Terms, Privacy and other notices

Dividiamo ("the Service", "the App", "we") is a free web app (PWA) to record and split shared expenses among couples, flatmates, friends and travel groups. The Service is a non-commercial personal project offered by Matteo Aldi, natural person, as owner and developer.

Contact

info@dividiamo.app

Nature

Free personal project, non-professional

Governing law

Italian law

The owner's full identifying details (residential address, tax code) are available upon written request to the email above, for legitimate purposes under GDPR.

2.1 Subject matter

The Service lets you record, split and keep track of shared expenses. It is provided "as is" and "as available", without guarantees of continuity, accounting accuracy or fitness for a particular purpose.

2.2 Acceptance

By signing up or using the Service you declare you have read and fully accepted these legal notices. If you do not intend to accept them, do not use Dividiamo.

2.3 Age requirement

The Service is reserved for people aged at least 16. If we become aware of an account held by a minor, we will delete it.

2.4 Account and security

To use the Service you must provide a valid email and a secure password, or sign in via a third-party provider (Google). You are solely responsible for the confidentiality of your credentials and the activity carried out through your account. In case of unauthorised use, contact us immediately.

2.5 Acceptable use

You agree not to:

• use the Service for illegal, fraudulent or third-party harmful purposes;
• upload offensive, defamatory, pornographic, discriminatory content or content protected by third-party rights;
• circumvent security measures, decompile or reverse engineer;
• send spam, malware or perform unauthorised scans;
• invite people without their consent to the processing of their personal data.

2.6 User content

You retain ownership of the content you upload (expenses, notes, receipts, profile photo, group covers). You grant the owner a limited, free, non-exclusive licence, strictly necessary to provide the Service (storage and syncing between your devices and members of the groups you join). You are responsible for the lawfulness of the content and for respecting the privacy of other members.

2.7 Non-professional nature

Splits, balances and debt-simplification calculations are provided as a personal aid and do not constitute financial, tax, legal or accounting advice. The owner is not a party to the financial relationships between users and does not manage, hold or transfer money.

2.8 Availability and changes

The Service may be suspended, modified or discontinued at any time, even without notice, for maintenance, updates or project shutdown. Where possible we will notify you through the app or via email.

2.9 Limitation of liability

As a free service provided on a personal basis, to the maximum extent permitted by law the owner is not liable for indirect damages, loss of data, lost profits or disputes between users arising from use of the Service. Nothing in these notices excludes or limits liability for wilful misconduct or gross negligence, nor the mandatory rights recognised to consumers.

2.10 Account closure

You can delete your account at any time from the Profile section. The owner may suspend or close accounts that violate these notices, with prior notice where reasonably possible.

2.11 Governing law and venue

These Terms are governed by Italian law. For disputes with users qualifying as consumers, the court of the consumer's place of residence or domicile in Italy has exclusive jurisdiction (Legislative Decree 206/2005 — Consumer Code).

Drafted pursuant to Articles 13-14 of EU Regulation 2016/679 ("GDPR") and Italian Legislative Decree 196/2003 as amended.

3.1 Data controller

The data controller is Matteo Aldi, natural person. Contact for privacy and support: info@dividiamo.app. No DPO has been appointed, as the legal thresholds (art. 37 GDPR) do not apply.

3.2 Categories of data processed

• Account data: email, encrypted password managed by the auth provider, display name, profile photo.
• Usage data: expenses, groups, balances, deposits and withdrawals of the joint account, budgets, goals, trips.
• Uploaded content: receipts, profile photos, group covers, notes. "Personal Space" notes are visible only to you.
• Technical data: IP address, user agent, system logs, access timestamps, session identifiers.
• Optional data: monthly income (for income-proportional splits), push notification tokens (collected only when the feature is enabled in a future release).

We do not knowingly process special categories of data (art. 9 GDPR). Please do not include such data in notes or receipts.

3.3 Purposes and legal bases

3.4 Processing methods

Data is processed with electronic tools and appropriate technical and organisational security measures: TLS encryption in transit, access control, database-level Row Level Security, optional two-factor authentication.

3.5 Recipients and sub-processors

To provide the Service we rely on the following suppliers, appointed as processors under art. 28 GDPR:

• Supabase, Inc. / Lovable Cloud — database hosting, authentication, storage, serverless functions (EU servers).
• Cloudflare, Inc. — CDN, DDoS protection, edge functions.
• Google LLC — only if you choose "Continue with Google" (OAuth) and/or enable in the future push notifications via Firebase Cloud Messaging (feature not yet released).
• Frankfurter (frankfurter.app) — read-only request for ECB public exchange rates; receives no personal data.
• Transactional email provider — sends confirmation, password reset and verification code emails.

