Privacy Policy

1. About this policy

This policy explains how SPEND PILOT LTD collects, uses, shares and protects your personal data when you use the SpendPilot mobile application for iOS and Android, the SpendPilot website at spendpilot.co.uk, the early access waitlist, and any related services (together, the "Service").

SpendPilot helps you set a weekly or monthly grocery budget, builds a meal plan and shopping list that fits inside it, compares the cost of that list across UK supermarkets, and shows you where to buy the ingredients. To do that we need some information about your household, your budget and what you eat. Some of that information, for example allergies or religious dietary requirements, is treated by law as more sensitive, and we explain how we handle it below.

Please read this policy alongside our Dietary and Health Data Notice, our AI Transparency Notice and our Cookie Policy.

2. Who we are

SPEND PILOT LTD is the data controller for your personal data.

"We", "us" and "our" mean SPEND PILOT LTD. "You" and "your" mean the person using the Service.

SpendPilot launches first in the United Kingdom. We have not appointed a representative under Article 27 of the EU GDPR, as the Service is not yet offered in the European Economic Area. We will appoint one, and update this policy, before any EEA launch.

3. The short version

• We collect what we need to run the Service: your account details, household size, budget, postcode, dietary selections, and the plans, lists and spending you create.
• We never ask for your bank login, connect to your bank account, or handle your payment card. Your spend is what you type in.
• Your dietary selections are processed only with your explicit consent, and you can use SpendPilot without them.
• We use OpenAI to generate meal plans and swap suggestions. We do not let any AI provider train on your data.
• We do not sell your personal data and we do not show advertising.
• Your data is hosted in Germany. A small number of providers in the United States receive limited data under lawful transfer safeguards.
• You can see, export, correct and delete your data from inside the app or by emailing [email protected].

4. The data we collect

What we do not collect

• Bank credentials, bank account or card details, or any transaction feed from your bank. SpendPilot has no bank connection.
• Precise GPS location. We use the postcode you give us.
• Your name or contact details from any supermarket.
• Data from other apps on your device.

5. Sensitive information about your diet

Some dietary selections tell us about your health, for example a nut allergy, coeliac disease, diabetes or a weight goal. Others, such as halal or kosher, can reveal religious belief. The law calls this special category data and we treat it with extra care:

• We process it only with your explicit consent, which we ask for on a dedicated screen before you can select any dietary requirement.
• You can use SpendPilot without giving this consent. Your plans will not be filtered for diet.
• You can withdraw consent at any time in Settings > Privacy > Dietary data. Withdrawing deletes your dietary selections and stops any further processing of them.
• We use these selections for one purpose only: to build plans, lists and swaps that fit your requirements. We do not use them for marketing, we do not sell them, and we do not share them with supermarkets.
• We do not try to infer your religion, ethnicity or medical conditions from your selections. We use the selection as a food filter and nothing more.

The Dietary and Health Data Notice sets this out in full.

6. How we use your data and our lawful bases

Where we rely on legitimate interests we have assessed that our interest does not override your rights. You can ask for a copy of any assessment by emailing [email protected].

We do not use your personal data for advertising, and we do not build profiles of you for anyone but you.

7. How AI is used

SpendPilot uses artificial intelligence, provided by OpenAI, to turn your budget, household size, dietary selections and food preferences into a meal plan, and to suggest cheaper swaps when your basket goes over budget.

• We send OpenAI only what the planner needs: your budget, household size, number of meals, dietary and food preference selections, and the items in your plan or list. We do not send your name, email address, postcode or account identifiers. [CONFIRM AGAINST THE PROMPT ACTUALLY SENT]
• OpenAI acts as our processor. Under OpenAI's published API terms, data sent through the API is not used to train OpenAI's models. SpendPilot has a zero data retention arrangement in place with OpenAI, so no data is cached or retained after the response is returned.
• Every plan and swap is a recommendation. You decide what goes in your basket and what you buy. No decision that has a legal or similarly significant effect on you is made solely by automated means.
• Prices, budget health scores and "safe to spend" figures are calculated from what you enter and from the prices we fetch. They are estimates, not financial advice.

