Privacy Policy — Bitfair Split

DIVINEGIFT ONYII LTD ("we", "us", "our") is the publisher of Bitfair Split (the "App") for Android. This Privacy Policy explains how the App handles information about you ("you", "the user"). It is written to meet the requirements of the EU/UK General Data Protection Regulation (GDPR/UK-GDPR), the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), other US state privacy laws, the Children's Online Privacy Protection Act (COPPA), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA).

1. Plain-English summary

Bitfair Split is a 100% offline application. It does not create an account for you, it does not send any data over the internet, and it does not include any analytics, advertising, or third-party tracking software development kits ("SDKs"). Every piece of information you enter — groups, people's names, expenses, settlements, your display name — lives only on your device, inside the App's private storage area.

Because we do not receive your data, we have nothing about you. We cannot read it, share it, sell it, or hand it over to anyone.

2. Who we are (data controller)

ItemDetailsCompany nameDIVINEGIFT ONYII LTDAppBitfair Split (Android)Contact e-mailalaoayomide2020@gmail.comRoleData Controller (where any data processing is deemed to occur)

You can reach us at the e-mail address above for any privacy-related question or to exercise any of the rights listed in Section 9.

3. The data we collect

We do not collect, transmit, store on our servers, or otherwise process any personal data. The App has no network permission in its Android manifest and performs no outgoing network requests.

The categories below describe data that you yourself enter into the App and that never leaves your device unless you actively export it (see Section 5):

Display name (defaults to "You" until you change it).
Names you type to identify other members of a group.
Expense descriptions, amounts, dates, categories, optional notes.
Group names and the currency you choose for each group.
Records of settlements you choose to mark as paid.
App preferences (default currency, theme).

This information is stored in a private database on your device that is only accessible to the App itself. We have no means to read it remotely.

4. Permissions requested by the App

The App requests no Android runtime permissions: no location, no camera, no microphone, no contacts, no calendar, no photo library, no storage, and no network access. If a future version of the App ever needs an additional permission, this Policy will be updated and the permission will be requested through the standard Android dialog at the moment it is needed.

The App provides a backup feature that lets you export a JSON file containing the data you have entered (groups, people, expenses, settlements, preferences). The export is performed through the standard Android Storage Access Framework ("SAF"):

You — not the App — choose the destination of the file.
If you save the file to a cloud-synced folder (for example Google Drive, Dropbox or OneDrive), the operating system or that third party may copy the file to their servers. Their privacy practices govern that copy. We are not a party to that processing.
If you share the file with another person (e-mail, messaging app, USB transfer), they will be able to read every record in it.

The import feature is the reverse: you pick a JSON file and the App reads it into the on-device database. The App never accesses files you have not explicitly selected.

6. Android System Backup

Android offers a feature called Auto Backup that, when enabled by the user, periodically copies certain app data to the user's own Google Drive account, encrypted with the user's Google credentials. This is controlled at the operating-system level, not by the App.

If Auto Backup is enabled on your device, the App's on-device database may be included. To opt out, go to your Android Settings → System → Backup. We have no access to that backup; it lives inside your personal Google account.

7. Cookies, tracking technologies, advertising

The App contains no cookies, no advertising identifiers, no analytics SDKs, no crash-reporting SDKs, and no third-party tracking technologies of any kind. We do not engage in cross-context behavioural advertising, "sharing" as defined by the CCPA/CPRA, or the sale of personal information.

8. Children's privacy (COPPA and equivalent)

The App is suitable for general audiences and does not knowingly collect any information from children under 13 (or under 16 in the European Economic Area), because the App does not collect personal information from anyone. We do not target the App to children and we do not build profiles. A parent or guardian who believes information about a child has nonetheless been entered into the App on a shared device can delete it directly inside the App via Settings → Clear all data.

9. Your privacy rights

Because we hold no personal data about you on our systems, in practice the rights below can be fully exercised by you inside the App, without contacting us. You can also write to us at alaoayomide2020@gmail.com and we will respond within the legally required timeframe (one month under GDPR, 45 days under CCPA/CPRA, 30 days under PIPEDA).

