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Privacy

What data Orwanna processes, on the website and in the app, why, and how to ask us to delete it.

This website

This part explains what happens when you visit orwanna.com. Below it is the full privacy policy, which covers the app and the website.

Nothing loads until you decide

When you arrive, no measurement or advertising tool loads, and we store nothing on your device except your cookie choice, once you make it. While you decide, what you do on the page (opening a question or using the calculator, for example) is kept only in that tab's memory. If you accept, it is sent. If you reject or close the page, it is deleted without leaving your browser.

If you accept

You can accept everything or, under "Choose", only analytics or only advertising.

  • PostHog, for analytics, with servers in the EU (eu.i.posthog.com): the pages you see, how far down them you get, the questions you open, the download buttons you press, your approximate country, the type of device and, if you arrive from one of our ads or links, where you came from. It sets cookies and stores data in your browser's storage to recognise your visit.
  • A recording of your visit, also with PostHog, to see where people get stuck. What you type into fields is hidden in the recording.
  • In the calculator: the card you pick, and the balance and monthly cuota exactly as you type them, with the result (how many years it would take to pay off and whether your cuota covers the interest). If you press the link to your issuer's official terms, we record that you pressed it and for which card.
  • The Meta pixel, for advertising: it sets a cookie and tells Meta you visited the page, so we can tell whether the ads we pay for bring anyone. Meta processes this outside the EU, under its own standard contractual clauses. It never receives what you type into the calculator.

If you reject

Neither PostHog nor the Meta pixel loads. We store your choice in your browser (orwanna_consent_v3) for 12 months so we don't ask again.

Changing your mind

Under "Cookie settings" at the bottom of every page. If you withdraw what you accepted, we remove PostHog's and Meta's cookies and data from your browser and the page reloads without them.

Calculator links

A calculator link with figures carries the balance and the cuota in the web address, so it can show them. That address stays in the server's technical logs for a limited time. We don't send it to PostHog with the figures: we strip them before measuring anything.

The old waiting list

This site no longer asks for your email. If you joined the waiting list it used to have, your email and your answers are still stored in PostHog. Write to us and we'll delete them.

Legal basis

Your consent, for analytics, recording and the Meta pixel. You can withdraw it whenever you like from "Cookie settings". We don't sell your data.

How long

Analytics data is kept for at most [PERIOD PENDING: Filip sets it in PostHog] and then deleted.

Your rights

You can ask us for access to your data, to correct it or to delete it, and object to us processing it. If we don't answer you properly, you can complain to the Spanish Data Protection Agency (aepd.es).

For any of these, write to [email protected].

DRAFT, pending legal review

Version 0.1, 5 November 2026. Applies to the Orwanna app for iPhone and Android and to the website orwanna.com. The Spanish version is the source; if the two differ, the Spanish one applies.

In short

  • Orwanna reads the transactions on your accounts through Tink to work out your round-ups and propose sends to your debt.
  • Money never passes through Orwanna. A licensed partner initiates each payment. Orwanna never initiates, holds or executes it: the money goes from your account straight to your debt, after you confirm at your bank.
  • We do not sell your data.
  • You can delete your account from the app. Your data leaves our database at that moment and leaves the backups over the following days (section 6).

1. Who is responsible

The controller of your data is [RAZÓN SOCIAL], tax id (NIF) [NIF], registered address [DOMICILIO], registered at the [REGISTRO MERCANTIL]. In this policy we call it "Orwanna" or "we".

  • General contact: [EMAIL DE CONTACTO]
  • Privacy and your rights: [CONTACTO DE PRIVACIDAD]

[Data protection officer: whether one must be appointed is still to be confirmed. If one is, add their contact here.]

2. What data we process

2.1 In the app

Before you create an account. The first time you open the app we create an anonymous user with a random identifier. It lets you accept access to your bank data, connect your bank and try the app before you create an account. If you do not sign in or start the trial within 72 hours, we delete it with everything linked to it, bank data included.

Your account. When you sign in with Apple or Google we receive the identifier Apple or Google assigns to you, your email (or Apple's relay address if you choose to hide yours) and your name, if Apple or Google gives it to us. We also keep the language you choose. You never have a password with us.

Bank data we read through Tink.

  • From your accounts: the account name and type, the currency, the balance, the last four digits of the IBAN and, if the bank sends it, the masked card number.
  • From your transactions: the date, the amount, the currency, whether it is pending or booked, the description your bank gives it and, if the bank sends them, the merchant name, the category and the merchant category code. The first time we read the last 90 days. After that we read what is new, twice a day.
  • From the access permission: which bank it is, when the permission expires and its status.
  • The bank's response as it arrives. It can include your name as account holder and data about other people who appear in your transactions, for example the name or IBAN of someone who sends you a transfer. We keep this copy for 90 days and then delete it. We do not keep the full IBAN of your accounts: we strike it out before storing anything and keep only the last four digits.

We never see your bank login details. You type them on your bank's page, not in Orwanna.

