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Privacy & data boundaries

Privacy, in plain English.

Your routines are personal. HabitTreasury is built around limited data use, separate choices and no sale of personal data.

Last updated: 10 November 2026 · English edition
Publisher and service providerFalnyomtató Kft.info@falnyomtato.com
01

Who controls your data

Falnyomtató Kft., the publisher of HabitTreasury, is the data controller for the personal data described in this Privacy Notice. You can contact us about privacy, data rights or this notice at info@falnyomtato.com.

This notice applies to the HabitTreasury website, account, habit and treasury features, Tully, optional AI drafts, billing and related support. It explains what we process, why, and the choices available to you.

02

The data we process

We aim to collect only what is needed to provide and protect the service. The data involved depends on which features you use.

  • Account data: your email address, authentication records, verification status, session information and account settings.
  • Your product content: habit names and definitions, cues, check-ins, rest or missed-day states, review content, keeper interactions and virtual treasury entries.
  • Billing data: plan, currency, subscription status, invoices, payment state and refund or cancellation records. Card details are handled by the payment provider; HabitTreasury does not need your full card number.
  • Technical and security data: timestamps, request and error logs, approximate device or browser information and security events needed to operate and protect the service.
  • Consent and preferences: the choices and notice versions for analytics, advertising, optional AI and marketing email.
  • Support correspondence: the information you choose to send when asking for help.

You do not need to disclose an ADHD diagnosis, other health information, client identities or calendar contents to use the core service. Please avoid putting confidential client information or unnecessary sensitive details into habit text, notes, chat or support requests.

03

Why we use it and our legal bases

Where UK or EU data-protection law applies, we rely on the following legal bases. The exact basis depends on the processing context.

PurposeLegal basis
Create and secure your account, provide the features you request and remember your choicesPerformance of a contract; legitimate interests in secure operation
Record your check-ins, treasury history, reviews and settingsPerformance of a contract
Process paid subscriptions, invoices, refunds and cancellationsPerformance of a contract; compliance with legal obligations
Prevent abuse, investigate faults and protect users and the serviceLegitimate interests in security and service integrity
Send service, security and billing messagesPerformance of a contract; legal obligations where applicable
Optional product analytics or advertising measurementYour separate, withdrawable consent where required
Optional external AI drafts or marketing emailYour separate, withdrawable consent or another basis explained at the choice point
Meet accounting, tax, consumer-protection and other legal dutiesCompliance with legal obligations

We do not sell personal data. We do not use habit content, health information or private keeper conversations to build advertising audiences.

04

Tully and optional AI

Tully’s core planning, check-in, return and review prompts can use local, human-written rules without calling an external AI provider. A local rule-based response is not presented as an AI-generated draft.

Personalised external AI drafts require a separate opt-in. When enabled, only the minimum approved server-side context needed for the requested draft should be sent to the selected provider. Passwords, full payment details, email addresses and another user’s records are not approved AI context.

You can accept, edit or dismiss a draft. AI cannot autonomously change a habit, ledger entry or subscription. You can withdraw AI consent for future optional processing in Settings. Withdrawing consent does not affect processing already lawfully completed.

HabitTreasury and Tully do not provide medical, therapeutic, crisis or medication advice.

05

Analytics, advertising and marketing

Optional analytics and advertising measurement have separate consent controls. We do not intentionally place optional analytics or advertising storage before the relevant affirmative choice where consent is required.

Habit names, notes, AI chat, email addresses, diagnoses, moods and calendar contents are prohibited from marketing analytics events and advertising platforms. A raw search query containing a health descriptor must not be copied into campaign URLs or event fields.

Marketing or onboarding email has its own opt-in. Withdrawing marketing consent does not stop necessary account-security, service or billing messages. You can use the unsubscribe or preference controls in an optional email, or contact us directly.

Essential storage needed for authentication, security and requested service operation is treated separately from optional analytics and advertising storage.

06

When data is shared

We share only the data needed for a specific service or legal purpose with providers acting under appropriate contractual and confidentiality obligations. Depending on the features used, these can include:

  • cloud hosting, database, backup and infrastructure providers;
  • authentication, transactional email and error-monitoring providers;
  • Stripe or the designated payment processor for checkout, billing, tax and refund operations;
  • the selected external AI provider, only after separate AI opt-in and only with the approved minimum context;
  • professional advisers, auditors or authorities where legally required or necessary to establish, exercise or defend legal claims.

Providers may only process personal data under their applicable role and terms. We do not permit an external provider’s access to imply ownership of your content. You can contact us for information about the providers relevant to your use of the service.

07

International transfers

Some service providers may process data outside the country where you live, including outside the European Economic Area or the United Kingdom. Where required, we use an approved transfer mechanism, such as an adequacy decision or appropriate contractual safeguards, and assess supplementary protections where necessary.

You may contact us for more information about the safeguard relevant to a particular transfer. We do not describe a transfer as local or restricted to a region unless the applicable provider configuration supports that statement.

08

How long we keep data

We keep personal data only for as long as needed for the purpose for which it was collected, including service delivery, security, dispute handling and legal obligations. Retention is assessed by data category rather than by keeping every record for one blanket period.

  • Account and product content is generally kept while your account is active so the service and history remain available.
  • When you delete content or your account, the relevant live records are deleted or anonymised without undue delay unless a specific legal, security or dispute-related ground requires limited further retention.
  • Billing, invoice, tax and accounting records may need to be retained for the periods required by applicable law.
  • Consent and suppression records may be retained as needed to demonstrate compliance and respect future opt-outs.
  • Security logs and backups are retained for limited operational cycles appropriate to their purpose, after which they are deleted or overwritten.

When retention ends, data is securely deleted, overwritten or anonymised so it no longer identifies you.

09

Your rights and controls

Depending on where you live and the applicable law, you may have rights to access, correct, delete, restrict or object to processing, receive a portable copy of your data, and withdraw consent. You may also have the right not to be subject to certain solely automated decisions with legal or similarly significant effects.

Free and Pro both include export and deletion controls. You can also contact info@falnyomtato.com to exercise a right. We may need to verify that a request concerns your own account. We respond within the period required by applicable law and explain if an exception applies.

Withdrawing consent does not make earlier consent-based processing unlawful. Returning from Pro to Free does not remove export, deletion or access to your existing history.

10

Security, complaints and updates

Security

We use organisational and technical measures appropriate to the service, including authenticated access controls, scoped server-side data access and protections for account and billing operations. No online service can promise absolute security, but we investigate suspected incidents and provide notices where legally required.

Complaints

Please contact us first if you have a concern so we can investigate. You may also complain to your local data-protection authority. In Hungary, this is the National Authority for Data Protection and Freedom of Information (NAIH). If you live elsewhere in the EEA or in the UK, you can normally approach the authority in your country of residence or workplace, or where you believe an infringement occurred.

Changes to this notice

We update this notice when the service, providers or legal requirements change. We publish the revised date on this page and provide a more prominent notice when a change requires it. Related contractual terms are in our Terms of Service.