Privacy Policy for Revius

Want to delete your Revius account and data? See section 5. Account and Data Deletion for instructions on how to request deletion of your Revius account and all associated data, both inside the app and without reinstalling it.

Welcome to the Revius Privacy Policy!

We value every user and reliably protect the information you entrust to us in our mobile application. In this section, you can learn about how we collect, process, store, and use your personal data, as well as your rights regarding such data.

The following definitions are used in this document:

• Privacy Policy — the document you are currently reading;
• Revius Application (also "application" or "app") — a mobile application, a personal finance management service, available for download via the App Store and Google Play;
• Sunrise LLC, a limited liability company incorporated under the laws of the Republic of Armenia, TIN 08325795, state registration number 999.110.1588694 (hereinafter referred to as the "Company"), registered address: 22A N. Zaryan St., Arabkir, Yerevan 0051, Republic of Armenia;
• Contact email address: support@revius.pro
• User Account (also "account") — a personal account created by the user in the application to use the functionality of the Revius application;
• Personal Data (also "personal information") — any information relating to a directly or indirectly identified or identifiable individual (personal data subject);
• Personal Data Operator — a government body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data;
• Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

The current version is available at: revius.pro/privacy

1. Scope of the Privacy Policy

This Privacy Policy applies to information we collect during your use of the Revius application, the website https://revius.pro, as well as during the performance by the Company of any agreements and contracts entered into with users.

This Privacy Policy applies to the processing of personal data of users who are citizens of countries other than the Russian Federation or CIS countries. Use of the Revius application constitutes the user's unconditional consent to the current Privacy Policy and the specified conditions for processing personal data. If you disagree with these terms, you should refrain from using the Revius application.

2. What Information We Collect

The categories of personal data we process depend on how the user interacts with the application.

In some cases, the user may provide certain personal information or refrain from providing it; however, access to certain features of the application may also depend on the user providing certain data and the extent of such provision.

During the use of the application, we may process the following data, among others:

Information provided by the user voluntarily

In order to create your account and provide access to the application, we may need the following personal data, among others:

• Full name / username;
• Email address;
• Country of residence;
• Income level;
• Information about financial goals and spending habits;
• Records of the expenses you enter in the application, including the amount, the currency, the category, the date, and any description you add;
• The text of an expense you dictate using voice input, if you choose to record an expense by speaking instead of typing (see "Voice input" below);
• Photographs you select from your device — for example a receipt or a screenshot — if you use the receipt scanning feature (see "Receipt photographs" below);
• Information about subscriptions to third-party services.

The Company does not verify the accuracy of personal data provided by the user and is unable to assess the legal capacity of users. However, the Company assumes that the user provides accurate and sufficient information and keeps this information up to date. The consequences of providing inaccurate or insufficient information are defined in the Terms of Use.

Voice input

The Revius application allows you to record an expense by speaking instead of typing. Voice input is optional: every function of the application that accepts voice input also accepts manual input, and you can use the application without ever recording your voice.

If you choose to use voice input, speech is recognised by the speech recognition service built into your device's operating system. Depending on your device, its settings and the language you speak, this service may perform recognition locally on the device or send the audio to the servers of the operating system vendor (Apple for iOS, Google for Android) for processing. This processing is governed by the privacy policy of the respective vendor.

The audio recording itself is never transmitted to us and is not stored by us at any point. We receive only the recognised text, which is sent to our server and then to OpenAI, which interprets it as an expense and returns a structured record saved to your account. Data submitted to OpenAI through its application programming interface is not used to train its models.

Receipt photographs

The Revius application allows you to add an expense by selecting a photograph — for example a receipt or a screenshot — from your device. This feature is optional: every expense can also be entered manually, and you can use the application without ever selecting a photograph.

The photograph is chosen through the photo picker built into your device's operating system. The application does not request access to your photo library as a whole and does not request access to your camera; taking a new photograph from within the application is not supported. We receive only the single image you select, at the moment you select it, and the application never reads your photo library in the background.

