Privacy policy

At Commingle, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains what information we collect, why we collect it, how we use it and the choices available to you.

At a glance

You shouldn’t need to be a lawyer to understand our Privacy Policy. Here’s who can access your data in Commingle – you, your friends or Commingle itself.

End-to-end encrypted – your data remains unreadable while transmitted and stored, including to Commingle.

¹Visible only to participants of the split transaction.

²A blockchain-like, end-to-end encrypted ledger of your balances with all friends, accessible to all of them. It contains only current totals, not the transactions behind them.

³Visible only to help your friends find you on Commingle. Customisable in your profile.

Information we collect

Optional: Your name, pronouns and avatar

Providing your name, pronouns and avatar is entirely optional. You can create and use a Commingle account without them, although your name may be imported automatically if you sign in with Apple or Google. You can change or remove any of this information at any time.

You are free to use your real name, a nickname or any other display name you prefer. This information is primarily used to help you and your friends recognise each other when using shared features such as adding friends or splitting expenses. A profile photo makes this even easier, but it is never required.

If we contact you by email, we may also use your chosen name and, where appropriate, your preferred pronouns to personalise our communication.

Your profile information is visible only to people you interact with through Commingle’s shared features.

We retain this information until you delete your account. Following account deletion, it is removed within 30 days unless we are legally required to retain it.

Optional: Contact information

Your contact information, such as your email address or phone number, is collected only if you choose to provide it or use a sign-in method that provides it to Commingle. You can use Commingle without providing contact information when a supported sign-in method allows it.

We may use your contact information to manage and secure your account, communicate important account or subscription information, and notify you about significant changes to Commingle.

Your contact information may also be used to help other Commingle users find you and connect with you, for example to add you as a friend or split expenses. You can control whether you can be found this way in your profile settings.

We do not use your contact information for advertising or sell it to third parties.

We retain this information until you delete your account. Following account deletion, it is removed within 30 days unless we are legally required to retain it for longer.

Everything else: End-to-end encrypted

Virtually everything else you enter in Commingle – including your financial transactions, categories, events, wallets, notes, attachments and chart and summary settings – is end-to-end encrypted before it leaves your device. Commingle cannot access or read this data.

Commingle stores only an encrypted backup of this data, which can be restored only with your encryption key. Financial analysis, including the calculations used to generate charts, summaries and insights, is performed directly on your device.

Split transactions are shared with their participants in end-to-end encrypted form and kept in sync between their accounts. Participants can access and update transactions they are part of, but Commingle cannot read their contents.

Friend balances resulting from split transactions are calculated directly on your device. The resulting balance ledger is also end-to-end encrypted and shared between your friends so that balances can remain in sync without Commingle being able to read them.

Push notifications about changes to split transactions are end-to-end encrypted as well. Their contents cannot be read by Commingle, Apple or Google.

AI-powered features

Commingle offers optional AI-powered features to help you save time when managing your finances. These features are entirely user-initiated or can be disabled at any time.

Examples include:

• scanning receipts
• creating transactions using your voice
• suggesting categories while you enter a transaction

To provide these features, a limited subset of the information you provide–such as transaction descriptions, receipt images, voice recordings or other information necessary to understand your request–may be transmitted to third-party AI service providers for processing.

We only send the information reasonably necessary to fulfil your request. AI processing is used solely to generate the requested result and is not used to make automated decisions about you.

Receipt scanning and voice transactions are processed only after you explicitly initiate them. AI category suggestions can be disabled at any time in the app’s settings.

We currently use Google’s Gemini models for certain AI features and may use other AI providers or models in the future where they provide comparable privacy protections or improve quality, performance or cost. Regardless of the provider used, your data is processed only for the purpose of providing the AI feature you requested.

Usage data

We collect information about how Commingle is used in order to:

• improve the app
• diagnose problems
• measure performance
• develop new features

This may include information about screens viewed, features used and app performance.

