Privacy Policy
My Two Cents · iOS & Android app · Last updated: November 2026
1. Who we are
My Two Cents (called Meus Trocados in Brazil) is a personal finance app. We respect your privacy and take the protection of your financial data seriously.
The controller responsible for the personal data described in this policy is GGSA Consultoria em TI Ltda., a company based in São Paulo, Brazil (CNPJ 49.390.014/0001-58), operating the app under the brand names My Two Cents and Meus Trocados. You can reach us at contact@ggsalabs.software.
2. Data stored on your device
Your financial data (accounts, entries, categories, goals and budgets) is kept in the local database on your device, in SQLite. Without an account, that is the only place it exists: no identifiable financial information is sent to external servers without your explicit consent.
The app never asks for your bank username, password or any bank login, and it does not connect to your bank. You type entries, snap receipts or import statement files that you download yourself.
3. Account and sync (optional)
You can use the app without an account. If you decide to sign in with Apple or Google, a copy of your app data (accounts, entries, categories, goals, budgets, loans, automatic rules, tags and notification preferences) is sent to our server so it stays the same on all your devices and can be recovered if you switch devices. Attachments (photos of receipts) are not sent.
- Encryption: data travels over an encrypted connection (HTTPS) and is stored encrypted with a key exclusive to your account, which in turn is protected by a master key in AWS KMS. This is not end-to-end encryption: the server can decrypt the data of an account when it needs to process it.
- Use by the server: besides syncing, the server may decrypt your data to generate the summaries and alerts of the Pro plan AI. In that case, only totals by category and by period, calculated on the server, are sent to Anthropic (Claude), which generates the text. Anthropic does not use this data to train models.
- What we keep about your account: a login identifier (Apple or Google), your email when the provider shares it (Apple may hide it), and your connected devices (name, app version and the Apple notification token used to tell your other devices that something is new). The device name may contain your first name, as in "Alex's iPhone".
- Access logs: date, time and IP address of logins, session renewals, exports and account deletions, kept for 6 months, as Brazilian law (Marco Civil da Internet) requires.
- Pro subscription: with an account, your Pro subscription is linked to it in RevenueCat, so it works on all your devices.
- Signing out: the app first uploads anything not yet synced, then erases the data from this device. It stays in your account and comes back when you sign in again.
- Without an account: your data lives only on your device. If you have no backup (iCloud, or exported in More → Data and Backup), deleting the app or losing the device erases it for good.
- Deleting the account (More → Account) permanently erases from the server your account key, your records, devices and sessions (what stays is in section 13). Without the key, any encrypted copy that still exists in the backups of the hosting provider can no longer be read. The data on this device is erased too; an iCloud backup, if you have one, stays there and can be restored.
4. When we use external servers
Photos of receipts and proofs of payment (camera or gallery) have their text read on the device first. On Pro, if that reading isn't reliable enough, or if you tap "Improve with AI", the photo is sent to the AI (Anthropic), after you authorize it. On the free plan the photo never leaves the device.
When you speak an entry, speech recognition is done by the device system (on the device itself when available); we do not record or send the audio. The text is interpreted on the device and is not sent to anyone.
Outside the sync described above, we only send data to external servers when you explicitly authorize it, through a consent dialog that explains what will be sent, before the first use of each feature below.
- AI diagnosis (Pro feature): we send only totals aggregated by category, financial health score and goals, without entry descriptions or personally identifying data, to Anthropic (an American company that operates the Claude model), which generates the diagnosis.
- AI statement and receipt extraction (Pro feature): the content of the PDF or image of the account statement, card statement or receipt is sent to the server, which forwards it to Anthropic (Claude) for processing. Our server does not store the content after extraction.
- AI chat (Pro feature): when you talk to the assistant, we send aggregated data from your recent months (balance, statements, goals, budget, score) to Anthropic (Claude), which answers your questions. When the question requires it, the assistant may also send the description and amount of specific entries, for example when looking up an expense by merchant name.
