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Privacy Policy

Last updated: April 3, 2026

This Privacy Policy describes how forvalt ("we", "us", "the App") collects, uses, stores, and protects your personal data. forvalt is a financial planning tool delivered as a Telegram Mini App.

1. Operator

forvalt is operated as an independent project. For privacy-related inquiries, contact us via the Telegram bot @forvalt_bot using the /support command.

2. Data We Collect

2.1 Data from Telegram

When you open the App through Telegram, we receive the following from the Telegram Mini App API:

We do not access your phone number, contacts, or message history.

2.2 Data you provide

2.3 Data collected automatically

3. Lawful Basis for Processing

We process your personal data under the following legal bases (GDPR Article 6):

Processing activityLawful basis
Financial planning and projectionsContract — necessary to provide the core service you signed up for
Syncing data across devicesContract — necessary to deliver the service
AI financial advisorConsent — initiated only when you explicitly use the feature; data sent to Groq (US) only upon your action
Payment processing (Stripe)Contract — necessary to process your Premium subscription
Product analytics (anonymous aggregates)Legitimate interest — improving the App. You can opt out via Profile → Data & Privacy → Analytics. We use only bucketed, non-identifiable values.
Customer supportLegitimate interest — responding to your support requests
Cross-border transfers (Belarus users)Explicit consent — collected during onboarding as required by Law No. 99-З

4. How We Use Your Data

PurposeData used
Financial planning and projectionsDate of birth, income, expenses, goals, assets
Syncing data across devicesFull app state (linked to Telegram ID)
AI financial advisorFinancial snapshot + your questions (sent to Groq)
Payment processingTelegram ID and username (sent to Stripe)
Product analyticsAnonymous aggregate counters and session data
Customer supportTelegram name and messages sent via /bug or /support

5. Where Your Data Is Stored

5.1 On your device

Your financial data is stored in your browser's localStorage. This data persists until you clear your browser data or delete it through the App.

5.2 On our servers

ServiceLocationData storedRetention
Supabase (PostgreSQL)EUEncrypted app state (AES-256-GCM), subscription recordsUntil user requests deletion
Redis CloudEU (Frankfurt)Anonymous aggregate counters, session flagsAnalytics: 48 hours. User metadata: until deletion request

5.3 Admin audit logs

All administrative actions (e.g., granting premium, sending messages, banning users) are logged in an append-only audit table. These logs contain the admin's Telegram ID, the action performed, the target user ID, and a timestamp. Audit logs are retained for 7 years for regulatory compliance and dispute resolution, after which they are permanently deleted.

5.4 What is NOT stored on the server

6. Third-Party Data Sharing

We share data with the following third-party services:

ServiceCountryWhat is sharedWhenDPA status
Groq (AI processing)United StatesFinancial snapshot (income, expenses, goals, assets) and your questionsOnly when you use the AI advisorGroq processes data per their Privacy Policy. Data is not retained after processing.
Stripe (payments)United StatesTelegram ID, username, subscription planOnly when you subscribe to PremiumStripe operates under their Privacy Policy and Data Processing Addendum
Supabase (database)EUEncrypted app stateOn every syncSupabase operates under their Privacy Policy and DPA
Redis Cloud (cache)EU (Frankfurt)Anonymous counters, session flagsOn app openRedis operates under their Privacy Policy
Telegram Bot APIGlobalMessages, notificationsWhen you interact with the botTelegram's Privacy Policy applies

We do not share data with advertising networks, data brokers, or social media platforms.

7. Cross-Border Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States (Groq, Stripe) and the European Union (Supabase, Redis). These transfers are necessary to provide the App's functionality.

For EU/EEA users, transfers to the US are covered by the service providers' Standard Contractual Clauses (SCCs) and Data Processing Agreements.

For users in Belarus, cross-border transfers are performed only with your explicit consent, obtained during the onboarding process, as required by Law No. 99-З "On Personal Data Protection".

8. Your Rights

8.1 All users

8.2 Users in Belarus

In accordance with Law No. 99-З, you additionally have the right to:

Belarus-specific restrictions:

Online payment via Stripe is not available for users in Belarus. Premium can only be activated through direct contact with the administrator.

We do not send marketing communications or track individual usage for Belarus users who have not given consent.

9. Data Deletion

When you request deletion (Profile → Data & Privacy → "Delete all my data"), we permanently remove:

Aggregate, anonymized analytics counters (total opens, total goals created, etc.) are not deleted as they cannot be linked back to you.

Admin audit log entries referencing your Telegram ID are retained for the audit log retention period (7 years) for regulatory compliance, but contain no financial data.

10. Data Security

11. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms:

Our full breach response procedure is documented at breach-notification.html.

12. Children's Privacy

forvalt is not intended for users under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us via /support.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the App after changes constitutes acceptance of the updated policy.

14. Contact

For any privacy-related questions, data access requests, or deletion requests:

See also: Terms of Service · Data Protection Impact Assessment