Device information

We collect technical information about your device, including:

• device identifiers (where available)
• advertising identifier (IDFA, where available and permitted)
• IP address
• operating system
• app version
• device model

We use this information for:

• fraud prevention
• security
• diagnostics
• improving app reliability
• measuring the effectiveness of our marketing campaigns

We do not use your financial data for advertising purposes.

Cookies, tracking technologies and similar identifiers

Our website and certain parts of Commingle use cookies and similar technologies to:

• remember preferences
• measure website traffic
• understand how users discover Commingle
• evaluate the effectiveness of marketing campaigns

Where required by applicable law, we will request your consent before using non-essential cookies or similar tracking technologies.

Advertising and third-party services

We work with third-party providers, including Google and Meta, for analytics and marketing.

These services may receive pseudonymised or anonymised identifiers to:

• measure advertising performance
• understand how users discover Commingle
• build similar audiences for future marketing campaigns

We never share your financial data with advertising platforms, nor do we access your social media profiles.

For more information, please refer to:

• Google Privacy Policy
• Meta Privacy Policy

How we use your information

We use your information to:

• provide, operate and maintain Commingle
• personalise your experience
• synchronise your data across devices
• provide optional AI-powered features that you explicitly request
• improve existing features and develop new ones
• analyse usage and app performance
• communicate with you about your account
• process subscriptions
• prevent fraud and abuse
• ensure the security of our services
• comply with legal obligations

Legal bases for processing (GDPR)

Where the General Data Protection Regulation (GDPR) applies, we process your personal information under one or more of the following legal bases:

• Performance of a contract – to provide and operate Commingle.
• Legal obligation – where processing is required by applicable law.
• Legitimate interests – including improving Commingle, preventing fraud, ensuring security and maintaining reliable services.
• Consent – where required by law, such as for marketing cookies or similar technologies.

International data transfers

Commingle is operated using infrastructure located in the United States.

If you access Commingle from another country, your information may be transferred to and processed in the United States.

We are committed to complying with applicable data protection laws, including the GDPR where it applies.

Data security

We implement technical, organisational and administrative safeguards designed to protect your information from unauthorised access, disclosure, alteration and destruction.

While we take reasonable steps to protect your information, no method of electronic transmission or storage can be guaranteed to be completely secure.

Data retention

We retain your information for as long as necessary to provide our services and comply with applicable legal obligations.

When you delete your account, your personal data is scheduled for deletion within 30 days unless we are legally required to retain certain information.

Shared transaction history may remain available to other participants.

Your privacy rights

To exercise any of your privacy rights, please contact us at:

hello@commingle.app

We aim to respond within one month where required by applicable law.

For users in the European Economic Area (GDPR)

You have the right to:

• access your personal information
• correct inaccurate information
• request deletion of your information
• restrict processing
• object to processing
• request data portability
• withdraw consent where processing is based on consent

For California residents (CCPA/CPRA)

You may have the right to:

• know what personal information we collect
• request deletion of your information
• request correction of inaccurate information
• opt out of the sale or sharing of personal information where applicable

Children’s privacy

Commingle is not intended for children under the age of 13.

If you are under the minimum age required by the laws of your country, you may only use Commingle with the permission of a parent or legal guardian.

If you believe a child has provided personal information to Commingle, please contact us and we will promptly delete that information.

Data controller

The data controller responsible for processing your personal information is: Krzysztof (Chris) Rutkowski – Founder of Commingle.

Your data is securely stored using Google Cloud data centres located in Iowa, United States.

Acceptance of this Privacy Policy

By creating an account and using Commingle, you acknowledge that your personal information will be processed as described in this Privacy Policy.

Where required by applicable law, we will ask for your consent before processing information for specific purposes such as marketing cookies.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

If we make significant changes, we will notify users through the app, by email or by other appropriate means where required.

Contact us

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

hello@commingle.app