The image you select is transmitted through our server to OpenAI, which reads the expense details from it and returns a structured record — the name of the shop or service as it appears in the image, the amount, the currency, the date, a suggested category and whether the payment appears to be a recurring one. That record is saved to your account. Data submitted to OpenAI through its application programming interface is not used to train its models.

The image itself is processed in memory only. It is never written to disk, never recorded in our database or logs, and is not stored on our servers at any point; it becomes inaccessible as soon as the request has been processed. We retain only the structured expense record, which you can view and delete in the application like any other expense.

Information collected automatically during the use of the application

Personal information collected during the use of the application may include the following data:

• Device information, which may include the hardware model, operating system and version, and other device identifiers;
• Server log data, which may include your registration data, dates and times of your requests, your IP address, and time spent in the Revius application;
• Subscription status and transaction identifiers received from the app store you used to purchase a subscription;
• Analytics data collected through Google Analytics for Firebase, which may include a pseudonymous application instance identifier, device model and brand, operating system and version, screen resolution, application version, device language, an approximate region derived from your IP address, and records of your interactions with the application, such as opening the application, viewing screens, creating an account, signing in, viewing the subscription screen, starting a free trial, and completing a purchase.

The Revius application does not use push notifications delivered from our servers. Reminders you enable in the application are scheduled and displayed locally on your device, and no notification tokens are created or transmitted. The application instance identifier described above is used solely for analytics; it is pseudonymous, can be reset by reinstalling the application, and cannot be used to deliver notifications to your device.

The Revius application does not collect the precise geolocation of your device and does not request access to location services. Where the application needs to know your country, it uses the country you select yourself during onboarding. Our analytics provider derives an approximate region, no more precise than country or city level, from the IP address of your connection; this approximate region is not linked to your account or to your financial data.

The application does not collect advertising identifiers, does not display advertising, and does not use analytics data for advertising or for tracking you across other companies’ applications and websites.

Cookies and tracking technologies on the website

Cookies are small data files stored on your device when you visit the website https://revius.pro. They allow us to collect information about your device identifiers, IP address, the web browser used to access the website, pages viewed, time spent on pages, and links you follow. Web beacons are graphic images placed on a website or in an email that are used to monitor the behavior of a user visiting a website or opening an email; they are often used in conjunction with cookies.

Cookies and web beacons are used on our website only. The Revius mobile application does not use cookies or web beacons.

Personal information collected by the Company from other sources

Within the framework of applicable law, we may also receive from third parties information about suspected or confirmed cases of violation by individual users of the Terms of Use, Privacy Policy, or applicable legislation to ensure the safety of our users.

If you use links to visit other websites or services posted in chats or in our application, this policy will not apply to your use and activity on such websites. You should review the privacy policies of other websites, as we do not control them and are not responsible for any information provided or collected by these third parties.

Personal data specified in this policy is collected only with the voluntary consent of the user and is processed exclusively for the purposes clearly defined in this policy.

3. Purposes of Processing and Using Users' Personal Data

The main purpose of collecting user information is to provide the ability to use the Revius application and improve its quality.

Within the scope of the above purpose, we may process personal data ourselves and through third parties, including to:

• Provide access to the application in accordance with the Terms of Use;
• Improve the operation of the application, enhance existing functionality, and add new features;
• Develop new applications independently and by legal entities within the same group;
• Provide personalized recommendations in the application;
• Conduct scientific research and development to improve the functionality of the application;
• Conduct statistical and other research based on aggregated data sets;
• Fulfill user requests and provide technical support to the user;
• Communicate with the user, including sending notifications, requests, and information related to the use of the application, and performing agreements and contracts;
• Identify and prevent violations of the Terms of Use and this Policy, for example, by reviewing user complaints, studying and developing countermeasures against violations, and analyzing and accumulating information about incidents of violations;
• Create personalized recommendations and provide them to the user;
• Properly fulfill obligations imposed on the Company in accordance with applicable law.

