Breadly

Breadly – Privacy Policy

Last updated: October 31, 2026
Controller: Nazar Palamarchuk
Contact: ua.nazar.palamarchuk.ua@gmail.com
1.

Who we are

Controller/Developer: Nazar Palamarchuk, independent software developer located in Ukraine. Application: Breadly Contact: ua.nazar.palamarchuk.ua@gmail.com
For liability limits, warranty disclaimers, and service availability terms, please review our Terms of Service.
2.

What this policy covers

This policy covers the Breadly mobile applications (iOS and Android) and related cloud services, including authentication, subscriptions, optional cloud synchronization, and optional import tools.
We do not sell your personal or financial data.
Breadly does not currently use any third-party tracking, advertising identifiers, or cross-app tracking technologies. If tracking is introduced in a future release (for example for advertising), we will request your consent before any tracking occurs, including through Apple's App Tracking Transparency (ATT) prompt on iOS or equivalent mechanisms on other platforms.
Some features described in this policy are planned for future releases (such as transaction attachments, AI-powered tools and advertising). Those features are clearly labeled and are not active unless and until they are shipped and enabled.
Before any planned feature becomes active, we will update this Privacy Policy and, where required, our App Store/Play Store privacy disclosures and in-app consent flows.
3.

Information we process

A. Local-Only Mode (no sign-in, no sync)

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On-device data may include accounts, categories, budgets, activities, and transactions.
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Data is stored locally on your device using SQLite and is not transmitted to our servers unless cloud sync is enabled.
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We do not collect advertising identifiers. Crash reports are collected in every mode, including local-only mode, as are pseudonymous performance metrics that record app launches and the screens you open but not what you enter — see Diagnostics & Error Monitoring and Performance Metrics below.
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Local-only data can be permanently lost due to sign-out, uninstall, device loss/theft, factory reset, clearing app data, storage corruption, app/OS failures, or user error.
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We cannot recover local-only data under any circumstances. You are solely responsible for backups and verification of local records.

B. Account & Authentication

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Authentication is provided via Clerk. You can sign in with Apple or with Google, on both iOS and Android.
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When you sign in with Google, we receive your name, email address, and authentication identifiers from Google. We do not receive your Google password.
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When you sign in with Apple, we receive an authentication identifier and the email address Apple shares with us — your own, or a private relay address if you choose to hide yours — and your name if you choose to share it. We do not receive your Apple Account password.
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Minimal account metadata is stored to operate login and manage your session, including your device's time zone setting, which Clerk records when your account is created and each time you sign in.
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Expense data remains local unless sync is enabled.

C. Subscriptions

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Subscription purchases are processed by Apple App Store or Google Play and validated via RevenueCat.
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We do not store full payment card details.
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Purchase metadata (product ID, entitlement status, transaction ID) may be processed to validate access.

D. Cloud Sync (Paid Feature)

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If enabled, synced data (for example accounts, categories, budgets, activities, and transactions) is transmitted to cloud infrastructure via PowerSync (sync engine) and stored in a PostgreSQL database hosted by PlanetScale (United States).
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Synced data may be accessed and managed from Ukraine for operational purposes such as support and debugging.
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Synced data is used solely to provide synchronization and backup across your devices.

E. Multi-Currency & Exchange Rates

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The app stores your default currency preference and per-account currency selections.
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Exchange rate data is fetched from third-party currency data providers and stored server-side to support multi-currency conversions and display.
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Exchange rates are provided for informational and convenience purposes only. Rates may be delayed, incomplete, or inaccurate and should not be relied upon for financial decisions.
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Currency preference data follows the same storage model as other app data: local-only unless cloud sync is enabled.

