Privacy policy

The short version

This notice covers the website. The unreleased offline iPhone app has a separate draft privacy notice because its local records have a different boundary from the website waitlist.

Who we are

This site is operated by [controller — company or individual], of [jurisdiction] at [address]. For the purposes of data protection law we are the controller of the limited personal data described below.

Nummiro is a personal finance tool. It is not a bank, a broker, or a financial adviser, and it does not hold or move anyone’s money.

What this policy covers

This policy applies to https://nummiro.com and nothing else. It does not cover the Nummiro application, which is not available to anyone: it is in development and has not been released. When the application is distributed it will be governed by the separate app privacy notice published on this site, and we will not quietly extend this policy to cover it.

One fact about that application is worth stating here anyway, because it is the reason this policy stays short. The current application isoffline-first: it connects to no bank, and the records a person enters are held in local storage on their own device, protected by the operating system. They reach us only if that person deliberately exports a file and sends it to someone. We do not receive them.

The application now contains the code for signing in to a Nummiro account, and that code is switched off and points at no server. No Nummiro account can be created or used today, by anyone, on any surface. We intend to offer accounts, and when we do the sign-in will carry an email address and a password to us — never the money records, which stay on the device. This policy and the application’s own notice will be rewritten before that is switched on, not after, which is the ordering the rest of this page promises.

What we collect

From an ordinary visit, we collect no personal data ourselves. Specifically, and to be concrete about it:

• There are no user accounts. Account sign-in is built but switched off and points at no server, so no account exists to be signed in to and there is no profile to build. Turning it on requires rewriting this page first.
• There is no analytics software of any kind — no page-view counter, no session recording, no heatmaps, no A/B testing tool.
• There are no advertising or social media tracking pixels, and no conversion tags.
• There is no embedded third-party content on ordinary page views: no external fonts, maps, video players, or comment widgets. The waitlist form uses Cloudflare Turnstile to prevent automated abuse; when you use that form, your browser loads its security check from Cloudflare.

This is enforced technically, not only by intention: every response carries a Content-Security-Policy header that permits resources from this site’s own origin, plus Cloudflare Turnstile for the waitlist form’s security check. Adding an unrelated third-party script would visibly break the page rather than quietly start collecting data.

The waitlist form

If you submit the waitlist form, we collect your email address, the date you joined, and a random unsubscribe token. We use this only to send Nummiro launch updates and to honour an unsubscribe request. Joining does not create an account or give us access to any financial information.

The delivery provider that sends those messages is Resend, Inc. We provide it with your email address and the content needed to deliver the message. We do not sell, rent, share with advertisers, or upload waitlist addresses to an advertising platform or custom audience. Every message includes an unsubscribe link.

• The address is used to email you about Nummiro and nothing else. No marketing for other products.
• We do not use the waitlist for advertising or behavioural profiling.
• You can remove your address through the unsubscribe link in an email or by writing to us, and we will delete it from the waitlist.

Cookies and tracking

This site sets no cookies of its own and uses no local storage, session storage, or browser fingerprinting. There is no cookie banner because there is nothing to consent to — a banner asking permission to do nothing would be theatre.

Our hosting provider may set strictly necessary cookies for security and abuse prevention as part of serving the site. Those are not under our control and are not used to profile you, build an advertising audience, or track you across other websites.

Hosting and server logs

This site is served from Cloudflare, Inc.’s global network, which acts as our processor. To deliver a page and protect a site from attack, their infrastructure necessarily handles technical request data, which may include your IP address, the time of the request, the page requested, and your browser’s user-agent string. If you are reading this somewhere other than our own domain — a preview build, for instance — the host may differ, and we will update this section if the arrangement changes.

We do not use those request logs for product analytics, advertising or visitor profiling. They are held and deleted according to our provider’s own policies, which are published atcloudflare.com/privacypolicy.

Legal bases for processing

Where the UK GDPR or EU GDPR applies, the legal basis we rely on for the request data described above is legitimate interests — specifically, serving a website that works and keeping it available and secure. We think that is a low-impact processing activity that a visitor would reasonably expect, and it is the minimum needed to show you a page at all.

For the waitlist, the legal basis is consent, given by choosing to submit the form and withdrawable at any time.

Where data is processed

Both companies in the request path — Cloudflare, Inc. and Resend, Inc. — are established in the United States and operate global infrastructure, so personal data described on this page may be processed outside the United Kingdom and the European Economic Area. Where the UK or EU GDPR applies to that transfer, we rely on the standard contractual clauses each provider publishes as part of its data processing agreement.

We have not appointed any other processor, and we do not transfer waitlist addresses to anyone else. If that changes, this section is rewritten before the change is made, not after.

How long we keep things

We keep a waitlist address until you unsubscribe, ask us to delete it, or Nummiro launches and we send the final waitlist notice. We then delete it within 30 days unless you separately choose to join a new list. Provider-side request logs are retained for their own defined periods, not ours.

Your rights

Depending on where you live, you may have the right to access the personal data an organisation holds about you, to have it corrected or erased, to object to or restrict its processing, and to receive it in a portable form. You also have the right to complain to your data protection authority.

For a waitlist request, contact us from the address you used to join. The supervisory authority you can complain to is the one for[jurisdiction].

Children

Nummiro is intended for adults managing their own money. This website is not directed at children, and we do not knowingly collect waitlist addresses from children.

Changes to this policy

We will update this page when what we do changes, and the "last updated" date at the top will change with it. The commitment we are making is about order of operations: the policy is updated before the behaviour is, not after. If we ever start collecting something, this page will say so first.

Contact us

Privacy questions, requests, or corrections to anything on this page can go to [email protected]. We would genuinely like to hear if you think something here is vague or overstated.