Data is not sold to third parties for commercial purposes and is not used for advertising profiling.

3.6 Data shared with other users

When you join a group or invite someone, your profile (display name, avatar) and the expenses you enter in the group become visible to other members, for the Service to work. The "Personal Space" remains private and is never shared.

3.7 Non-EU transfers

Some sub-processors may transfer data outside the EU. Adequate safeguards are in place: Standard Contractual Clauses of the European Commission and, where applicable, adherence to the EU-US Data Privacy Framework.

3.8 Retention period

• Account and content: for the entire duration of the account.
• Deleted items (trash): up to 30 days.
• Technical and security logs: up to 12 months.
• Monthly closures of the joint account: immutable history for as long as the account is active.
• After account deletion: profile is anonymised ("Deleted user"); expenses in shared groups remain visible to other members to preserve balance integrity, without identifying references.

3.9 Data subject rights

Under articles 15-22 GDPR you have the right to:

• access your data and receive a copy (portability);
• request rectification or erasure;
• request restriction or object to processing;
• withdraw consent, without affecting the lawfulness of prior processing;
• lodge a complaint with the Italian Data Protection Authority.

Many rights are already exercisable directly from the app (edit profile, CSV export, account deletion). For further requests write to info@dividiamo.app.

3.10 Minors

The Service is not intended for children under 16. We do not knowingly collect data of minors.

Dividiamo uses exclusively cookies and localStorage that are technical and strictly necessary for the Service to work:

• authentication session;
• theme preferences (light/dark/automatic);
• offline app state (Service Worker/PWA);
• anti-abuse and security tokens.

We do not use profiling cookies, advertising trackers or third-party analytics tools. For this reason no consent banner is required under the Italian DPA Guidelines of 10 June 2021.

If we introduce analytics or marketing tools in the future, this section will be updated and a compliant consent banner will be shown.

Some future features may use AI models (e.g. automatic expense category recognition, receipt data extraction, budget suggestions). When active:

• data sent to the models will be limited to the minimum necessary for the requested feature;
• we will not use your data to train third-party models without your explicit consent;
• AI-generated results are suggestions and may contain errors: it is up to you to verify them before acting on them;
• you will be able to disable AI features from settings, where available.

Dividiamo is currently entirely free and requires no mandatory purchase. Should premium features, one-off purchases or subscription plans be introduced in the future, the following rules will apply, in addition to the terms of the distribution store used.

6.1 Pre-contractual information

Before each purchase we will clearly display: price including VAT, currency, offer content, duration, any free trial period, price after the first period, renewal conditions and cancellation methods, in accordance with the Italian Consumer Code (Legislative Decree 206/2005) and Directive 2011/83/EU.

6.2 Auto-renewing subscriptions

Subscriptions renew automatically at the end of each period (weekly, monthly or yearly) at the same price, unless cancelled. You may cancel at any time: renewal will stop and you will be able to use the premium Service until the end of the period already paid. No pro-rata refund is issued for the remaining period unless otherwise required by law.

6.3 Free trials

Where offered, free trials automatically convert to a paid subscription at the end, unless cancelled at least 24 hours before expiry in accordance with the rules of the store used for purchase.

6.4 Right of withdrawal (EU consumers)

Under arts. 52 ff. of the Italian Consumer Code you have 14 days to withdraw from a distance contract for digital content. By requesting immediate performance of the premium Service and expressly acknowledging the loss of the right of withdrawal, you accept that once the service begins the right of withdrawal is no longer exercisable, as provided by art. 59 letter o) of the Italian Consumer Code.

6.5 Price changes

Any price increases will be communicated at least 30 days in advance by email or in-app notification. If you do not accept the new price you may cancel the subscription free of charge before the changes take effect. Continued use after that date constitutes acceptance.

6.6 Refunds

Refund requests for purchases made through the App Store or Google Play are handled directly by Apple or Google under their respective policies; the Service owner has no direct refund power over such purchases. For web purchases contact info@dividiamo.app: we will assess the request on a case-by-case basis within legal limits.

