Wallet Bot — Privacy Policy

Effective date: August 6, 2026 Last updated: August 6, 2026

This Privacy Policy is published in Spanish and English. For consumers residing in the Argentine Republic, the Spanish version (“Política de Privacidad”) is the legally operative text and prevails in case of any discrepancy. For all other users, this English version prevails and the Spanish version is a convenience translation.

1. Who we are

Wallet Bot (“Wallet Bot”, the “Service”, “we”, “us”, “our”) is a personal expense-tracking application, available as a mobile/native application and as a web application at https://app.walletbot.live.

The controller of the personal-data database (the “responsable de la base de datos” under Argentine Law No. 25,326 on Personal Data Protection) is:

• Controller: [CONTROLLER LEGAL NAME]
• Domicile: [CONTROLLER ADDRESS, ARGENTINA]
• Contact for privacy matters: support@walletbot.live

2. Scope

This Policy describes what personal data we collect through the Wallet Bot native apps and web app, why we collect it, who we share it with, how long we keep it, and the rights you have over it. It forms part of, and should be read together with, our Terms and Conditions.

By creating an account you confirm that you have read this Policy and you give your free, express and informed consent to the processing described in it, including the international transfer described in Section 8. Providing your personal data is voluntary; however, without an email address (or a third-party sign-in) we cannot create an online account for you. You may instead use the app in local-only mode (see Section 16), in which case your financial records stay on your device and are not sent to us (the app still sends the usage and diagnostic data described in Section 3.4).

3. Information we collect

3.1 Account and profile data

• Email address and display name.
• If you register with email and password: your password, stored only as a cryptographic hash. We never store or can read your plaintext password.
• If you sign in with Google, Apple or another supported identity provider: your name, email address, profile picture URL, the provider’s account identifier, and the authentication tokens issued by the provider.
• Email verification status and verification / password-reset tokens (short-lived).

3.2 Financial data you enter

Wallet Bot is a manual-entry expense tracker. We store the financial records you (or the voice assistant acting on your instructions) create:

• Money accounts: the labels you choose (e.g. a bank or wallet name), currency, description, color and icon.
• Transactions: type (expense, income, transfer, balance adjustment), name/description (e.g. a merchant name), amounts and currencies, dates, status, exchange rates for cross-currency transfers, and resulting balances.
• Categories, tags, saved filters and dashboard configuration.

We do not connect to your bank. We never ask for, receive or store bank credentials, card numbers, account numbers (CBU/CVU/IBAN) or any other means of payment. The names you give your accounts are free-text labels only.

3.3 Voice assistant and conversation data

See Section 5, which describes this processing in detail.

3.4 Technical and security data

• Web sessions: IP address and browser user-agent, stored with your session.
• Native app sign-ins: the device’s user-agent string, stored with the session record (this is what lets you recognize signed-in devices).
• Synchronization requests: platform (Android/iOS/macOS) and app version, used to enforce minimum supported versions.
• Configuration requests: platform, app version, device language, and a random installation identifier generated by the app (it is deliberately random app state, not a hardware identifier). These values are processed to serve remote configuration and update notices and are not stored in our database.
• Rate-limiting counters and security/error logs, which may include email addresses in delivery-failure events.
• Usage analytics: events about how you use the app (screens viewed, features used and similar interaction data), together with device and app information (device model, operating system and version, app version, language) and random installation and session identifiers generated by the app (they are not hardware or advertising identifiers).
• Crash and diagnostic data: error and crash reports, including stack traces, device and app information, and the state of the app at the time of the error. Crash reports are not meant to include your financial records, but may incidentally contain fragments of the data being processed when the error occurred.

3.5 Transactional email records

When we send you a transactional email (verification, password reset, account deletion confirmation), our email delivery provider temporarily retains the recipient address, subject and message content (see Section 9), together with delivery events (delivered, bounced, complained).

4. What we do NOT collect

• No connection to banks or financial institutions; no bank or card credentials.
• No precise or approximate geolocation.
• No access to your contacts. We access your files, photos or camera only when you explicitly pick a file, share a file or take a picture — never in the background or without an action from you.
• No advertising identifiers, no advertising networks, no third-party tracking.
• No phone number, date of birth or government ID.
• We do not sell or rent personal data to anyone, and we do not share it for third-party advertising.