You have the following rights:

Right of access (Art. 15) — see what data exists. All data is visible inside the App; tap any group, expense or settlement to view its contents, or use Settings → Export backup to obtain a machine-readable JSON copy.
Right to rectification (Art. 16) — edit any expense, member, group, settlement, or preference directly in the App.
Right to erasure / right to be forgotten (Art. 17) — delete individual records inside the App, or use Settings → Clear all data to wipe the entire on-device database. Uninstalling the App also removes its data.
Right to restriction of processing (Art. 18) — because we do not process your data on any server, no restriction action is needed on our side; you can stop using the App at any time without consequence.
Right to data portability (Art. 20) — Settings → Export backup produces a structured JSON file that you can import into a future version of the App or process with any text editor.
Right to object (Art. 21) — not applicable, as we do not process data for direct marketing, profiling, or any purpose based on legitimate interests.
Right not to be subject to automated decision-making (Art. 22) — the App performs no automated decision-making about you. The settlement calculator is a deterministic arithmetic tool that only operates on data you yourself enter.
Right to lodge a complaint with a supervisory authority — you may contact your national data protection authority. A list is available at edpb.europa.eu/about-edpb/about-edpb/members_en.

Legal basis (GDPR Art. 6). If any local processing inside the App is deemed to require a lawful basis, it relies on your consent (Art. 6(1)(a)), freely given by entering data, which can be withdrawn at any time by deleting that data or uninstalling the App.

9.2 California (CCPA / CPRA) and other US state privacy laws

Bitfair Split does not collect, sell, share, or disclose personal information. Notwithstanding, we acknowledge the following rights, which apply by analogy to data held on your device:

Right to know what categories of personal information are held — see Section 3 above.
Right to delete personal information — use Settings → Clear all data inside the App, or uninstall the App.
Right to correct inaccurate personal information — edit directly in the App.
Right to opt out of sale or sharing — there is nothing to opt out of; we do not sell or share personal information.
Right to limit use of sensitive personal information — not applicable; we do not process sensitive personal information.
Right to non-discrimination — exercising any right will not result in reduced functionality, higher prices, or worse service.

If you reside in Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Florida (FDBR), or any other US state with a comprehensive privacy statute, the rights granted by your state law are honoured on the same basis as described above: deletion, correction, access, and portability are available through the App itself.

We do not engage in "targeted advertising" or "profiling" as defined by these statutes.

9.3 Canada (PIPEDA, Quebec Law 25)

If you are in Canada, you have the right to:

Access the personal information held about you — visible in-app, or exportable as JSON.
Correct that information — edit directly in the App.
Withdraw consent — delete records or uninstall the App.
File a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, for Quebec residents, with the Commission d'accès à l'information (cai.gouv.qc.ca).

We do not transfer personal information outside Canada because we do not transfer personal information at all.

9.4 Other jurisdictions

Where local law grants additional rights (for example Brazil's LGPD, Australia's Privacy Act, Switzerland's nFADP), we will honour those rights to the extent applicable. Contact us at alaoayomide2020@gmail.com.

10. International data transfers

Because no data leaves your device under our control, there are no international data transfers to disclose. Any cross-border transfer that occurs as a result of your own use of Android Auto Backup or your own choice of cloud-synced folder for an export file (Section 5–6) is governed by the respective third party's privacy policy.

11. Data retention

Data lives on your device for as long as you decide to keep it. There is no server-side retention schedule because there is no server. Uninstalling the App, or using Settings → Clear all data, removes the entire on-device database immediately.

12. Security

Data is stored inside the App's private storage area, which is sandboxed by the Android operating system and not readable by other applications. Operating-system-level disk encryption protects the data at rest on modern Android devices. We do not transmit your data, so there is no in-transit security to describe on our side.

No method of electronic storage is 100% secure; we recommend keeping your device protected with a screen lock and up-to-date system software.

13. Third-party software

The App is built on top of open-source libraries published by Google (AndroidX, Jetpack Compose, Room, DataStore) and the Kotlin Foundation (Kotlin standard library, kotlinx.coroutines). These libraries execute locally inside the App and do not phone home. We do not include any third-party analytics, advertising, attribution, or tracking SDK.

A complete list of open-source components and their licences is bundled with the App and available on request from alaoayomide2020@gmail.com.

14. Do Not Track signals

The App contains no web tracking and therefore does not respond to "Do Not Track" browser signals; there is no tracking to disable.

15. Changes to this Privacy Policy

If we ever update this Policy, the new version will be published at the URL where you are reading it, and the Effective date at the top will be updated. Material changes (for example if the App ever begins collecting any data) will additionally be announced inside the App on the next launch.

16. How to contact us

For any question about this Privacy Policy, to exercise any of the rights above, or to file a complaint, write to:

DIVINEGIFT ONYII LTD

E-mail: alaoayomide2020@gmail.com

We will respond within the timeframes required by the law applicable to you.