Your debts. The name you give it, the balance, the interest rate (TIN), the monthly payment, the card's IBAN that sends go to, the holder's name and the last four digits of the card. You type them in, or we take them from a card that appears in your accounts.

Round-ups and sends. The multiplier, the weekly cap if you set one and the minimum balance you want to leave in the account. For each send: the amount, the status, the dates, the debt it goes to, the account it comes from, the payment's identifier at Tink and what Tink tells us about the payment. That response includes the IBAN of your account and of your card; we strike them out 90 days after the send ends.

Trial and subscription. The status of your trial or subscription, its start, renewal and end dates, and the purchase identifier Apple or Google sends us. We do not see your card or payment details: the store takes the payment.

Device and notifications. Whether your phone is an iPhone or Android, the notification code Apple or Google assigns and the last time the app used it.

Security and errors. The IP address and technical details of each request in the server logs. A log of security events: sign-in and sign-out, device registered, attempts to connect the bank and their outcome, account deletion. Error reports from the app and the server, from which we remove emails, IBANs, request contents and credentials before sending.

Use of the app. We record some steps: install, acceptance of bank-data access, bank connected, subscription screen shown, trial started, account created, send confirmed, send completed, subscription active and subscription expired. Each step carries a pseudonymous identifier and, at most, the band your debt falls in (for example "between 1,000 and 3,000 €"). Never exact amounts, IBANs, names or emails.

What you write to us. If you write to us, your email and what you tell us.

What stays on your phone. The app keeps your first name on the phone to greet you, and your language preference. The daily message is worked out on the phone itself and does not reach us.

2.2 On the website

  • If you joined the old waiting list, removed on 5 November 2026: your email and, if you gave them, your answers to the optional questions and your phone or WhatsApp number. The website no longer collects any of these.
  • In the calculator: the card you choose, the balance and monthly payment you type, the result and the balance band. If you tap the link to your lender's terms, that you tapped it and for which card.
  • With your consent: page usage data and a recording of your visit (PostHog), and Meta's advertising pixel. In recordings, what you type into forms is hidden. If you do not accept, they do not load. Details in the cookie policy.
  • Server logs: your IP and the page address. If you open a shared calculator link, that address carries the balance and monthly payment in it.

3. What we use it for, and on what legal basis

PurposeLegal basis
Create and keep your account, work out your round-ups, show you estimates of interest and of the date your debt ends, propose sends and tell you about themPerformance of the contract you accept by using the app (Art. 6(1)(b) GDPR)
Read your accounts through TinkPerformance of the contract (Art. 6(1)(b) GDPR). On top of that, payment services law requires your explicit consent to access your accounts (Art. 94(2) of Directive (EU) 2015/2366 and Spanish Royal Decree-law 19/2018). You give it in the app and on Tink's page. If you withdraw it, we stop reading your accounts
Process data about other people who appear in your transactionsLegitimate interest in providing the service you ask for (Art. 6(1)(f) GDPR). We use it only for that
Ask Tink to initiate each send you confirmPerformance of the contract (Art. 6(1)(b) GDPR)
Keep the anonymous user before you create an accountSteps you ask for before entering a contract (Art. 6(1)(b) GDPR)
Manage the trial and the subscriptionPerformance of the contract (Art. 6(1)(b) GDPR)
Protect the service, prevent abuse and fix errorsLegitimate interest in a service that is safe and works (Art. 6(1)(f) GDPR)
Measure use of the app with the pseudonymous steps in section 2.1Legitimate interest in knowing which parts of the app work (Art. 6(1)(f) GDPR). You can object by writing to us
Answer your messages and your rights requestsPerformance of the contract and legal obligations (Art. 6(1)(b) and 6(1)(c) GDPR)
Meet legal obligations, for example tax or requests from authoritiesLegal obligation (Art. 6(1)(c) GDPR)
Website: old waiting list, optional questions and contact phone (no longer collected)Your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time
Website: analytics, visit recording and Meta pixelYour consent (Art. 6(1)(a) GDPR and Art. 22(2) of Spanish Law 34/2002, LSSI)

What we do not do:

  • We do not sell your data.
  • We do not use your bank data to grant credit or to assess your creditworthiness.
  • We do not use your bank data for advertising or share it with advertisers.
  • We do not classify your transactions to infer your health, religion, trade union membership or other specially protected data. If we ever add transaction classification, we will design it to ignore those categories and say so here first.

4. Who else processes your data

We work with these companies. Those marked "processor" process data only on our instructions and under a contract that requires it.

