Privacy Policy

Last updated: 1st of February 2026

This Privacy Policy explains how Aivinn AB ("Aivinn", "we", "us", or "our") processes personal data when you use the Aivinn mobile application and related services (the "App" or the "Service"). This Privacy Policy forms an integral part of the Aivinn Terms and Conditions.

1. Who We Are

The data controller for the purposes of the General Data Protection Regulation (GDPR) is:

Aivinn AB Sweden
Sweden

For privacy-related questions or to exercise your rights, you can contact us at: info@aivinn.eu.

Aivinn has not appointed a Data Protection Officer (DPO), as we are not legally required to do so under Article 37 GDPR.

2. Who This Policy Applies To

This Privacy Policy applies to users of the Aivinn App who are 16 years of age or older and located in the European Economic Area (EEA). The Service is not designed or marketed for children under 16.

3. Personal Data We Process

We process the following categories of personal data:

3.1 Account Data

  • Email address
  • Encrypted or hashed authentication credentials
  • Country and language settings

3.2 Financial Input Data

  • Financial information you voluntarily enter into the App
  • Transactions, amounts, dates, and categories
  • Notes or labels added by you

3.3 Derived and Inferred Data

  • Financial wellness score
  • Behavioural patterns and trends
  • Insights generated from your usage of the Service

This data is derived automatically and does not represent creditworthiness or regulated financial assessments.

3.4 Technical and Usage Data

  • Device type and operating system
  • App version
  • Usage events and interaction data
  • IP address (processed transiently for security and technical purposes)

4. How We Use Your Data

We process personal data for the following purposes:

  • To provide and operate the Service
  • To generate insights, summaries, and financial wellness indicators
  • To personalise your experience within the App
  • To ensure security, stability, and fraud prevention
  • To analyse and improve the functionality and performance of the App
  • To communicate with you regarding your account, subscriptions, and updates

5. Legal Bases for Processing

We rely on the following legal bases under GDPR:

5.1 Performance of a Contract (Article 6(1)(b))

To provide the Service you request, including account management, insights, and subscriptions.

5.2 Legitimate Interests (Article 6(1)(f))

For:

  • App analytics and performance measurement
  • Security and abuse prevention
  • Improving AI models using anonymised or aggregated data

These interests are balanced against your rights and freedoms.

5.3 Consent (Article 6(1)(a))

Where required by law, such as for:

  • Push notifications
  • Certain communications or optional features

You may withdraw consent at any time through device or account settings.

6. Analytics and Tracking Technologies

The App uses analytics tools, which may include mainstream mobile analytics services, to understand how users interact with the Service and to improve performance and usability. These tools may process:

  • Usage events
  • Device and app-related information

We do not use analytics data to identify you personally or to track you across unrelated services.

7. Artificial Intelligence and Model Improvement

Aivinn uses automated systems, including AI, to generate insights and financial wellness indicators.

  • Personal data is used to provide insights to you only
  • Anonymised and aggregated data may be used to improve models and system performance
  • Personal data is excluded from model training where identification would be possible
  • AI outputs are informational only and do not constitute professional advice.

8. Data Sharing and Processors

We do not sell your personal data and do not share it with third parties for their own purposes.

We may use carefully selected service providers (processors) to support:

  • Hosting and infrastructure
  • Analytics
  • Security and monitoring

These providers process data solely on our instructions and are bound by contractual and legal confidentiality obligations.

9. International Data Transfers

All personal data is stored and processed exclusively within the EU/EEA.

We do not transfer personal data outside the EEA at launch.

10. Data Retention

We retain personal data only for as long as necessary to provide the Service.

  • When you delete your account, your personal data is deleted immediately
  • Anonymised or aggregated data that can no longer be linked to you may be retained for analytics and improvement purposes

11. Your Rights Under GDPR

You have the right to:

  • Access your personal data
  • Correct inaccurate or incomplete data
  • Request deletion of your data
  • Object to or restrict certain processing
  • Request data portability
  • Withdraw consent at any time

To exercise these rights, contact us at info@aivinn.eu.

12. Communications

12.1 Emails

We may send:

  • Transactional emails (account, billing, security)
  • Product updates and service-related communications

You may opt out of non-essential communications at any time.

12.2 Push Notifications

The App may send push notifications related to:

  • Insights and nudges
  • Account activity
  • Service updates

You can manage push notification preferences through your device settings.

13. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse.

No system is completely secure, and we cannot guarantee absolute security.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If changes materially affect how we process personal data, we will inform you in advance where required by law. Continued use of the App after updates constitutes acceptance.

15. Contact

If you have questions about this Privacy Policy or how we handle personal data, contact: