Legal · Freelancer Income Stabilizer

Privacy Policy

Last updated: April 2026 Effective date: April 2026

1. Data We Collect

1.1 Data That Stays on Your Device (We Never See This)

The following data is stored locally on your device only. It is never transmitted to our servers or any third party:

• Income records and earnings entries
• Expense records
• Invoice data
• Income forecasts and projections
• Any other financial data you enter into the app

This data is stored using your device's local storage and iOS Keychain. Only you can access it. We have no copy of it.

1.2 Outreach Generation Feature

The Generate Outreach feature requires you to provide your own OpenAI API key. This key is:

• Entered by you directly in the app
• Stored exclusively on your device using the iOS Keychain (Apple's secure credential storage)
• Never transmitted to us or any server we control
• Used solely to authenticate requests you initiate to OpenAI's API

When you tap Generate, the app sends the following directly from your device to OpenAI's servers using your own API key:

• The service type you enter
• The target client description you enter
• The tone preference you select

We never see, access, store, or transmit your OpenAI API key or your outreach inputs. The entire transaction is between your device and OpenAI directly.

Your OpenAI API usage is subject to OpenAI's pricing and billed directly to your OpenAI account. We have no involvement in that relationship.

Important: Please do not enter the full name of a specific individual in the target client field. Use a role or company type instead (e.g. "marketing manager at a SaaS startup"). This protects the privacy of third parties.

1.3 Push Notification Token

If you grant permission for push notifications, your device generates a push notification token. This token is:

• Managed by Apple's Push Notification service (APNs)
• Stored locally on your device
• Used solely to deliver notifications you have requested (e.g. income logging reminders)
• Not accessible to us on any server

2. Legal Basis for Processing (GDPR)

We are based in Romania and are subject to the EU General Data Protection Regulation (GDPR). Our legal bases for processing are:

3. International Data Transfers

When you use the Generate Outreach feature, your outreach inputs are transferred to the United States where OpenAI's infrastructure is located.

This transfer is protected by EU Standard Contractual Clauses (SCCs) pursuant to GDPR Article 46(2)(c), incorporated through our Data Processing Agreement with OpenAI.

4. Third-Party Services

We use one third-party service:

OpenAI, L.L.C.

• Purpose: Processing outreach generation requests
• Data shared: Service type, target client description, and tone preference (only when you tap Generate)
• Location: United States
• Privacy Policy: https://openai.com/privacy
• Data Processing: OpenAI processes API data in accordance with their API data usage policies. By default, OpenAI does not use API inputs to train their models.

We have no advertising SDKs, analytics services, crash reporting tools, or any other third-party trackers in this app.

5. Data Retention

6. Your Rights

Under GDPR (and equivalent laws in other jurisdictions), you have the following rights:

How to exercise your rights

• Locally stored data: use Settings → Delete All My Data in the app.
• Data processed by OpenAI: contact us at contact@stropapps.com and we will facilitate your request with OpenAI, or contact OpenAI directly at privacy@openai.com.
• All other requests: contact us at contact@stropapps.com. We will respond within 30 days.

7. Supervisory Authority

If you are located in the European Union and believe we have not handled your data lawfully, you have the right to lodge a complaint with your local data protection authority.

• Romania: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP) — www.dataprotection.ro
• United Kingdom: Information Commissioner's Office (ICO) — ico.org.uk
• Other EU member states: Your national data protection authority — edpb.europa.eu

8. Children's Privacy

This app is intended for users aged 18 and older. It is not directed at children or minors. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, do not use this App. If we become aware that a person under 18 has provided data through this App, please contact us at contact@stropapps.com and we will take steps to delete that information promptly.

9. Cookies and Tracking

This app does not use cookies, web beacons, pixel tags, device fingerprinting, or any other tracking technologies. We do not track you across apps or websites.

10. Data Security

We take the security of your data seriously:

• All local data is stored using iOS-native security mechanisms (Keychain for sensitive data, encrypted local storage)
• All communications with OpenAI's API are encrypted using HTTPS/TLS
• Your OpenAI API key is stored exclusively in the iOS Keychain on your device. It is never transmitted to us. API requests are made directly from your device to OpenAI using your own credentials.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via an in-app notification. The "Last updated" date at the top of this page will also be revised.

Your continued use of the app after changes are posted constitutes your acceptance of the updated policy. If you do not agree with the changes, please stop using the app and delete it from your device.

12. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

This Privacy Policy is available in English. For users in Romania, a Romanian-language version can be requested by contacting us.