Personal Data Processing Policy

1. General provisions

This policy explains personal data processing in «Мы». It covers all data the controller receives from visitors to vdvoemwallet.com and users of the app.

The policy was prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

Definitions

• Personal data means information relating directly or indirectly to an identified individual.
• Controller means the person organising and carrying out processing, identified in the next section.
• User means a person registered in the app.
• Couple means a shared space for two users linked by an invitation code. Records within the couple are visible to both participants; this is a core property of the service.
• Processing means any operation with data, including collection, storage, modification, disclosure, deletion and the other operations listed below.

By using the site and app, you agree to this policy. If you disagree, you should not use the service.

2. Who processes your data

Personal data controller: the individual Panin T. R.

For all data enquiries: noreply@timur-p.ru.

Website and app: vdvoemwallet.com.

The policy applies to all site visitors and all users of «Мы».

3. Categories of data subjects

The Controller processes data about:

• Site visitors — everyone opening vdvoemwallet.com, even without registering. Only technical and web analytics data is processed about them.
• App users — registered people and their partners in the couple. Most data relates to them.
• Third parties whose details a user enters — relatives, friends and acquaintances added to People. Their name, relationship and birthday are processed. These details come from the user, not directly from those people; the user is responsible for having grounds to disclose them.

The Controller does not deliberately collect minors’ data. The service is intended for adults.

4. What data is processed

This lists everything the app collects, based on its source code rather than hypothetical needs. The app does not collect data outside this list.

2.1. Account data

• Email address.
• Password. It is never stored in plain text: the server stores only a hash from which the original password cannot be recovered.
• Your name within the couple and an avatar if you upload one.
• Couple data: name, invitation code and a home-screen photo if you add one.

2.2. Data you enter

• Financial entries: date, amount, category, comment, which partner added the entry and a receipt photo if attached.
• Budget settings: currency, category limits, trips and exchange rates.
• Personal dates: relationship start date, participants’ birthdays and nicknames.
• “Us” records: tasks, calendar events, notes, wishlist, plans, polls and time capsules.
• Other people’s details: People can store relatives’ and friends’ names, relationships and birthdays. This is third-party data you enter; you are responsible for having the right to do so.
• Loyalty card images if you add them.
• Feedback: message text, your name within the couple and the screen from which you wrote.

2.3. Documents

Documents work separately from everything else. Files are encrypted on your device with a key derived from your chosen PIN and are not uploaded to the server at all. The PIN itself is not transmitted. The server stores only a verification string from which neither the PIN nor file contents can be recovered.

2.4. Technical data

• Notification subscription: your browser push endpoint, notification encryption keys, device name and your name within the couple. Created only if you enable notifications.
• Account devices: after acceptance of this policy version and consent, the app stores a random browser profile identifier, approximate operating system, browser, device type and launch mode, including the saved launch store label (Google Play or RuStore) if available, and first and last visit dates. These details are linked to your account and available only to the administrator for diagnosing service use. Tracking is independent of push notifications. The exact phone model, IP address and full User-Agent are not recorded in this register. Different browsers on one phone may appear separately.
• Face ID or Touch ID login: the identifier and public key created by your device. The device does not transmit your fingerprint or face image; the app receives only confirmation that authentication succeeded.
• Activity log: which participant changed what and when.
• Password guessing protection: account name and times of failed login attempts. IP addresses are not stored for this purpose.
• Server and hosting logs: IP address, request time and browser type.
• Web analytics data: see section 9.

2.5. My Plus payment information

For My Plus payments via SBP, we store the selected period, amount in roubles, date, order and payment identifiers and statuses, access expiry and refund details. The order is linked to the payer’s account and couple; the creator attribution at checkout is saved for commission calculations. This allows repeated or delayed notifications to be handled without duplicate accruals. Settlement history may remain after the couple is deleted.

RollyPay receives the order number, amount, currency, access period description and return URLs. The app does not send RollyPay your name, email, password, budget or transaction comments. Payment is confirmed by the payment partner and bank; the app does not receive the payer’s banking details. Automatic debits are not enabled. See the User Agreement for payment terms.

2.6. Creator programme

If you apply a creator’s promo code when creating a couple, we link that couple to the creator and account for confirmed My Plus payments and refunds to calculate commission. The creator sees an anonymised couple label, attribution date, promo code used, payment count and their own earnings. Participants’ names, email addresses, financial entries and personal records are not disclosed to creators.