CompanyWhat it doesRoleWhere
Tink ABConnects to your bank, passes us your account and transaction data, and initiates each payment you confirm. An authorised payment institution in Sweden (company number 556898-2192), supervised by the Swedish financial authority. You accept its terms on its page and its own privacy notice applies: https://tink.com/privacy-policiesController for what it does with you under its terms [exact role towards Orwanna to be confirmed]Sweden (EU)
Enable Banking OyAlternative for reading accounts. Switched off today. If we ever offer it to you, we will tell you before you connectController for what it does with you under its terms [to be confirmed]Finland (EU)
Railway CorporationHosts our servers and the databaseProcessorServers in the EU (Amsterdam). US company
AppleSign in with Apple, iPhone notifications, subscription billing in the App StoreController for its own services; processor for notifications [to be confirmed]Ireland and US
GoogleGoogle sign-in, Android notifications (Firebase Cloud Messaging), subscription billing in Google PlayController for its own services; processor for notifications [to be confirmed]Ireland and US
PostHog Inc.App analytics (pseudonymous steps) and website analyticsProcessorServers in the EU (Frankfurt). US company
Functional Software Inc. (Sentry)Error reportsProcessor[Servers in the EU (Frankfurt): confirm the region chosen]. US company
ResendWould send the sign-in link by email. Not active todayProcessorUS
Vercel Inc.Hosts the websiteProcessor[Region to be confirmed]. US company
Meta Platforms Ireland Ltd.Advertising pixel on the website, only if you accept it[Joint controller for collection on the website, to be confirmed]Ireland and US
Google (Google Workspace)Our email and working documentsProcessor[To be confirmed]

Authorities and courts may also receive data when the law requires it, and so may our advisers (accountants, lawyers), who are bound by confidentiality.

5. Transfers outside the European Economic Area

Our database is in the EU. Some of the companies in section 4 are based in the United States or may access data from there. In those cases we rely on one of two safeguards:

  • The European Commission's adequacy decision on the EU-US Data Privacy Framework of 10 July 2023, when the company has signed up to it.
  • The standard contractual clauses approved by the European Commission (Decision 2021/914), when it has not.

You can ask us for a copy of these safeguards at [CONTACTO DE PRIVACIDAD].

6. How long we keep your data

DataHow long
Your account and everything the app holds (accounts, transactions, debts, sends, device)While you have the account. When you delete it, it is removed from the database at that moment
Database backupsUp to [6] days after deletion, the time our provider keeps each daily backup [confirm in the Railway dashboard]
Anonymous user who does not sign in or start the trial72 hours, with its bank data
The bank's full response for each transaction90 days. The data the calculations need (date, amount, description) stays while you have the account
IBANs inside Tink's response about a paymentStruck out 90 days after the send ends
Permission to access your bank90 days with Tink. After that you need to renew it
One-time sign-in codesDeleted when they expire
Ended sessions30 days after they end
Attempts to connect the bank90 days
Security event log13 months. When you delete your account, we remove any reference to you from it
Server logs[Depends on the Railway plan: confirm]
Error reports[90 days: confirm in Sentry]
App usage steps[Confirm PostHog's period]
Website: old waiting list and optional answersUntil we open your access and at most 12 months after the public launch, or until you unsubscribe
Website: analytics and recordings[Confirm PostHog's period]

If a law requires us to keep something longer, we keep it blocked and only for that purpose.

Tink, Apple and Google keep their own data under their own policies. When you delete your account, we ask Tink to delete the user it created for you and the permission to access your bank.

7. Your rights

You can ask us for:

  • Access: to know what data we hold about you and get a copy.
  • Rectification: to correct what is wrong.
  • Erasure: to delete it. You can do this yourself in Settings, "Delete account".
  • Restriction: to stop using it while a complaint is resolved.
  • Portability: to receive the data you gave us in a machine-readable format.
  • Objection: to stop using it where the basis is our legitimate interest, for example usage measurement.
  • Withdrawal of consent at any time. On the website, from "Cookie settings" at the foot of every page. For your bank data, by deleting the account or withdrawing the permission at your bank.

Write to [CONTACTO DE PRIVACIDAD] from your account's email, or tell us how to identify you. It is free. We answer within one month at most; if the request is complex, we can extend that by two more months and will tell you within the first month.

For what Tink does with your data under its terms, you can also contact Tink. For subscription billing, contact Apple or Google.

8. Complaints to the authority

If you think we are not handling your data properly, you can complain to the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid, www.aepd.es, or at its online office, sedeagpd.gob.es. We ask you to write to us first in case we can sort it out, but you do not have to.

9. Automated decisions

We do not take automated decisions that have legal effects on you or affect you in a similar way. The app works out automatically how much to propose for each send, but a send only goes if you confirm it in the app and at your bank. We do not assess your creditworthiness and we do not profile you for advertising in the app.

10. Minors

The app is for people aged 18 or over. The website is not meant for children under 14. If we learn that a minor has given us data, we delete it.

11. How we protect your data

  • All connections between the app, the website and our servers are encrypted.
  • We do not store your bank login details, Tink access tokens or passwords.
  • We strike out the full IBAN of your accounts before storing it, and the app shows only the last four digits.
  • Sign-in codes and sessions are stored as a fingerprint (hash), not in readable form.
  • Only the people at [RAZÓN SOCIAL] who need it can access the database, each with their own account.

12. Changes to this policy

If we change something important, we will tell you in the app and, if we have your email, by email, before the change applies. The date of the current version is at the top.