Consent to Personal Data Processing

1. Who gives consent and to whom

Consent is given by an individual registering with «Мы» at vdvoemwallet.com, referred to as the “User”.

Consent is given to the personal data controller: the individual Panin T. R., email noreply@timur-p.ru, referred to as the “Controller”.

Consent is given freely, voluntarily and in the User’s own interest by ticking the relevant registration form checkbox.

2. Data subject

The data subject is the User giving this consent.

The Controller does not request or process the User’s legal full name, passport details, residential address, phone number or other identity particulars. The User is identified by their registration email and their chosen name or pseudonym, which need not be their real name.

For this reason, enquiries about personal data must come from the email registered to the account: the Controller has no other way to verify that the request comes from the User.

3. Personal data covered

The User consents to processing of the following personal data:

1. email address;
2. password as a hash value;
3. the name or pseudonym provided on registration and an uploaded profile image;
4. couple details: name, invitation code and a photo uploaded by the User;
5. financial entries made by the User: date, amount, category, comment, author and receipt image;
6. accounting settings: currency, category limits, trips and exchange rates;
7. dates entered by the User: relationship start date and participants’ birthdays;
8. content created by the User: tasks, calendar events, notes, wishlist, plans, polls and delayed messages;
9. loyalty card images uploaded by the User;
10. notification subscription details: browser push endpoint, notification encryption keys and device name;
11. account device details: a random browser profile identifier, approximate operating system, browser, device type and launch mode, including a saved launch store label (Google Play or RuStore), if available, and first and last visit dates. This register is available only to the administrator, is independent of notification settings and does not contain IP addresses, the full User-Agent or the exact phone model;
12. the identifier and public key of the device authentication method (Face ID, Touch ID). Biometric data itself is neither sent to nor processed by the Controller;
13. User activity details: who changed a record and when, and login attempt times;
14. technical information: IP address, browser and operating system type and version, referral source, pages viewed and actions on them.

4. Purposes of processing

Data is processed solely for these purposes:

1. creating and maintaining the User’s account and providing app access;
2. linking two Users into a shared couple’s space and displaying record authorship;
3. providing app features: shared budgeting, tasks, calendar, notes, wishlist and plans;
4. generating date reminders and spending and gift suggestions;
5. delivering notifications to the User’s devices;
6. account security and protection against unauthorised access;
7. handling the User’s enquiries;
8. diagnosing use of the service across devices using the account device register;
9. analysing website traffic and improving the site.

Data is not used for advertising, disclosed to advertising networks or sold to third parties.

5. Processing operations

The User consents to collection, recording, organisation, accumulation, storage, clarification and amendment, retrieval, use, disclosure to the recipients listed in section 5, anonymisation, blocking, deletion and destruction.

Processing is carried out using automated databases and without automated means.

6. Consent to cross-border transfers

The User separately and knowingly consents to cross-border transfer of personal data to the following recipients to the extent described:

1. Supabase, Inc. (Germany, Frankfurt) — database, authentication and server functions. All data listed in section 2, except document files, is disclosed. Germany is a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data.
2. Groq, Inc. (USA) — processing requests for the budget assistant and gift suggestions. Amounts, categories, transaction comments, participants’ names, balances and limits are disclosed; for gift suggestions, birthdays and the occasion are included. Email, passwords and document files are not disclosed. The USA is not a party to that Convention.
3. Google LLC (USA) — website fonts and Google Analytics. Fonts receive the IP address and browser type. Analytics receives anonymised visit information: a truncated IP address, browser and device type, referral source and pages opened, only after the User consents to cookies. The USA is not a party to that Convention.
4. Apple Inc. (USA), Google LLC (USA), Mozilla Foundation (USA) — push delivery. The device’s push subscription endpoint and encrypted notification content are sent; these recipients cannot decrypt that content. This occurs only when the User enables notifications.

Data is also disclosed to Russian recipients: Timeweb LLC (storage for website files and app updates, IP addresses and service logs), MT FINANS LLC (RuVDS; website server and relay between the app and the database, IP addresses and requests in transit) and Yandex LLC (web analytics, details from item 13 of section 2). These are not cross-border transfers.

7. Duration and withdrawal

Consent takes effect when given and remains effective until withdrawn.

It may be withdrawn at any time by emailing a written request to noreply@timur-p.ru from the registered address.

The User is informed that withdrawal stops processing and results in account deletion, because the app cannot provide its features without processing the specified data.

Deletion procedures and timeframes are described in the Personal Data Processing Policy.

8. User acknowledgement

By ticking the registration checkbox, the User confirms that they:

1. have read the Personal Data Processing Policy and this consent;
2. understand the data disclosed, processing purposes and recipients;
3. have been informed of their rights under Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”, including access, correction, blocking and destruction, and the right to complain to Roskomnadzor or a court about the Controller’s actions;
4. have provided accurate data.

Version 1.2 dated 13 October 2026.

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