Политика за поверителност

At Colibre, we value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use our AI-driven app for personalized financial advice. Colibré

processes personal data in accordance with the General Data Protection Regulation (GDPR), Bulgarian data protection laws, and other applicable regulations. We are dedicated to transparency and providing you with clear information about your data rights. If you have any questions or concerns, please contact us at colibre.comp@gmail.com .

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the 'Last updated' date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the App or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

Data collection

How do we collect information?

Creating an account and signing up for Colibré requires an email address and personal information. All information used is user-inputted and the Service does not operate via automated tracking across other websites or applications.

What information do we collect?

Personal information: Name, email address, date of birth, nationality.
Financial statements: Bank account details, transaction history, income, expenses.
Behavioral data: Spending habits, saving goals, user engagement.
Device and Technical data: IP address, browser type and device identifier.

Information used for our AI features is collected from various sources such as public financial portals, news, media, and articles, as well as Application Programming Interfaces (APIs). No data collected from the certain user is shared publicly or used for our Service for any other customers, excluding the certain user.

2. Legal Basis for Processing

Methods of data collection and processing are in accordance with all of the necessary laws for data protection from the European Union.

General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
EU Artificial Intelligence Act
Payment Services Directive 2 (PSD2) (Directive (EU) 2015/2366)
Markets in Financial Instruments Directive II (MiFID II) (Directive 2014/65/EU)
Consumer Protection Laws (Directive 2019/2161 and others)
ePrivacy Directive (Directive 2002/58/EC) (Pending ePrivacy Regulation)
NIS2 Directive (Directive (EU) 2022/2555)

We comply with all applicable legal requirements for anti-money laundering, delivering app services, and fraud prevention.

We offer full transparency for all algorithmic models implemented and those algorithms use only the necessary data.

3. Purpose of Data Collection

We use your personal data for the following purposes:
Personalized Financial Advice: Generating AI-driven insights based on your financial behavior and goals.
Behavioral Analysis: Identifying spending patterns and providing tailored recommendations.
Service Delivery: Managing user accounts, processing transactions, and providing app functionality.
Customer Support: Responding to inquiries, troubleshooting issues, and enhancing user experience.
Data Analytics and Improvements: Analyzing user behavior to improve our AI models and app features.
Compliance: Meeting legal and regulatory obligations, including fraud prevention and data security.
Marketing (with Consent): Sending promotional materials, newsletters, and personalized offers.

4. Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your confidential information entered into our app.

Colibré or its parts may integrate or otherwise include third-party services for purposes such as login or relevant data for our AI features. By using our services, you acknowledge that fact and also other terms and conditions than these Terms may apply to your use of such third-party services (including privacy policies) and that we do not guarantee availability of such services and content. You must agree and comply with any applicable third-party terms when using Colibré.

5. Data security

We implement robust security measures to protect your personal data from unauthorized access, loss, or misuse, including:

Encryption: All sensitive data is encrypted during transmission and storage.

Access Controls: Restricted access to personal data on a need-to-know basis.

Regular Security Audits: Periodic assessments to identify and address vulnerabilities.

Despite these efforts, no system can be completely secure, and users are responsible for maintaining the confidentiality of their account credentials.

Colibré stores your data securely on servers located within the European Economic Area (EEA) or other regions with adequate data protection measures. We retain your data only as long as necessary for the purposes outlined in this policy:

Account Information: Retained for the duration of your account and for a limited period thereafter as required by law.

Financial Data: Retained as long as necessary to provide personalized advice and comply with legal obligations.

Anonymized Data: Retained indefinitely for analytical and research purposes.

Data is securely deleted or anonymized when no longer needed.

6. User rights

Under GDPR and all other relevant laws, users have the following rights:

Right to access your personal data
Right to correct inaccurate or incomplete data
Right to request deletion of your personal data (subject to legal exceptions)
Right to data portability
Right to request limited processing of your personal information
Right to object data processing for AI-driven purposes
Right to withdraw consent without affecting the lawfulness of prior processing
Right to file a complaint

When you sign up for Colibré, you provide explicit consent for data processing related to personalized financial advice and AI-driven insights. You can manage or withdraw your consent at any time through the app’s settings. Note that withdrawing consent may limit certain functions of the app.

Colibré is intended for use by individuals who are 16 years of age or older. We do not knowingly collect or process personal data from minors without verifiable parental or guardian consent. If we become aware that we have inadvertently collected personal data from a child under 16, or the guardian or parental consent is falsified, we will take immediate steps to delete that information.

Parents or guardians who believe that their child under 16 has provided personal information to Colibré without their consent should contact us at colibre.comp@gmail.com, and we will promptly address the issue.