A creator application involves their name, account email, Telegram contact, and website and comment if provided. We store the application status and rejection reason, if any. Statistics, promo codes and payout requests are unavailable until approval. Once approved, a creator can create up to three promo codes; we store them and their related metrics.

The creator dashboard processes participation terms, commission percentage, earnings, balance adjustments and settlement history. Each adjustment records its amount, reason, administrator and time. Settlement history is retained to reconcile earnings and payouts; deleting an invited couple does not automatically delete completed settlement records.

A payout request stores the amount, method, statuses, rejection reason if any, and the link to a completed payout and transfer confirmation. Depending on the method, you provide: card number and recipient name; for SBP, phone number, bank and recipient name; for USDT on TRC‑20, wallet address. Card expiry, CVV/CVC, passwords, seed phrases and private keys are not requested. Details are supplied to execute the payout you request; the dashboard itself does not execute bank or cryptocurrency transfers.

Full payout details are available only to the creator and the administrator handling the payout. They are stored encrypted using Supabase Vault; general lists display abbreviated details. Access to applications, settlements and payouts is separated: each creator sees only their own data and programme management is restricted to the administrator.

A creator referral label is stored in your browser’s localStorage for no more than 30 days to offer the promo code when creating a couple. It is not used for advertising and does not itself give the creator access to your account.

5. Purposes and legal bases

Newsletter consent

News emails are sent only to people who opt in by choosing “Yes, send them” in the app or enabling “Service news by email” in their profile. Consent is separate and voluntary; the app works fully without it.

By consenting, you agree to receive emails at your account address about new «Мы» features and changes and advice on shared budgeting and using the app. Emails are sent no more than twice a month. Your email and name within the couple are used. The fact and date of consent, text version and browser details are stored to verify consent if needed.

You can unsubscribe at any time without giving a reason using the “Unsubscribe” link in any email, the profile switch or an email to noreply@timur-p.ru. Unsubscribing does not affect the app. Service emails (password resets and service operation messages) are separate and are sent regardless of newsletter consent.

6. Processing operations and retention

Processing includes collection, recording, organisation, accumulation, storage, clarification and amendment, use, disclosure to the recipients listed in section 5, blocking, deletion and destruction. Processing uses automated databases.

We do not sell your data, disclose it to advertising networks or use it to show advertisements. The app does not make data-based decisions that produce legal consequences for you.

Retention. Data is stored while your account exists. Processing stops when the purposes in section 5 are achieved or you withdraw consent. After withdrawal or account deletion, data is destroyed within the legally required timeframe. Database backups may retain it temporarily and are overwritten through rotation.

Failed login attempt data is deleted automatically after one day. PIN-encrypted documents exist only on your device and are removed with browser data.

The device register holds no more than 20 records per account. The administrator sees visits from the last 90 days. Records older than 90 days are removed on the next permitted device update for that account; no scheduled cleanup occurs if the user does not return. Account deletion also removes its device records.

7. Recipients and countries

The app uses third-party services. This lists exactly what they receive; there are no other recipients.

Cross-border transfers

Transfers to Germany, the USA and China are cross-border. These services process data on our behalf and to the extent described above.

Germany is a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. The USA is not; transfers there are based on the separate consent requested during registration.

If you prefer not to send your financial data to the USA, do not use the budget assistant or gift suggestions. The rest of the app works fully without them.

China is also not a party to that Convention. A receipt photo is sent to DeepSeek (China) only with separate consent requested before first use. Without consent, the photo is simply attached to the entry and you enter the amount yourself.

8. Database localisation

We state this directly because it is an important fact, not a formality.

Article 18(5) of Law 152-FZ requires the recording, organisation, accumulation, storage, clarification and retrieval of Russian citizens’ personal data to use databases located in the Russian Federation.

This requirement is currently not fully met. The app’s database uses Supabase servers in Germany (Frankfurt). The website is served from Russia.

The Controller is working on moving the database to infrastructure in Russia. Until that is complete, you use the service knowing this circumstance and may withdraw consent and delete your account at any time as described below.

9. How data is protected

Only measures actually implemented are listed.