F. Diagnostics & Error Monitoring

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We use Sentry for crash reporting and diagnostics.
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When you are signed in, Sentry error reports are linked to your account identifier, email address, and name.
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If your session expires, Sentry error reports stay linked to your account identifier until you sign in again or erase the data on this device, including while you keep using the app on this device. Until the app next restarts, they may also stay linked to your email address and name.
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Sentry reports, and the short app-session records Sentry uses to measure how often the app crashes, also carry random identifiers for your app installation and app session. These are not linked to your account, name, or email unless you are signed in or your session has expired as described above.
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Sentry may record your IP address, and the approximate location it derives from it, with error reports and app-session records in every mode, whether or not you are signed in.
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Unhandled application errors, and errors that make the app show its error screen, are also recorded by Expo's EAS Observe service: the error type, message, and stack trace.
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If the app crashes in its native code, a crash report is also sent to EAS Observe on a later launch: the exception or signal type, the error message or the operating system's termination reason, and, where available, up to 50 frames of the native stack trace, normally the crashing thread's. On iOS the report comes from Apple's MetricKit and also carries the technical details needed to read that stack trace: the names and build identifiers of the app and system code it passes through, the number of threads, and, for a crash caused by an invalid memory access, a description of the memory region involved. On Android it comes from the app's own crash handler and the system's record of why the app exited.
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These EAS Observe reports are associated with the same random installation and app-session identifiers as the performance metrics below, not with your account, name, or email. Because they share the session identifier, an error can be placed in the sequence of screens opened in the session where it occurred.
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Sentry reports include device and app information (such as device model, OS version, memory, storage and battery state, network connection type, language and time zone settings, app version, and installed update) and a short trail of technical events from before the error: app lifecycle and system events (for example the app moving to the background, the keyboard opening, low memory, or a change in network connectivity); on iOS, the title of each screen shown and the kind of control tapped (with the fixed caption of a native button, such as "Save"); the web address without query parameters, method and status code of the app's network requests; diagnostic log messages written by the app and the libraries it uses; and app update checks.
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Used only for troubleshooting and improving stability.
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Crash reports do not include what you type or your financial data: no transactions, account or category names, amounts, or balances.

G. Performance Metrics

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We use Expo's EAS Observe service to collect pseudonymous app performance metrics, such as app launch time, time to first render, time to interactive, and screen navigation timings.
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Alongside these timings, technical metadata is collected: device model, OS version, app version, update and runtime version, network connection type and whether it is metered or limited by Low Data Mode (iOS) or Data Saver (Android), device thermal state, battery level and charging state, low-power mode, slow and frozen frame counts and total frame-freeze time, how long each stage of app startup took and whether the launch screen reached its time limit, a summary of the network requests the app makes while it starts up (how many there were and how many failed, bytes sent and received, total time and overall download speed, plus the hostname, response status code, duration, time until the first byte of the response arrived and bytes received of the slowest one), and your device's language/region setting.
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Screens are identified by their route pattern (for example "/transactions/[id]") — never by the specific record you opened.
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Navigation metrics also carry the non-identifying options a screen was opened with — for example whether the categories view was showing income or expenses, or which kind of account was being created. Parameters that name a specific record are removed before the metric leaves your device, and the resolved screen address is dropped along with them.
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Because each navigation metric names the screen and the app session it belongs to, these metrics also record how the app is used: which screens were opened, in what order, and when. This is the product interaction data listed in our App Store and Google Play privacy disclosures.
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Metrics are associated with a random identifier the app creates for its installation and a random identifier for each app session; neither is linked to your account, name, or email. The installation identifier is the device identifier listed in our App Store and Google Play privacy disclosures. It is not an advertising identifier and is not used to track you across other companies' apps or websites.
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No personal or financial data, and no screen contents, are included in performance metrics.
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Used to measure and improve app startup, navigation performance, and stability, and to understand in aggregate how the app's screens are used (for example, how often a screen is opened). Not used for advertising or to build a profile of you.

H. CSV Import (Optional Tool)

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If you use CSV import, selected CSV files are processed to create categories or transactions.
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Imported data follows the same storage model as manually entered data: local-only unless cloud sync is enabled.
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You are responsible for reviewing imported data accuracy before relying on it.

I. App Updates

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The app may receive over-the-air (OTA) updates that do not require a separate app store download.
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Update checks and downloads transmit technical metadata such as platform, runtime version, release channel, and the identifiers of installed updates, together with the same random installation identifier used for performance metrics, to Expo's EAS Update service.
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To tell you when a new store version is available, the app asks the App Store (iOS) or Google Play (Android) for the latest version of Breadly. On iOS this sends only the app's App Store identifier to Apple's public lookup service, which, like any server, receives your device's IP address.
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Updates may modify app functionality, fix bugs, or change features. Continued use of the app after an update constitutes acceptance of any changes.

J. Early Access / Beta Features

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Certain features may be labeled "Early Access" or "Beta" and made available to a limited group of users.
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Data generated or processed by early access features follows the same storage model as other app data (local-only unless cloud sync is enabled).
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Early access features may change, be removed, or behave unpredictably. Data created during early access may be affected if a feature is modified or removed.

K. Planned Attachments (Not Active Yet)

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Transaction attachments (receipt images and voice memos) are a planned feature. The current app does not record audio, take photos, or attach files to transactions, and it requests no camera or microphone permission.
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If and when attachments are launched, they will be stored locally by default and follow the same sync behavior as other data when cloud sync is enabled, and they will not be transcribed or processed by AI unless you explicitly use a planned AI feature (see Planned AI Features below).
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You will be able to use Breadly without recording or attaching anything. This Privacy Policy will be updated before attachments are launched.

