Privacy Policy

This privacy policy for Kade Gray, operating as Ibexel ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://budget.ibexel.com, or any website of ours that links to this privacy policy
• Download and use our application, ibexel Budget, or any other application of ours that links to this privacy policy
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of Key Points

This summary provides key points from our privacy policy, but you can find out more details about any of these topics in the full sections below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us. Specifically, we collect your name, email address, and country of residence for account creation. All financial and budget data you enter into the app is end-to-end encrypted and can only be read by you.

Do we process any sensitive personal information? Your financial and budget data is end-to-end encrypted on your device. We do not have the ability to access, read, or process this data. We do not process other categories of sensitive personal information.

Do we receive any information from third parties? We do not receive any information about you from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

How do we keep your information safe? We have organizational and technical processes in place to protect your personal information, including end-to-end encryption of your financial data. However, no electronic transmission over the internet can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights? The easiest way to exercise your rights is by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Do We Use Cookies and Other Tracking Technologies?
6. How Long Do We Keep Your Information?
7. How Do We Keep Your Information Safe?
8. Do We Collect Information from Minors?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do United States Residents Have Specific Privacy Rights?
12. Do Other Regions Have Specific Privacy Rights?
13. Do We Make Updates to This Policy?
14. How Can You Contact Us About This Policy?
15. How Can You Review, Update, or Delete the Data We Collect from You?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, specifically your name and email address. All financial and budget data is end-to-end encrypted and only accessible by you.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include:

• Name
• Email address
• Country of residence (collected at registration to identify applicable privacy rights)
• Account login credentials (passwords are hashed and never stored in plain text)

Encrypted Financial Data. All financial and budget data you enter into ibexel Budget is end-to-end encrypted on your device before being transmitted to our servers. This means:

• We cannot read, access, or process your financial data
• Only you hold the encryption keys to decrypt your data
• Your budget entries, transaction records, and financial information remain private and accessible only to you

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• Account Management. We process your name and email address to facilitate account creation, authentication, and account management.
• Service Delivery. We process your information to provide you with the requested service. Note that your encrypted financial data is stored but never processed or read by us.
• Customer Support. We process your information to respond to your inquiries and solve any potential issues you might have.
• Administrative Communications. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• Security and Fraud Prevention. We may process your information as part of our efforts to keep our Services safe and secure.
• Service Improvement. We may process information about how you use our Services to better understand usage patterns and improve our products.
• Legal Compliance. We may process your information to comply with applicable legal obligations.
• Vital Interests. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Personal Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada:

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If the information is publicly available and is specified by the regulations

4. When and With Whom Do We Share Your Personal Information?

In Short: We do not share your personal information with third parties, except where required by law.

We will never provide your personal information to third parties other than where we are required to do so by law, such as to comply with a court order, legal obligation, or government authority request.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We use a single cookie solely to keep you logged in. We do not use any tracking technologies.

We use one session cookie for authentication purposes — this is what keeps you logged in to your account. We do not use cookies or any other technologies (such as web beacons or pixels) to track your behaviour, serve advertising, or collect analytics.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your end-to-end encrypted financial data will be deleted when you delete your account. Since we cannot read this data, we simply remove the encrypted data from our servers.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures, including end-to-end encryption.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Key measures include:

• End-to-End Encryption. All financial and budget data you enter into ibexel Budget is encrypted on your device before transmission. We never have access to your unencrypted financial data.
• Password Security. Your account passwords are cryptographically hashed and never stored in plain text.
• Secure Transmission. All data transmitted between your device and our servers is encrypted in transit using industry-standard protocols.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. What Are Your Privacy Rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.

You can make such a request by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at [email protected]. However, please note that this will not affect the lawfulness of the processing before its withdrawal.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at [email protected].

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account
• Contact us at [email protected]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of certain U.S. states, you may be granted specific rights regarding access to your personal information.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have specific rights regarding your personal information under applicable state privacy laws.

Your rights may include:

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of your personal data
• Right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling

Categories of personal information we collect:

• Identifiers: Name, email address, IP address, account name, country of residence
• Internet or similar network activity: Browsing history, search history, and interactions with our website and application
• Geolocation data: Approximate location based on IP address

We do not sell personal information to third parties. We do not process personal information for targeted advertising.

We do not process sensitive personal information. Your financial data is end-to-end encrypted and we cannot access it.

California Residents — Shine The Light Law: California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for direct marketing purposes.

To exercise any of these rights, you can contact us by email at [email protected]. We will respond to your request in accordance with applicable law.

Right to Appeal: If we decline to take action regarding your request, we will inform you of our decision and reasoning. If you wish to appeal, please email us at [email protected].

12. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. At any time, you have the right to request access to or correction of your personal information by contacting us at [email protected].

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, or for a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information by contacting us at [email protected]. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the Information Regulator (South Africa) at [email protected].

European Economic Area, UK, and Switzerland

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

13. Do We Make Updates to This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may email us at:

[email protected]

Or by post to:

Kade Gray
Operating as Ibexel

15. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at [email protected].

Please note that because your financial and budget data is end-to-end encrypted, we cannot provide you with a copy of that data — it is only accessible to you directly through the ibexel Budget app. Upon account deletion, all encrypted data will be permanently removed from our servers.