6.7 Payment providers

Payments are processed exclusively by qualified third-party providers (Apple, Google, Stripe or equivalent PCI-DSS compliant providers). The owner does not store full card data and has no access to payment credentials; from providers we only receive information necessary to reconcile the purchase (transaction ID, outcome, amount).

6.8 Invoicing

Receipts or invoices are made available by the payment provider and, where applicable, also in-app or via email. For invoices with an Italian VAT number or business heading, write to info@dividiamo.app before purchase.

If you access Dividiamo through a version distributed by an application store (Apple App Store, Google Play or others), the terms of use and purchase conditions of that store apply in addition to these notices.

7.1 EULA and Apple's role (iOS, iPadOS, macOS, watchOS, visionOS users)

These terms constitute the end-user licence agreement ("EULA") between you and the Service owner; Apple is not a party to that agreement. You further acknowledge that:

• the licence is limited to a non-transferable use on the Apple-branded devices you own or control, as specified in the App Store Usage Rules;
• Apple has no obligation whatsoever to furnish any maintenance or support services with respect to the Service;
• in the event of any failure of the Service to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the Service (if applicable); to the maximum extent permitted by law, Apple will have no other warranty obligation whatsoever with respect to the Service;
• any claims relating to the Service, its performance or non-conformity, or the infringement of third-party rights (including product liability, statutory or consumer-protection requirements) are the sole responsibility of the owner and not of Apple;
• in case of third-party claims that the Service or your use infringes intellectual property rights, such claims must be addressed to the owner;
• you represent that you are not located in a country subject to a U.S. Government embargo or that has been designated as a "terrorist supporting" country, and that you are not listed on any U.S. Government list of prohibited or restricted parties;
• Apple and its subsidiaries are third-party beneficiaries of this EULA and, upon your acceptance, will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third-party beneficiary.

7.2 Google Play (Android users)

Android users are also bound by Google Play's terms. In-app purchases are subject to Google's policies; Google is not a party to the contract between you and the Service owner.

7.3 In-app purchases and store account management

In-app purchases made through the stores follow the refund, cancellation, purchase restoration and account management rules provided by Apple or Google. Use the settings of the relevant store to manage or cancel subscriptions.

Dividiamo currently contains no advertising of any kind: no banners, no native ads, no sponsored promotions, no sharing of data with ad networks or data brokers.

Should advertising be introduced in the future, the following rules will apply:

• ads will be clearly identifiable as such under Legislative Decree 145/2007 and the AGCM advertising guidelines;
• we will prioritise non-profiling formats (contextual ads based solely on language or type of page content) that do not require user tracking;
• any profiled ads will be shown only after explicit, informed and specific user consent, via a banner compliant with the Italian Data Protection Authority's Guidelines of 10 June 2021 and, where applicable, the IAB TCF framework; consent may be withdrawn at any time from settings;
• on Apple devices, ATT (App Tracking Transparency) consent will be requested before any cross-app or cross-site tracking;
• Premium users (where available) may enjoy an ad-free experience as part of the plan;
• ads will not be shown to users identified as under 16;
• the list of advertising partners will be published in this section upon actual activation, as data processors under art. 28 GDPR.

This section will be updated when advertising is actually introduced, with in-app notice and email to registered users.

We adopt reasonable technical and organisational security measures: TLS, role-based access control, database-level Row Level Security, optional two-factor authentication, soft-delete trash.

If you discover a security vulnerability, please report it confidentially to info@dividiamo.app before disclosing it publicly, in the spirit of responsible disclosure. We commit to responding within a reasonable time and to fixing critical vulnerabilities as soon as possible.

The "Dividiamo" trademark, logo, design and non-public source code are the property of the owner. Reproduction without written authorisation is prohibited.

If you believe that content published through the Service infringes your right (copyright, trademark, image, privacy), write to info@dividiamo.app stating: (i) your contact details, (ii) the disputed content and its location, (iii) the right you believe has been infringed, (iv) a good-faith statement. We will promptly carry out the necessary checks.

We work to make Dividiamo accessible to everyone, following as much as possible the WCAG 2.1 AA guidelines (contrast, keyboard, screen reader, tap targets ≥44px). If you encounter barriers report them to info@dividiamo.app: we commit to reviewing them and improving the experience.

These notices may be updated. Material changes will be highlighted through the app or via email. Continued use of the Service after the publication of changes constitutes acceptance of them.

Last updated: 18 July 2026.

For any request regarding these notices, privacy or the Service in general, write to info@dividiamo.app. We respond within a reasonable time, compatibly with the personal nature of the project.