L. Planned AI Features (Not Active Yet)

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Planned features include AI-powered receipt scanning via photo, voice-to-text input for transaction entry, AI-assisted categorization, budgeting suggestions, and spending insight tools.
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These features are currently inactive and no AI provider processing occurs unless and until such features are launched and enabled by you.
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If and when enabled, relevant content (such as receipt images or audio recordings) may be processed by third-party AI providers, potentially in the United States or other jurisdictions.
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AI processing may occur on-device, in the cloud, or a combination of both, depending on the feature and implementation.
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AI features will be optional. You will be able to use Breadly without enabling them.
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AI outputs may be inaccurate and must be reviewed by you before use.
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Before activation, we will update this Privacy Policy and required store privacy disclosures to reflect the live data flows.

M. Planned Advertising (Not Active Yet)

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Advertising is currently not active.
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If advertising is enabled in a future release (for example for non-subscribers), third-party advertising providers may collect device identifiers, advertising ID, IP address, and limited usage data.
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Where required (such as EU/EEA), consent will be requested before enabling personalized ads.
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On iOS, any tracking activities will require ATT permission before tracking occurs.
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Before activation, we will update this Privacy Policy and required store privacy disclosures to reflect the live advertising data flows.
4.

Why we process information

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Provide core app functionality (accounts, categories, budgets, activities, and transactions).
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Support multi-currency tracking and exchange rate conversions.
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Authenticate users and manage sessions.
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Validate subscriptions and entitlements.
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Provide cloud synchronization across devices (if enabled).
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Support optional import tools.
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Deliver over-the-air app updates.
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Monitor and fix technical issues via crash reporting.
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Measure app startup and navigation performance, and understand in aggregate how the app's screens are used, through pseudonymous performance metrics.
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Comply with legal obligations.
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Support future optional features (such as AI tools or advertising) only if implemented and enabled.
6.

Sharing & processors

We do not sell your personal or financial data.
Third-party processors include:
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Clerk (authentication) — United States
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Apple and Google (sign-in providers) — United States
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RevenueCat (subscription validation) — United States
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Apple App Store & Google Play (billing) — United States
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PowerSync (cloud sync engine) — United States
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PlanetScale (cloud database hosting) — United States
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Sentry (error monitoring) — European Union (Germany)
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Expo (over-the-air updates, EAS Observe performance and usage metrics, and error and crash logs) — United States
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Third-party currency data providers (exchange rates) — various jurisdictions
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AI providers, if and when AI features are implemented and enabled — United States or other jurisdictions
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Advertising providers, if and when advertising is implemented and enabled — various jurisdictions
All processors act under contractual data protection obligations where applicable. We only share the minimum data necessary for each processor to perform its function.
7.

International transfers

Data may be processed in the United States and, for crash and error diagnostics, in the European Union (Germany). Data may be accessed from Ukraine for operational purposes. For EU/EEA users, transfers rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) where required by applicable law. By using the cloud sync feature, you acknowledge that your synced data will be transferred to and processed in the United States.
8.

Data retention

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Local-only data remains on your device and is under your control.
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Synced data is retained while your account is active. Upon account deletion or a valid data deletion request, synced data will be deleted within 30 days, except where retention is required by law.
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Crash logs are retained only as long as necessary for diagnostics (typically no more than 90 days).
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Performance metrics are retained only as long as necessary to analyze app performance and usage and to improve the app.
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Legal and accounting records are retained as required by applicable law.
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Subscription validation data is retained as long as necessary to verify entitlements.
9.

Your rights

A. General rights

Depending on your jurisdiction, you may have the right to:
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Access the personal data we hold about you.
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Correct inaccurate personal data.
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Request deletion of your personal data.
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Restrict or object to processing.
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Data portability (receive your data in a structured format).
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Withdraw consent at any time.
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Lodge a complaint with your local data protection supervisory authority.
To exercise any of these rights, contact ua.nazar.palamarchuk.ua@gmail.com.

B. California residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
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Right to know what personal information is collected, used, and disclosed.
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Right to request deletion of your personal information.
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Right to opt out of the sale of personal information (we do not sell personal information).
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Right to non-discrimination for exercising your privacy rights.
To submit a verifiable consumer request, contact ua.nazar.palamarchuk.ua@gmail.com.