4. Processing of Users' Personal Information and Its Transfer to Third Parties

In some cases, for the purpose of developing the Revius application, optimizing its operation, and offering new functionality by us and/or legal entities within the same group, we may transfer some personal data of users to partners, service providers, and/or other third parties.

Service providers we use

We use the following service providers, each of which processes user data solely on our behalf and in accordance with our instructions, for the limited purposes described below. We do not sell user data and we do not transfer it to third parties for their own independent purposes, including advertising.

• OpenAI, L.L.C. — interpretation of expense descriptions, including text produced by voice input, recognition of expense details from images you select for scanning, and generation of the observations and recommendations shown in the application. Text, depersonalized information about your expenses and, where you use receipt scanning, the image you selected are transmitted for this purpose; audio recordings are not. Data submitted through the OpenAI application programming interface is not used to train its models.
• RevenueCat, Inc. — management of subscriptions and verification of purchases made through the app store. An application-generated user identifier and the status and history of your subscription are transmitted for this purpose. Payment card details are never transmitted to us or to RevenueCat.
• Unisender Go — delivery of transactional email messages, specifically one-time login codes. Your email address and the login code are transmitted for this purpose. These messages are not marketing communications, and no promotional emails are sent through this provider.
• Google LLC — product analytics through Google Analytics for Firebase, used to understand how many people install and use the application, which features they use, and how well the application retains them over time. A pseudonymous application instance identifier, technical information about your device and application version, an approximate region derived from your IP address, and records of your interactions with the application are transmitted for this purpose. Your name, email address, expense records, and the content of your financial data are never transmitted to this provider. Advertising identifiers are not collected, and this data is not used for advertising purposes.
• The app store you used to install the application (Google LLC for Google Play, Apple Inc. for the App Store) — processing of payments for a subscription. Payment details are collected by the app store directly from you and are governed by the terms of that store; we never receive or store them.

We also use a hosting provider to operate our servers. The hosting provider stores data on our behalf and does not access its content for its own purposes.

We guarantee that in order to ensure the confidentiality of your personal data and the security of their processing, such transfer will be carried out exclusively in compliance with all requirements of applicable legislation.

We may transfer your personal data to third parties (including partners, service providers, Revius affiliates, etc.) located in other countries, subject to compliance with the necessary requirements of the Law of the Republic of Armenia of 13 June 2015 No. 49-ZR on the Protection of Personal Data.

At the same time, before such transfer, we always obtain confirmation that such countries provide adequate protection of your personal data, and thus your personal data will be protected no less reliably than is ensured in the Republic of Armenia.

In addition to the above conditions, if such processing is carried out in whole or in part in countries that do not provide an adequate level of personal data protection in accordance with applicable legislation, such processing will be carried out exclusively in compliance with all legal requirements and with the necessary legal grounds.

In the event of transfer of your personal data outside of the Republic of Armenia, Revius ensures its legality, including but not limited to the existence of legal grounds for such transfer as provided by law and compliance with other requirements of the Law of the Republic of Armenia of 13 June 2015 No. 49-ZR on the Protection of Personal Data.

We may partially share data with third parties if:

• The user has consented to such actions;
• The transfer is necessary for the user to use the application or to fulfill a specific agreement or contract with the user;
• The transfer is required by the applicable legislation of the Republic of Armenia or other applicable legislation within the framework of legally established procedures;
• For the purpose of protecting the rights and legitimate interests of the Company or third parties, for example, in cases where the user violates the Terms of Use, this Policy, or other assumed obligations.

The Company stores users' personal information in accordance with applicable legislation of the Republic of Armenia, this Policy, and the Company's internal regulations.

