, such as accounting and responding to lawful requests | Legal obligation (6.1(c)) |
We do not use your data for advertising, to build profiles to sell, or to decide what financial product to point you at. We take no commissions or referral fees.
4. Who else handles your data
We use these companies (processors) to run Capman. Each handles only what its job needs.
| Company | What it does | What it receives |
|---|---|---|
| Supabase | Database and sign-in | Everything you store in Capman. Region: [CONFIRM] |
| Vercel | Hosting | Requests to the app and site, including IP addresses |
| Sign-in | Your Google account identity when you sign in | |
| Plaid | Bank connections | Your bank credentials, entered on Plaid's or your bank's own screen. We receive accounts, balances and transactions |
| Enable Banking | Bank connections in Europe | As above, through your bank's Open Banking interface |
| Cerebras | AI that reads statements, categorises transactions and powers the advisor | Statement text, transaction descriptions, account names and numbers, and the questions you ask the advisor |
| Anthropic | Optional AI review of transaction categories | Transaction descriptions and categories, when that feature is used |
| Tavily and OpenFIGI | Look up and verify securities | Only a security's public name, ticker or ISIN. No amounts, account numbers or personal data |
| Frankfurter | Exchange rates | A currency pair. No personal data |
About the AI providers. The AI sees the content of what you upload and ask. Cerebras says in its own policy that inputs and outputs are not retained and that logs are deleted when no longer needed. It does not state a retention period or a data processing agreement, and we have not yet asked for one. [Update when the agreement is in place] We use AI providers' business interfaces, not consumer chat products, and we do not allow them to train on your data. [Confirm per provider] We can give you the current provider terms on request.
We do not sell your data, and we do not share it with anyone else except where the law requires it.
5. Moving data outside Europe
Some of these companies process data in the United States. Where we send personal data outside the EU/EEA, we rely on the European Commission's standard contractual clauses or another transfer mechanism the law allows. [Confirm the mechanism for each provider]
6. How we protect it
- Data travels over HTTPS and is encrypted at rest by our database provider.
- Bank connection tokens are encrypted with a separate key, which we can rotate.
- Bank access is read-only. Capman cannot start payments, transfers or trades.
- Access follows your role, and the database itself enforces it, not just the app.
- Signing out clears cached financial data from your browser.
What this does not mean. Capman is not end-to-end encrypted: our servers can read your data, because the app needs to in order to read statements and show your picture. [State who at Capman can access production data, and under what conditions] No system is perfectly secure. If a breach puts your rights at risk we will tell you and the supervisory authority as the law requires.
7. How long we keep it
We keep your data while your account is open. If you ask us to delete it, we remove it from our live database within 30 days, and it leaves backups when they roll over [CONFIRM backup retention period]. Where a bank connection supports it, we ask the provider to revoke access. With some European connections the consent stays open at your bank until it expires, and you can end it in your bank's own settings. We may keep a minimal record where the law requires, such as our audit trail for a defined period [CONFIRM].
Deleting a single account inside Capman removes its history. Marking it closed keeps the history but removes it from totals.
8. Your rights
Under the GDPR you can:
- get a copy of your data (access), and fix what is wrong (rectification);
- have your data deleted (erasure), or its use restricted;
- receive your data in a portable format. Settings has an export of your household's data, for roles allowed to export;
- object to processing based on legitimate interests;
- withdraw consent, including a bank connection, at any time.
Email [privacy@capmanlabs.ai] and we will answer within one month. You can also complain to your data protection authority [name the authority, for example IMY in Sweden].
9. Cookies and local storage
We use only what the service needs: a sign-in session, and a copy of some of your data cached in your browser so the app loads quickly. Signing out clears the cached data. We use no advertising or tracking cookies, so there is nothing to opt out of.
10. Children
Capman is for adults. You must be at least 18. We do not knowingly collect data from children.
11. If the company changes hands
If Capman is ever sold or merged, we will tell you before your data is transferred and let you export it and leave first.
12. Changes to this policy
If we change this policy in a way that matters, we will tell you in the app or by email before it takes effect. The date at the top shows the current version.
13. Contact
[COMPANY NAME, ADDRESS, privacy@capmanlabs.ai]