C. Other U.S. state residents

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with consumer privacy laws may have similar rights, including:
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Right to access, correct, and delete personal data.
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Right to opt out of the sale of personal data (we do not sell personal data).
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Right to opt out of targeted advertising (we do not currently engage in targeted advertising).
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Right to appeal a denial of a privacy request.
To exercise any of these rights, contact ua.nazar.palamarchuk.ua@gmail.com. We will respond within the timeframe required by applicable state law.
10.

Data deletion

You may delete your account and its data at any time by:
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Using the in-app option (Settings > Danger Zone > Delete My Account), which immediately and permanently deletes your authentication account, all synced data associated with it, and the copy stored on your device, or
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Sending an email to ua.nazar.palamarchuk.ua@gmail.com with the subject line "Data Deletion Request."
In-app deletion is immediate and cannot be undone — there is no grace period and no recovery. Upon receiving an emailed request instead, we will:
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Delete synced data associated with your account within 30 days.
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Instruct third-party processors to delete your data where technically feasible and where we control the processing relationship.
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Retain only data required by law (for example tax/accounting records) for the legally mandated period.
If you use Breadly without an account, your data is local-only and never reaches our servers. Settings > Danger Zone > Start Over erases it from your device; uninstalling the app does the same.
Deleting your account does not cancel an active subscription. Subscriptions are managed by the App Store or Google Play and must be cancelled there.
11.

Security

We use a limited security model and disclose it transparently:
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Encryption in transit (HTTPS/TLS) is used for data transmitted to and from our servers.
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Synced server-side data is not protected by additional application-level encryption at rest by us.
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Synced data may be stored in readable form within our database environment for authorized access.
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Nazar Palamarchuk may access synced data for legitimate operational purposes such as support, troubleshooting, abuse prevention, and service maintenance.
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Access protection relies primarily on standard hosting/database access controls and authentication controls.
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No additional custom security measures are currently in place beyond those standard controls.
No system is 100% secure. We cannot guarantee absolute security of your data, and you use the service at your own risk. We encourage you to use strong device passwords, enable device-level protections, and keep your operating system up to date.
12.

Data breach notification

In the event that we become aware of a security breach affecting synced personal data, we will:
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Notify affected users without undue delay via email (if available) and/or in-app notice.
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Where required by applicable law (for example under the GDPR), notify the relevant supervisory authority within 72 hours of becoming aware of the breach.
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Provide information about the nature of the breach, the data affected, and steps being taken to address it.
As Breadly is operated by a single independent developer, breach response is provided on a best-effort basis. We will make reasonable efforts to identify affected users, but as a solo-operated service, response timelines may be longer than those of larger organizations. We encourage you to monitor your account activity and contact ua.nazar.palamarchuk.ua@gmail.com if you suspect unauthorized access.
13.

Automated decision-making

Breadly does not currently use automated decision-making or profiling that produces legal effects or similarly significant effects on you.
If AI features are enabled in the future, they will be advisory only and will not make automated decisions on your behalf. You will always retain full control over your financial data and any actions taken within the app.
14.

Do Not Track

Breadly does not currently respond to "Do Not Track" (DNT) browser signals or similar mechanisms.
Breadly does not track users across third-party websites or services. As described in this policy, we do not currently use any third-party tracking, advertising identifiers, or cross-app tracking technologies.
15.

Children

Breadly is not directed to children under the age of 16 (or under 13 where required by the U.S. Children's Online Privacy Protection Act). We do not knowingly collect personal data from children under these ages. If we become aware that we have inadvertently collected data from a child under 16 (or under 13 where COPPA applies), we will take steps to delete such data promptly. If you believe a child has provided us with personal data, please contact ua.nazar.palamarchuk.ua@gmail.com.
16.

Changes to this policy

We may update this Privacy Policy from time to time. For material changes, we will provide notice through:
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An in-app notification, or
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An update to the "Last updated" date at the top of this policy.
Material changes will take effect 14 days after notice is provided. Continued use of Breadly after the effective date constitutes acceptance of the updated policy. If you do not agree to the changes, you should stop using the app and request deletion of your data.
17.

Governing law

This Privacy Policy is governed by and construed in accordance with the laws of Ukraine, consistent with the governing law provisions of our Terms of Service.
This does not deprive you of the protection afforded by mandatory data protection laws in your country of residence (including the GDPR for EU/EEA users).
18.

Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:
Nazar Palamarchuk Independent software developer, Ukraine Email: ua.nazar.palamarchuk.ua@gmail.com
We will make reasonable efforts to respond to your inquiry within 30 days.
© 2026 Nazar Palamarchuk
This page is accessible as a public web URL for Google Play.