Our server does not keep the content sent to the AI; it keeps only the token count and cost, to apply usage limits. Under Anthropic's commercial terms, this data is not used to train models, and Anthropic automatically deletes inputs and outputs within 30 days, and may keep them longer only if it needs to enforce its usage policy or comply with the law.
Without an account, no individual financial data is stored permanently on the server.
5. Who processes data for us
- Railway: server and database hosting.
- Amazon Web Services (AWS KMS): holds the master key that protects the account keys.
- Anthropic: AI model (Claude) for the Pro features.
- Apple: Sign in with Apple and delivery of sync notifications (APNs).
- Google: Google sign-in, if you choose that option.
- RevenueCat: subscriptions (see section 6).
- Sentry: error reports (see section 7).
Some of these services are located outside Brazil (mainly in the United States).
6. Subscriptions and payments (RevenueCat)
Pro subscription management uses RevenueCat, an in-app payments platform. RevenueCat receives a user identifier (the one for your profile on the device or, with an account, the account identifier, with no name or email) and purchase information from the Apple App Store or Google Play to verify and manage subscriptions. No financial data from the app is shared with RevenueCat. We never see your card number: payments are handled by Apple or Google. See the RevenueCat Privacy Policy at revenuecat.com/privacy.
7. Error reports (Sentry)
In case of technical failures, we may collect anonymous error reports via Sentry. These reports contain information about the device, the operating system version and the exception that occurred, never financial data. Sentry is enabled only in builds distributed through TestFlight or the stores.
8. Usage data
To understand what people use and improve the app, it sends our server, at most once a day, usage counts: for example, how many entries, accounts, budgets and goals exist, whether there are recurring rules, which default categories are used most, and whether notifications and backup are on. We also send simple events, such as finishing the intro, opening the subscription screen or importing a document. We never send monetary amounts, descriptions, account names or names of categories you created. This data is tied to a pseudonymous identifier, which, with an account, is linked to it.
You can turn off the counts and events at any time at the bottom of the privacy screen in the app, under "Usage data"; this also deletes what has not been sent yet. That switch does not turn off the app-open ping (pseudonymous identifier, platform, version and country, which the server infers from the IP address without storing it), used to know how many people use the app and on which versions.
9. Messages and surveys
When you write in More → Send a suggestion or problem, we store on our server the message, the type (suggestion, problem or other), your email, only if you provide it to get a reply, the app and system versions, the device model, the language, whether you are Pro or not and the pseudonymous identifier of app opens. When you answer a short survey inside the app, we store the option chosen, your comment, if you write one, the app version and the same identifier, so we do not ask again. None of this includes your entries, balances or accounts. We use these messages only to reply to you and improve the app; you can ask for them to be deleted using the contact in section 18.
10. Backups and iCloud / Google Drive
The app makes automatic weekly backups in the documents folder of the device. iCloud and Google Drive may sync these files according to the system settings. You can export or delete your backups at any time in More → Data and Backup.
11. Biometrics and local security
Face ID, Touch ID and other biometric authentication are handled directly by the operating system. The app does not store or transmit biometric data.
12. Your rights under Brazilian law (LGPD)
Because our company is based in Brazil, we handle personal data in compliance with the Brazilian General Data Protection Law (LGPD, Law No. 13.709/2018). Under it, you have the right to:
- Access your data: all of it is visible inside the app itself.
- Correct incomplete, inaccurate or outdated data.
- Delete your data: deleting the app removes all local data. With an account, More → Account → Delete account erases what is on the server and the data on the device; what stays, and for how long, is in section 13. To request deletion of other data, get in touch.
- Portability: export your data as CSV or JSON in More → Export data and, with an account, what is on the server in More → Account → Export my data.
- Revoke consent at any time (including by signing out or deleting the account).
Legal bases (LGPD, art. 7): account, sync, export, deletion and the Pro subscription, performance of a contract; AI features, including the automatic summaries, consent; access logs, compliance with a legal obligation; security, fraud prevention, error reports and usage metrics, legitimate interest.