5. Voice assistant and AI processing

Wallet Bot’s voice assistant is an optional feature. It lets you record expenses and query your finances by voice or text chat.

• Microphone access is requested only when you start a voice session, and you can deny it; the rest of the app works without it.
• When you start a session, our backend issues a short-lived, single-use access token, and your device then connects directly to the session’s AI provider: Google’s Gemini Live API (Google LLC) or OpenAI’s API (OpenAI, L.L.C.). Your microphone audio is streamed from your device to that provider; raw audio never passes through or is stored on our servers.
• Audio recordings of a session are kept only on your device (native app). They are never uploaded to us; only the type and size of audio segments are recorded server-side.
• We store the conversation content: transcripts of what you said and what the assistant answered, the actions the assistant performed (“tool calls” — e.g. creating a transaction) and their results, and session metadata. For signed-in accounts this history is synchronized to our backend; web voice sessions are not stored on our servers; local-only accounts never upload voice history.
• While a session is active, the assistant can read and modify the financial data in your account (accounts, balances, transactions, categories, tags, summaries) in order to carry out your requests. The data it reads or writes becomes part of the conversation processed by the AI provider.
• The AI provider (Google or OpenAI) processes the audio and conversation content under its own applicable API terms. We configure sessions to use ephemeral, single-use credentials.
• Voice-session history is retained for a maximum of 12 months and is also deleted immediately if you delete your account (Section 9).
• The assistant can make mistakes (mis-hearing amounts, names or currencies). Review the records it creates; see the Terms and Conditions for the corresponding disclaimer.

6. Purposes of processing

We process your personal data to:

1. Provide and operate the Service — creating your account, storing and synchronizing your financial records across your devices, and operating the voice assistant when you use it. This processing is necessary to perform the contract between you and us (Article 5.2(d), Law 25,326).
2. Authentication and security — verifying your email, protecting your account, detecting and preventing fraud and abuse, rate limiting, revoking sessions after a password reset.
3. Transactional communications — emails strictly necessary for the Service (verification, password reset, account deletion). We send no marketing emails; if we ever introduce them, they will be strictly opt-in with a working unsubscribe.
4. Analytics and service improvement — measuring how the Service is used and collecting crash and diagnostic reports to detect errors, improve stability and guide product improvements. We may also analyze the content you enter, in aggregated or de-identified form, to improve and develop features of the Service. We do not use this data for advertising.
5. Legal compliance — responding to valid legal requests and exercising or defending legal claims.

We do not use your data for automated decision-making that produces legal or similarly significant effects on you, and we do not build advertising profiles.

Consequences of not providing data: without an email/identity you cannot create an online account; the local-only mode remains available. You may revoke your consent at any time, without retroactive effect, by contacting us or deleting your account.

7. Recipients: service providers we share data with

We share personal data only with the processors needed to run the Service, under their contractual data-protection commitments:

We may also disclose personal data if required to do so by law, court order or competent authority, or to protect the rights, safety and security of Wallet Bot, our users or third parties. If the Service is transferred as part of a merger, acquisition or asset sale, your data may be transferred with it; we will notify you before your data becomes subject to a different privacy policy.

We never sell your personal data, and we do not share it for cross-context behavioral advertising.

8. International data transfers

Our providers store and process data in the United States of America. Under Argentine law (Article 12, Law 25,326), the United States is not considered a country with adequate levels of data protection. We rely on two safeguards:

1. Contractual safeguards: our providers are bound by data-processing agreements containing data-protection commitments.
2. Your express informed consent: by creating an account and accepting this Policy you expressly consent to your personal data being transferred to and stored in the United States under those safeguards.

You may revoke this consent at any time (without retroactive effect) by deleting your account, since the Service cannot operate without its hosting providers.

9. Data retention

10. Account deletion

You can delete your account and all associated data at any time:

• In the app: Settings → Delete my account; or
• On the web, without the app installed: https://app.walletbot.live/delete-account.

We email you a confirmation link (valid for 24 hours). Once you confirm, deletion begins immediately and is irreversible: all your financial records, voice history, sessions and profile data are permanently erased from our backend, and your identity data is removed from our authentication system. What remains afterwards is described in Section 9.