• All website communication uses HTTPS.
• Passwords are stored as hashes and cannot be recovered from the database.
• Access restrictions are enforced in the database, not just the interface: another account’s request will not return your couple’s data even if made outside the app.
• An entry hidden from a partner is not sent to them by the server before its reveal date.
• Document files are encrypted with AES on your device and are not sent to the server.
• Login attempts are limited to protect against password guessing.
• You can additionally secure login with Face ID or Touch ID.
• You can export a full copy of your data from app settings at any time.

No system is completely secure. Report vulnerabilities to noreply@timur-p.ru.

10. Your rights

You may:

• obtain confirmation of processing and details of the data processed;
• obtain a copy of your data; most can be exported in JSON and CSV in app settings;
• request correction of inaccurate or outdated data; most can be edited in the app;
• request blocking or destruction of data processed unlawfully or no longer needed for the stated purposes;
• withdraw consent;
• complain to Roskomnadzor or a court about the Controller’s actions.

To exercise these rights, email noreply@timur-p.ru from your registered address. We respond within the statutory timeframe.

11. Contacting the Controller

Send requests to noreply@timur-p.ru from your registered email. This is the only way to verify a request is yours; the Controller does not store other identifying details.

Your request should include:

• what you want: information, correction, withdrawal of consent or account deletion;
• your account email;
• your name within the couple if the request relates to specific records.

The Controller responds within the periods set by Law 152-FZ. If a request is unclear or cannot be fulfilled, the Controller explains why rather than leaving it unanswered.

If dissatisfied, you may contact Roskomnadzor, the authorised body for personal data rights, or a court.

12. Withdrawing consent and deleting your account

Withdraw consent at any time by emailing noreply@timur-p.ru from your registered address. Withdrawal stops processing and results in account deletion because the app cannot work without processing these data.

You may request account deletion in the same way. The account and associated couple records will be deleted. Couple records are shared, so agree with your partner and export a copy from settings first if you wish to retain them.

We plan to add a deletion button directly to the profile. Until then, deletion is handled by email as described above.

Newsletter consent is withdrawn separately, using “Unsubscribe” in an email or the profile switch. This does not delete the account (see section 5).

13. Cookies, localStorage and analytics

What your browser stores

The app stores technical values on your device. The values below are needed for operation, are not sent to our server and are not advertising:

• session details, so you do not need to sign in every time;
• the last screen, to return there after a reload;
• a flag that Face ID or Touch ID login is enabled on this device;
• encrypted document files and a temporary access key valid for eight minutes.

Separately, after acceptance of updated documents, the browser stores a random identifier for the device register in section 2.4. This identifier is sent to the server with an approximate device description and linked to your account. It is not used for advertising; clearing site data creates a new record.

Web analytics

The site uses Yandex Metrika (112965264) and Google Analytics (stream G-QN2L7856ZX). Both collect anonymised visit information: IP address, browser and device type, referral source, pages viewed and actions. Both use cookies; Google Analytics receives a truncated IP address.

With your consent, analytics also records successful account creation, joining a couple and the first saved entry, without its amount, category or comment. Confirmed My Plus purchases include the technical order identifier, price, currency and paid period (month or year). These events exclude payment details, names, email and shared budget content.

Google Analytics belongs to Google LLC and is located in the USA, so these data leave Russia. See section 7.

Visitor action recording (Webvisor) is additionally enabled on information pages. Action recording is deliberately disabled inside the app so transaction, note and other personal content does not enter session recordings.

Analytics does not start without your consent. On your first visit, the site asks permission for cookies. Neither counter loads and no data goes to Yandex Metrika or Google Analytics until you select “Accept”. Your choice is saved in your browser and can be changed by clearing site data.

You can also refuse analytics through your browser: block cookies, enable “Do Not Track”, or install the Yandex Metrika blocker and the Google Analytics opt-out extension. This does not affect app operation.

14. Policy changes

We may amend this policy, for example when adding features or changing a service listed in section 5. The current version is always available at vdvoemwallet.com/privacy.

If changes affect the data collected, processing purposes or recipients, we will ask you to review the new version at your next login.

On 25 October 2026, MT FINANS LLC (RuVDS), whose server runs the website and the relay between the app and the database, was added to section 7, and what Timeweb LLC stores was clarified. The rest of the text is unchanged.

Version 1.4 dated 20 October 2026.

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