The user's personal data is processed by the Company throughout the entire period of the user's use of the application and/or the validity of agreements and contracts with the user, taking into account the requirements of applicable legislation of the Republic of Armenia.

5. Account and Data Deletion

This section explains how to delete your account in the Revius application, published on Google Play and the App Store by Sunrise LLC, and how to request deletion of the data associated with it.

How to request deletion

There are two ways to request deletion of your Revius account and associated data. You do not need to have the application installed to use the second one.

• In the application. Open the application, go to the profile settings and press the "Delete Account" button.
• By email. Send a request to support@revius.pro from the email address associated with your Revius account, stating that you want your account and data deleted. If you signed in using Apple and chose to hide your email address, send the request from the relay address issued to you by Apple, or include in the request any information that allows us to identify your account.

We will delete the account within 10 business days from the date we receive the request. We may contact you at your registered email address to confirm that the request came from the account owner before we proceed.

Before you delete your account: active subscriptions

Deleting your Revius account does not cancel a paid subscription and does not by itself result in a refund. Subscriptions are billed by the app store you purchased them from, and only you can cancel them:

• Google Play — open the Google Play app, go to Payments and subscriptions, select the Revius subscription and cancel it.
• App Store — open Settings on your device, tap your name, go to Subscriptions, select the Revius subscription and cancel it.

Please cancel your subscription before requesting deletion of your account. If you have already deleted your account and are unsure whether your subscription is still active, write to support@revius.pro and we will help you check its status and direct your refund request to the appropriate app store.

What is deleted

When your account is deleted, we permanently delete the following data from our systems:

• Your account and the credentials associated with it, including your email address, name or username;
• The country of residence and income level you provided during onboarding;
• All records of your expenses, including amounts, categories, dates and descriptions;
• All observations, financial health scores, challenges and other content generated for you in the application.

Deletion is irreversible. Once the account is deleted, this data cannot be restored, and you will lose access to the history of your expenses.

We never receive or store audio recordings, and therefore there are no voice recordings to delete when you request deletion of your account. Images you select for receipt scanning are likewise not stored: they are processed in memory only and become inaccessible as soon as the request has been processed, so no images remain to be deleted at the time of your request.

We also instruct the service providers listed in section 4 to delete the data we transferred to them in connection with your account. We cannot compel a third party to perform the deletion, but we do submit such a request in every case.

What is retained and for how long

We retain the following data after the deletion of your account, in the minimum volume necessary:

• Records of payments and subscription transactions — retained for the period required by the accounting and tax legislation applicable to the Company, which is 5 years from the end of the reporting year in which the transaction took place. These records are stored separately and are not used to restore your profile or your expense history.
• Data whose retention is required by law — retained for the period established by the applicable legislation, and transferred to a government authority only in accordance with a legally established procedure.

Modification of your data

You may at any time view, update or delete individual pieces of personal information specified in your account, either by editing them directly in the application or by sending a request to support@revius.pro.

6. Protection of Personal Data

The Company takes necessary and sufficient organizational and technical measures to protect the user's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.

7. Protection of Minors

To use the Revius application, the user must be at least 18 years old. If you suspect that a profile owner is a minor, please report it.

We will take measures to verify the user's age and, if necessary, delete such profile and all information about it, as well as monitor repeated attempts by minors to register in the application.

8. Changes to the Privacy Policy

The Company has the right to make changes to this Privacy Policy.

Revius will inform users of all changes to this Policy by posting information in the application. Continued use of the Application after changes are made to the current Policy will be considered your consent to these changes.

The new version of the Policy takes effect from the moment of its publication, unless otherwise provided by the new version of the Policy.

The current version is permanently available at: revius.pro/privacy

9. Applicable Law

This Policy and the relations between the user and the Company arising in connection with the application of the Privacy Policy shall be governed by the laws of the Republic of Armenia.

10. Feedback

All inquiries and notifications regarding the processing of personal data and/or any related matters may be sent by the user via email to support@revius.pro