Deletion is server-side: data stored locally on your devices (Section 16) is removed by signing out on each device or uninstalling the app.

11. Security

We apply technical and organizational measures aligned with the security recommendations of the Argentine enforcement authority (AAIP Resolution 47/2018), including:

• Encryption in transit (TLS) for all connections.
• Passwords stored only as cryptographic hashes, never in plain text.
• Short-lived, single-use credentials for voice sessions; signed, expiring tokens for authentication.
• Mandatory email verification; revocation of all sessions on password reset; rate limiting and anti-enumeration measures on sensitive endpoints.
• On-device storage of credentials in the operating system’s secure storage (Keychain / Android Keystore).

No system is perfectly secure. If we become aware of a security incident affecting your personal data, we will notify affected users and the competent authorities as appropriate to the nature of the incident.

12. Your rights (Argentina)

As data subject (“titular de los datos”) you have, free of charge, the rights of access, rectification, updating and deletion of your personal data (Articles 14–16, Law 25,326):

• Access: we will answer within 10 calendar days of your request. Access is free at intervals of no less than six months, unless a legitimate interest is shown.
• Rectification, updating and deletion: carried out within 5 business days.
• Revocation of consent: at any time, without retroactive effect.

To exercise any right, write to support@walletbot.live from the email address associated with your account (we may ask you to verify your identity), use the in-app options, or use the self-service deletion flow described in Section 10.

The following notices are required by Argentine regulation (their Spanish original text, included in the Spanish version of this Policy, is the legally operative version):

The AGENCY FOR ACCESS TO PUBLIC INFORMATION (Agencia de Acceso a la Información Pública), in its capacity as supervisory authority of Law No. 25,326, is empowered to handle complaints and claims filed by those whose rights are affected by breach of the applicable personal-data protection rules.

The data subject has the right to access their personal data free of charge at intervals of no less than six months, unless a legitimate interest is shown, pursuant to Article 14(3) of Law No. 25,326.

You can reach the AAIP at https://www.argentina.gob.ar/aaip.

13. Your rights (United States)

We extend the following rights to all users residing in the United States, regardless of state:

• Right to know / access the personal information we hold about you and obtain a portable copy.
• Right to correct inaccurate personal information.
• Right to delete your personal information (Section 10).
• Right to opt out of “sale” or “sharing” of personal information and of targeted advertising — noting that we do not sell or share personal information as those terms are defined in US state privacy laws, and we do not engage in targeted advertising.
• Right to non-discrimination for exercising any of these rights.

To exercise these rights, email support@walletbot.live from the address associated with your account; we will verify the request and respond within 45 days (extendable once where reasonably necessary, with notice). Authorized agents may submit requests with proof of authorization. If we deny a request, you may appeal by replying to our decision, and we will respond to the appeal.

14. Children

The Service is intended for adults and requires users to be 18 years or older. We do not knowingly collect personal data from anyone under 18, and in particular from children under 13 (COPPA). If we learn that we hold data of a person under 18, we will delete the account and its data. If you believe a minor has provided us data, contact support@walletbot.live.

15. Cookies and similar technologies (web app)

The web app may use cookies and similar browser storage to make the Service work (for example, keeping you signed in). We do not use third-party cookies.

16. Data stored on your device

The app stores your data locally on your device so it can work offline. If you use local-only mode (no online account), your data stays exclusively on your device, is never sent to us, and we cannot recover it if the device is lost (the app still sends the usage and diagnostic data described in Section 3.4). Signing out of an account or uninstalling the app removes its local data. Your operating system’s backup features may include app data according to your device settings, which are under your control.

17. Changes to this Policy

We may update this Policy as the Service evolves. If we make material changes, we will notify you through the Service (for example, with an in-app notice) before or when they take effect, and, where the change requires it (for example, a new purpose of processing), we will ask for your consent. The “Last updated” date at the top always reflects the current version. If you do not agree with a change, you may delete your account.

18. Contact

• Privacy and data-protection requests: support@walletbot.live
• Controller: [CONTROLLER LEGAL NAME], [CONTROLLER ADDRESS, ARGENTINA]
• Supervisory authority (Argentina): Agencia de Acceso a la Información Pública — https://www.argentina.gob.ar/aaip