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Privacy Policy

This Privacy Policy explains what personal data is collected when you use the millio mobile application (the "App"), our website located at https://udzutech.com/ (the "Website"), and related services (together, the "Services"), which are provided by Aleksei Kochetov / UDZU Tech, and how such personal data will be used, shared, or otherwise processed.

Updated: 8 March 2026

Effective date / Version

  • Effective date: 15 January 2026
  • Last updated: 8 March 2026
  • Version: 1

Consent and eligibility

  • BY USING THE SERVICES, YOU CONFIRM THAT (I) YOU HAVE READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU).
  • If you do not agree, please do not use the Services.

Definitions

  • "GDPR" means the General Data Protection Regulation (EU) 2016/679.
  • "EEA" includes all current member states of the European Union and the European Economic Area.
  • "Process" means to collect, store, use, disclose, or otherwise handle personal data.

Table of contents

  • 1. Categories of personal data we collect
  • 2. For what purposes we process personal data
  • 3. Under what legal bases we process your personal data (EEA users)
  • 4. With whom we share your personal data
  • 5. How you can exercise your privacy rights
  • 6. Age limitation
  • 7. International data transfers
  • 8. Changes to this privacy policy
  • 9. Data retention
  • 10. How "Do Not Track" requests are handled
  • 11. Personal data controller
  • 12. Contact us

1) Categories of personal data we collect

  • We collect (a) data you provide voluntarily, (b) data we collect automatically from your device, and (c) where applicable, data from Apple and Apple services when you use Sign in with Apple, iCloud sync, App Store subscriptions, or Apple Push Notification service. We follow a data-minimization approach and collect only what is necessary to provide and improve the Services.
  • 1.1 Data you give us: when you use millio, you may enter financial and related information, such as:
  • Accounts/wallets (names, currencies, balances).
  • Transactions (dates, amounts, categories, notes you choose to add).
  • Budgets, goals, tags, and other content you create in the App.
  • Preferences and settings.
  • If the Services include an account, you may also provide identifiers such as email address and name.
  • 1.2 Data provided to us by third parties (if applicable): if you choose to use Sign in with Apple, we may receive certain personal data from Apple, such as your name, email address (including a private relay address, if you choose that option), and an Apple-provided identifier. You can manage or revoke access in your Apple ID settings.
  • 1.3 Data we collect automatically: depending on your device and configuration, we may collect:
  • Device data: language settings, time zone, device type/model, operating system and version, app version.
  • Network data: IP address (typically used to infer approximate location such as country/region).
  • Usage data: millio does not currently use third-party analytics tools.
  • Diagnostics: millio does not currently use third-party diagnostics or crash-reporting providers. Apple may process limited technical data when you use Apple system services.
  • Advertising IDs: millio does not use advertising IDs and does not use your data for third-party tracking or advertising.
  • 1.4 Cookies (Website only): if you use our Website, we may use cookies or similar technologies to operate the Website, remember preferences, and measure performance. You can control cookies through your browser settings.

2) For what purposes we process your personal data

  • We process your personal data for the following purposes:
  • To provide and operate the Services (e.g., storing and displaying your finance data, syncing data through iCloud if you enable sync, delivering notifications, and providing market data features where available).
  • To authenticate you using Sign in with Apple, where you choose to use it.
  • To provide customer support and respond to your requests.
  • To ensure security and maintain the Services, including through Apple system services that support push notifications, iCloud sync, and App Store subscription management.
  • To communicate with you regarding important notices about the Services (e.g., policy updates, security notices).
  • To process payments and manage subscriptions (where paid features exist). Payments and subscription billing are handled by Apple through the App Store; we do not store full card details.
  • To comply with legal obligations and to enforce our Terms (if applicable).
  • 2.1 Analytics and diagnostics: millio does not currently use third-party analytics or diagnostics providers. If we introduce analytics, crash reporting, or similar tools in the future, we will update this Privacy Policy before doing so.
  • 2.2 Marketing communications (if applicable): we do not currently send marketing emails. If we introduce optional marketing communications in the future, we will request any required consent and update this Privacy Policy.

3) Under what legal bases we process your personal data (applies to EEA-based users)

  • If you are located in the EEA, we process personal data under the following legal bases (GDPR Article 6):
  • Your consent (Article 6(1)(a)) - for optional features or processing where consent is required.
  • Performance of a contract (Article 6(1)(b)) - to provide the Services you request.
  • Legitimate interests (Article 6(1)(f)) - to secure, maintain, and improve the Services (e.g., fraud prevention, debugging), unless overridden by your rights.
  • Compliance with legal obligations (Article 6(1)(c)) - when the law requires certain processing.

4) With whom we share your personal data

  • We do not sell your personal data. We may share personal data only as described below:
  • 4.1 Service providers (processors): we may share personal data with third parties that help us operate the Services, acting on our instructions, such as:
  • Apple services, including iCloud if you enable iCloud sync.
  • Infrastructure and hosting providers that support backend functions, such as delivering stock quote or market data features.
  • Apple services used for subscriptions, push notifications, and Sign in with Apple.
  • Customer support tools (for example, email), when you contact us.
  • Payment platforms (Apple App Store) to handle purchases and subscription status.
  • 4.2 Legal requests: we may disclose data to comply with law, regulation, legal process, or governmental requests, and to protect the rights, property, and safety of our users and the Services.
  • 4.3 Business transfers: if we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal data may be transferred as part of that transaction, subject to applicable law.

5) Your privacy rights

  • Depending on your location, you may have rights to access, correct, delete, or export your personal data, and to object to or restrict processing.
  • At this time, millio does not provide dedicated in-app tools for data export, account deletion, or full data deletion requests.
  • To request access, correction, export, or deletion of your personal data, please contact us at [email protected]. We may ask for information necessary to verify your identity.
  • If account deletion becomes available in the App in the future, this Privacy Policy will be updated accordingly.
  • EEA users: you also have the right to lodge a complaint with your local data protection supervisory authority.

6) Age limitation

  • We do not knowingly process personal data from persons under 16 years of age. If you believe a child has provided us with personal data, please contact us at [email protected].

7) International data transfers

  • We may process personal data in countries other than where you live. If we transfer personal data from the EEA to countries that do not provide an adequate level of protection, we rely on appropriate safeguards such as Standard Contractual Clauses or other lawful transfer mechanisms.

8) Changes to this privacy policy

  • We may update this Privacy Policy from time to time. If changes are material, we will notify you through the Services or by other means. The Last updated date indicates when this Privacy Policy was last revised.

9) Data retention

  • We retain personal data only for as long as necessary to provide the Services and for the purposes described in this Privacy Policy, unless a longer retention period is required by law.
  • User-entered finance data is stored until you delete it, remove the App, or disable related sync features, subject to Apple iCloud retention rules where iCloud sync is enabled.
  • Support communications are retained for a limited period to handle your request and comply with obligations.
  • Subscription and transaction-related records may be retained as required for legal, tax, accounting, and fraud-prevention purposes.

10) Do Not Track

  • The Services do not currently respond to "Do Not Track" signals. Some third-party services may offer their own opt-out mechanisms; please review their privacy policies.

11) Personal data controller

  • Name: Aleksei Kochetov

12) Contact us