Privacy Policy

1. Data Controller

The data controller for your personal data is Reflective, a French simplified joint-stock company (SAS) with a share capital of €100, registered with the Nanterre Trade and Companies Register under number 913 527 925, headquartered at 54 rue de Malabry, 92350 Le Plessis-Robinson, France. For any questions regarding the protection of your data, you may contact us at: antoine.galpin@reflective.studio.

2. Data Collected

We collect the following categories of data:

2.1 Account Data

Name, surname, email address, profile picture (optional), encrypted password, language and currency preferences.

2.2 Expense Data

Amounts, descriptions, dates, categories, currencies, splits between members, reimbursement history.

2.3 Receipt Photos

Images of scanned receipts for automatic item recognition. These images are processed to extract information and then deleted after processing. They are not used for algorithm training purposes.

2.4 Group Data

Group names, member lists, invitations sent and received.

2.5 Technical Data

IP address, device type, operating system, app version, session identifiers, usage logs.

3. Purposes of Processing

Your data is processed for the following purposes:

• Providing and improving the Service (expense management, receipt scanning, balance calculation)
• Managing your user account and authenticating your identity
• Enabling communication between group members
• Sending notifications related to the Service (new expenses, reimbursements, invitations)
• Analyzing Service usage to improve it
• Ensuring the security of the Service and preventing fraud
• Complying with our legal obligations

4. Legal Basis for Processing

The processing of your data is based on the following legal grounds:

• Performance of a contract: processing is necessary to provide the Service you have requested
• Consent: for sending marketing communications and using non-essential cookies
• Legitimate interest: for improving the Service, security and fraud prevention
• Legal obligation: for compliance with our accounting and regulatory obligations

5. Data Sharing

We may share your data with the following third parties:

• Members of your group: expense information is shared with other members of the groups you belong to
• Hosting and technical service providers: for data storage and processing (servers located in the European Union)
• Analytics services: to understand Service usage (data anonymized where possible)
• Competent authorities: in case of legal obligation or judicial requisition

We never sell your personal data to third parties.

6. Data Retention

Your data is retained for the following periods:

• Account data: for the duration of your use of the Service, then deleted within 30 days of account deletion
• Expense data: for the duration of your use of the Service, then 5 years for accounting purposes
• Receipt photos: deleted after processing and data extraction
• Technical data: 12 months

7. Your Rights

In accordance with the General Data Protection Regulation (GDPR), you have the following rights:

• Right of access: obtain a copy of your personal data
• Right of rectification: correct inaccurate or incomplete data
• Right of erasure: request the deletion of your data
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to the processing of your data on legitimate grounds
• Right to restriction: request the limitation of processing in certain cases
• Right to withdraw consent: withdraw your consent at any time for processing based on consent

To exercise these rights, contact us at antoine.galpin@reflective.studio. We will respond to your request within one month. You also have the right to lodge a complaint with the CNIL (French Data Protection Authority).

8. Cookies

The Splitz website does not use any cookies and does not collect any browsing data. Only the mobile application collects the data described in this policy.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, modification, disclosure or destruction. This includes encryption of data in transit and at rest, strict access controls, and regular security audits.

10. Policy Changes

We may update this Privacy Policy from time to time. In the event of a substantial change, we will notify you via an in-app notification or by email. The date of the last update at the top of this page indicates the current version.

11. Contact

For any questions regarding this Privacy Policy or the protection of your data, you may contact us:

Data contact: antoine.galpin@reflective.studio

Address: Reflective SAS, 54 rue de Malabry, 92350 Le Plessis-Robinson, France