See the AI Transparency Notice for more detail.

8. Who we share your data with

We do not sell your personal data. We share it only as follows.

Service providers (processors)

Companies that process data on our behalf, under contracts that require them to protect it and to act only on our instructions. The current list, with locations and purposes, is at Sub-processor List. In summary:

• Hosting in Germany for our servers and database.
• OpenAI for meal plan and swap generation.
• Google Analytics and Microsoft Clarity for understanding how the website and app are used, only with your consent.
• Apple and Google for app distribution and push notification delivery. Google also for sign-in and authentication, via Firebase Authentication (email/password and Google sign-in).
• An email provider for service and waitlist emails.

Supermarkets

SpendPilot is independent of every supermarket. We do not share your account, identity or dietary data with any of them.

To compare prices we collect publicly displayed prices from supermarket websites at the time you make a request, using automated tools. Those requests contain only the product searches needed to price your list. They do not contain your postcode, name, email address or account details.

When you tap through to a supermarket, you leave SpendPilot. The supermarket's own privacy policy and terms then apply.

Others

• Professional advisers such as lawyers, accountants and insurers, under confidentiality.
• Regulators, courts and law enforcement where the law requires or permits.
• A buyer or successor if we sell, merge or reorganise the business. Your rights will not be reduced and we will tell you before your data is transferred.

9. International transfers

Your data is stored on servers in Germany. Some of our providers are based in, or have staff in, the United States. Where personal data leaves the United Kingdom or the European Economic Area we rely on:

• the UK Extension to the EU-US Data Privacy Framework, or the EU-US Data Privacy Framework, where the recipient is certified; or
• the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment.

You can request a copy of the safeguards that apply to a particular transfer by emailing [email protected].

10. How long we keep your data

When you delete your account we delete or irreversibly anonymise your personal data as set out above. Anonymised statistics, which cannot identify you, may be kept to improve the Service.

11. Security

We protect your data with encryption in transit and at rest, access controls that limit staff access to what their role requires, logging and monitoring, and regular backups. [CONFIRM MEASURES THAT ARE IN PLACE TODAY] No system is completely secure. If a breach affects your data and is likely to put your rights at risk we will tell you and the relevant regulator as the law requires.

If you find a security problem, please tell us: see our Responsible Disclosure Policy.

12. Your rights

You have the right to:

• access the personal data we hold about you;
• correct data that is wrong or incomplete;
• delete your data (the "right to be forgotten");
• restrict how we use your data in some situations;
• receive a copy of the data you gave us in a portable format, and have it sent to another provider where feasible;
• object to processing based on legitimate interests, and to any direct marketing at any time;
• withdraw consent at any time where we rely on it, including for dietary data, marketing and analytics;
• not be subject to a decision based solely on automated processing that has legal or similarly significant effects on you, and to ask for human review;
• complain to us, and to the Information Commissioner's Office or, in the EEA, your national data protection authority.

The quickest way to exercise most rights is inside the app: Settings > Privacy. You can also email [email protected]. Full details, timelines and a request template are at Your Data Rights.

13. Children

SpendPilot is for adults. You must be at least 18 to create an account. We do not knowingly collect personal data from anyone under 18. Household size may tell us that children live in your home; we use that only to size your plan and we do not collect names, ages or any other details about them. See the Children and Age Policy.

14. Cookies and similar technologies

The website and app use cookies and similar technologies. Details, including how to give and withdraw consent, are in the Cookie Policy.

15. Links to other sites

The Service links to supermarket websites and may link to other third-party sites. We are not responsible for their content or their handling of your data.

16. Changes to this policy

We may update this policy from time to time. If a change is material we will tell you in the app or by email before it takes effect. The date and version number at the top show the current version, and we keep earlier versions available on request.

17. Contact and complaints

You have the right to complain directly to us and we will acknowledge your complaint within 30 days and respond without undue delay. You also have the right to complain to the Information Commissioner's Office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone 0303 123 1113, ico.org.uk. If you are in the EEA you may complain to your national data protection authority.