Privacy Policy — Adentro Money
Last updated: 20 September 2026
This Privacy Policy explains how Adentro Limited ("we", "us", "our") collects, uses, and protects your personal data when you use Adentro Money (the "Service"). We are committed to being straightforward about what we hold and why — because a service that helps you understand your money only works if you can trust it with your data.
We are the data controller for the personal data described in this policy.
Contact:
Adentro Limited
4 Warren Farm Close, Epsom, KT17 3AJ, United Kingdom
Email: support@adentromoney.co.uk
1. Who this policy covers
This policy applies to everyone who uses Adentro Money. If you are part of a household, each member has their own account and is a separate user — you each control your own data, and this policy applies to each of you individually.
2. What personal data we collect
We collect only what we need to provide the Service:
You give us directly:
- Account details — your email address and password (passwords are stored using industry-standard one-way hashing; we never store them in readable form).
- Two-factor authentication (2FA) data — if you enable 2FA, a secret used to verify authenticator-app codes, and recovery codes (both stored encrypted).
- Financial data you import — the bank and card statements you upload (as PDF or CSV), and the transactions, balances, and account information within them. This may include details of people or organisations you have paid or received money from, because that information appears on your statements.
- Categories, notes, and settings — the way you organise and label your financial data.
- Household connections — if you invite someone to your household (or accept an invite), we process the email address used for that invitation.
- Support communications — anything you send us when you contact us for help.
We collect automatically:
- Technical and usage data — such as your IP address, browser type, log-in times, and basic activity needed to operate and secure the Service.
- Cookies — see our Cookie Policy / Section 9 below.
We do not:
- Connect to your bank via Open Banking or ask for your online banking login. You are always in control of what you upload.
- Collect special-category data deliberately. Your financial data may incidentally reveal sensitive information (for example, payments that suggest health, religion, or political affiliation). We treat all your financial data as confidential and process it only to provide the Service. [review: lawful basis for any incidental special-category data]
3. Why we use your data and our lawful basis
Under UK GDPR, we must have a lawful basis for using your data. We rely on:
- To provide the Service (contract): creating and securing your account, reading and organising your imported statements, reconciling balances, generating insights, and answering your questions about your finances. This is necessary to perform our contract with you.
- AI-powered features (contract): when you ask a question of the built-in assistant, or when the Service categorises your transactions, relevant financial data is processed to produce the answer or categorisation (see Section 5).
- To keep the Service secure and working (legitimate interests): preventing fraud and abuse, diagnosing problems, and protecting our users and systems. We balance this against your rights.
- To take payment (contract / legal obligation): processing your subscription and meeting tax and accounting requirements.
- To send you service messages (contract / legitimate interests): for example, password resets, security alerts, household invitations, and important changes to the Service.
- Marketing (consent), if applicable: we will only send you marketing emails if you have agreed, and you can withdraw consent at any time.
4. Who we share your data with (our processors)
We keep our use of third parties deliberately small. We do not sell your data. We share it only with the service providers needed to run Adentro Money, each acting under a data-processing agreement:
| Provider | What they do | Where |
|---|---|---|
| Hetzner Online GmbH | Hosts our servers and stores your data | Germany (EU) |
| Resend | Sends transactional emails (e.g. password resets, invitations) | [review: confirm processing location + DPA] |
| Anthropic, PBC | Provides the AI models behind the assistant and transaction categorisation, via its commercial API | United States |
| [Payment processor — e.g. Paddle / Lemon Squeezy] | Processes your subscription payment as merchant of record | [to confirm on selection] |
We may also disclose data if required by law, to enforce our terms, or to protect the rights, safety, and property of our users or ourselves.
5. AI processing and your financial data
Some features — the assistant that answers your questions, and automatic transaction categorisation — are powered by AI models provided by Anthropic through its commercial API. To generate a response, the relevant portion of your financial data is sent to Anthropic's API for processing.
Important points:
- Under Anthropic's commercial (API) terms, your data is not used to train Anthropic's models by default.
- Anthropic processes this data as our processor under a Data Processing Addendum that includes Standard Contractual Clauses for international transfers.
- We send only what is needed to answer your question or categorise your transactions — not your entire account.
[review: confirm the UK International Data Transfer Addendum (IDTA) position and whether a Transfer Impact Assessment is recorded.]
6. International data transfers
Your data is stored within the EU (Germany). Some processing — specifically the AI features — involves a transfer to the United States (Anthropic). Where data leaves the UK/EU, we rely on appropriate safeguards, such as Standard Contractual Clauses and the UK Addendum, to protect it. [review]
7. How long we keep your data
- We keep your account data and financial data for as long as your account is active.
- If you delete your account, we delete your financial data and personal data within [30] days, except where we must keep certain records longer to meet legal, tax, or accounting obligations, or to resolve disputes. [review: retention periods]
- Backups are kept on a rolling basis and are encrypted; data in backups is overwritten in the normal backup cycle.
8. Your rights
Under UK GDPR you have the right to: access your data; correct it; delete it; restrict or object to processing; data portability; and withdraw consent where we rely on it. You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk.
To exercise any right, email us at the address above. We will respond within one month.
9. Cookies
We use a small number of cookies that are strictly necessary to run the Service (for example, to keep you logged in). If we use any non-essential cookies (such as analytics), we will ask for your consent first. [review: confirm actual cookies in use.]
10. Security
We protect your data with measures including: encryption of sensitive fields (such as 2FA secrets) at rest; hashed passwords; optional two-factor authentication; encrypted, off-site backups; access controls; and hosting with a reputable EU provider. No system is perfectly secure, but we take our responsibility for your financial data seriously.
11. Children
Adentro Money is not intended for anyone under 18, and we do not knowingly collect data from children.
12. Changes to this policy
We may update this policy from time to time. If we make material changes, we will notify you (for example, by email or an in-app notice) before they take effect.
13. Contact
Questions about this policy or your data? Email support@adentromoney.co.uk or write to us at the address above.