13. How to delete your account and data
To delete everything tied to your account:
- Open the app and go to More → Account.
- Tap Delete account and confirm.
What is erased: on the server, permanently, your account key, your synced records, your devices and your sessions; and on this device, your financial data. Encrypted copies in the hosting provider's backups can last up to 30 days, but they are unreadable without the key. An iCloud or Google Drive backup, if you have one, stays there and can be restored; to delete it, use your system settings.
What stays, and for how long: these records are tied to a pseudonymous identifier, not to your name or your login email (the email in a feedback message, if you gave one, stays with the message).
- Access logs (date, time and IP of logins, renewals, exports and the deletion itself): 6 months, as Brazilian law (Marco Civil da Internet) requires.
- App opens, usage counts and events: events for 13 months; daily counts become weekly after 90 days.
- AI usage (tokens and cost) and subscription events: no automatic deletion period today; we delete them on request.
- Feedback messages and survey answers: also no automatic period; we delete them on request.
- Error reports (Sentry): up to 90 days.
To delete what stays before those periods, or if you can't open the app, email contact@ggsalabs.software and tell us which login you use (Apple or Google); we reply within 15 days. Without an account, deleting the app erases everything on the device.
14. Your US privacy rights (California and other states)
This section applies to residents of California (California Consumer Privacy Act, as amended by the CPRA) and of other US states with similar laws. It supplements the rest of this policy.
What we collect, and from where. In the last 12 months, depending on how you use the app, we collected the following categories of personal information, all of it from you or your device:
- Identifiers: a login identifier (Apple or Google), your email when the provider shares it, your device name and push notification token, and a pseudonymous app identifier.
- Financial information you enter: accounts, entries, budgets, goals and similar data. It stays on your device unless you create an account, in which case an encrypted copy is synced to our server. We never ask for or collect bank logins or card numbers.
- Commercial information: your Pro subscription status, through RevenueCat.
- Internet or device activity: pseudonymous usage counts and events, and error reports, as described in sections 7 and 8.
- Messages you send us: suggestions, problem reports and survey answers (section 9).
Why we use it. To provide and sync the app, run the optional AI features you authorize, manage subscriptions, keep the service secure, fix errors, understand which features are used, and reply to you.
Who receives it. Only the service providers listed in section 5, for the purposes above.
We do not sell or share your personal information. We do not sell it, and we do not share it for cross-context behavioral advertising. The app has no advertising. We do not knowingly sell or share the personal information of anyone under 16. We do not use sensitive personal information to infer characteristics about you.
Your rights. You may:
- know what personal information we collect, use and disclose, and ask for a copy (including in a portable format);
- ask us to delete the personal information we collected from you;
- ask us to correct inaccurate personal information;
- opt out of the sale or sharing of personal information (not applicable, because we do neither);
- not be discriminated against for exercising any of these rights.
How to use them. Many of these are available in the app (export, delete account, turn off usage data). For anything else, email contact@ggsalabs.software from the address tied to your account, or tell us which login you use, so we can verify it is you. An authorized agent may make a request for you with your written permission. We will confirm receipt and respond within 45 days, and tell you if we need more time. If we decline a request, you may reply to appeal, and you may also contact your state attorney general.
California residents may also ask which categories of personal information we disclosed to third parties for their direct marketing: none.
15. Children
My Two Cents is not intended for people under 18 and does not knowingly collect data from minors. In particular, the app is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (US Children's Online Privacy Protection Act, COPPA). If you believe a child has provided data, email contact@ggsalabs.software and we will delete it.
16. International data transfers
Our company is in Brazil and our service providers are mainly in the United States. If you use the app from the United States, your information may be transferred to, stored and processed in Brazil and the United States.
17. Changes to this policy
We may update this policy. Significant changes will be announced in the app itself, and the date at the top shows the current version. We recommend reviewing it periodically.
18. Contact
Questions, data requests or exercise of rights:
GGSA Consultoria em TI Ltda.
contact@ggsalabs.software