Finch Privacy Policy

Last updated: 28.01.2026

This Privacy Policy explains how Finch Ventures BV ("Finch", "we", "us", or "our") collects, uses, and protects your personal data when you use the Finch mobile application and website (together, the "Services").

Finch is a B2C personal finance application that helps individuals understand and manage their finances through secure account aggregation, analytics, and personalised insights.

We process personal data in accordance with:

• The Swiss Federal Act on Data Protection (FADP)
• The EU General Data Protection Regulation (GDPR)

1. Data Controller

Finch Ventures BV
Therese Schwartzestraat 11
2549XK, Den Haag, Nederland
Email: team@finch-agent.com

2. Scope – B2C Users Only

Finch is provided exclusively to private individuals for personal use. This Privacy Policy applies only to consumer (B2C) users and does not cover business or employer-provided services.

3. Personal Data We Collect

We collect only the data necessary to operate Finch securely and to provide meaningful financial insights.

3.1 Data You Provide Directly

• Full name
• Email address
• Account credentials (securely hashed and encrypted)
• Subscription status (freemium or paid tier)
• Communication with customer support
• User preferences and settings

3.2 Financial Data via Open Banking & Banking Interfaces

With your explicit consent, Finch may access financial data via regulated providers, including:

EU / EEA

• Open banking platforms operating under PSD2 (e.g. Account Information Service Providers – AISPs)

Switzerland

• SIX bLink platform for secure financial data connectivity
• Swisscom infrastructure for identity, consent management, and secure transmission where applicable

Data accessed may include:

• Account balances
• Transaction history
• Merchant names and transaction descriptions
• Categories and timestamps

3.3 Automatically Collected Data

• Device and app information (OS, version)
• App usage and feature interaction
• Crash reports and performance logs
• IP address (anonymised or truncated where possible)

4. Freemium vs. Paid Features – Data Usage Distinction

4.1 Freemium Tier

The free version of Finch provides:

• Basic account aggregation
• High-level financial overviews
• Limited insights and summaries

Legal basis: Contract performance (Art. 6(1)(b) GDPR)

4.2 Paid / Premium Tier

Paid users receive:

• Advanced analytics and forecasting
• Deep transaction categorisation
• AI-powered, personalised financial insights
• Historical trend analysis

5. Purposes of Processing

We process personal data for the following purposes:

• Providing and maintaining the Finch app
• Secure authentication and user verification
• Generating personalised financial insights
• Subscription management and billing
• Customer support
• Product improvement and analytics
• Legal and regulatory compliance

6. Automated Processing & AI

Finch uses automated processing and AI-based systems to:

• Categorise transactions
• Identify spending patterns
• Generate insights and recommendations

These processes:

• Do not produce legal or similarly significant effects
• Remain explainable at a high level
• Can be limited or disabled by the user where applicable

7. Cookies, Analytics & Tracking

Finch uses minimal and privacy-focused analytics.

Finch does not use data collected from the app for cross-app tracking or advertising purposes, as defined by Apple, unless the user explicitly consents. Such consent may be requested, for example, for personalised analytics intended to optimise app functionality and user impact.

Analytics data is:

• Aggregated or pseudonymised where possible
• Never sold
• Not shared for advertising or marketing purposes

Further details are provided in Appendix A – Cookies & Analytics.

8. Data Sharing & Third-Party Processors

We do not sell personal data.

We may share data with trusted third-party service providers, including:

• EU open banking providers (PSD2-compliant)
• SIX bLink (Switzerland)
• Swisscom (identity, consent, secure infrastructure)
• Google Cloud hosting provider (Switzerland-based)
• Monitoring and error-tracking services
• Payment and subscription providers

All third-party service providers:

• Act solely as data processors
• Process personal data only on our documented instructions
• Do not use personal data for their own purposes
• Are contractually bound by Data Processing Agreements (DPAs)
• Comply with GDPR and Swiss data protection law

9. International Data Transfers

If data is transferred outside Switzerland or the EEA, we rely on:

• Adequacy decisions, or
• EU Standard Contractual Clauses (SCCs)

10. Data Retention

• Active accounts: retained for the duration of the contract
• Inactive accounts: deleted or anonymised after 12 months
• Legal obligations: retained as required by law

11. Your Rights (Including Consent Withdrawal & Deletion)

You have the right to:

• Access your data
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Data portability
• Withdraw consent at any time

Account Deletion & Withdrawal of Consent

You may withdraw your consent at any time by deleting your Finch account, which will result in the deletion of all personal data associated with your account.

Account deletion can be initiated directly in the app by:
Home Screen → Menu → Profile → Delete account, and following the on-screen steps.

Upon deletion, your data will be permanently and irrevocably removed from Finch-operated databases as soon as technically and legally possible.

Alternatively, users may request account deletion and consent withdrawal by sending an email to:
📧 team@finch-agent.com

12. Complaints

You may lodge a complaint with:

• Your local EU data protection authority, or
• The Swiss Federal Data Protection and Information Commissioner (FDPIC)

13. Children's Privacy

The Finch app is not permitted for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a minor has used the app, the account and associated data will be deleted.

14. Changes

We may update this Privacy Policy from time to time. Material changes will be communicated in-app or by email.

Appendix A – Cookies & Analytics Policy

A.1 Essential Cookies

Required for:

• Authentication
• Security
• Core app functionality

These cannot be disabled.

A.2 Analytics & Product Improvement

We use privacy-minimised analytics to understand:

• Feature usage
• Performance issues
• User flows (aggregated, pseudonymised)

Analytics are:

• Limited to what is necessary
• Not used for advertising
• Never sold or shared for marketing purposes

A.3 Personalised Insights & Consent

To provide premium personalised insights, Finch requires:

• Processing of detailed financial behaviour
• User acceptance of the Terms & Privacy Policy

If consent is not granted or is withdrawn:

• Premium services cannot be provided
• Freemium access remains available

Contact

📧 team@finch-agent.com