Legal
Shillings privacy policy
Shillings holds a detailed picture of your working life and your money. This explains exactly what we keep, why we keep it, and what you can make us do about it.
Who we are
Neirfeno Limited is the data controller for the personal data described in this policy. That means we decide what is collected and why, and we are the ones answerable for it.
| Who runs Shillings | Neirfeno Limited |
|---|---|
| Company number | SC514019, registered in Scotland |
| Registered office | 7 Thorter Way, Dundee, DD1 3DF |
| Support and data protection | support@getshillings.com |
| ICO registration | ZB673603 |
This policy covers the Shillings mobile app on iOS and Android, and this website. It should be read alongside our terms and conditions.
What we collect
Your account
You sign in with Google or with Apple. We receive an account identifier and your email address from whichever you use. If you use Sign in with Apple and choose to hide your email, we receive Apple's relay address instead of your real one, and that is all we ever see.
We do not operate passwords for Shillings, so we never hold one.
What you enter into the app
This is the substance of Shillings, and it is the most revealing data we hold about you:
- Your income streams and the jobs they come from, including employer or client names where you enter them.
- Pay rates, pay dates and pay cycles.
- Shifts you have worked and shifts you are down to work, with their dates, times and hours.
- Savings goals and progress towards them.
- Anything else you type into a note or a label.
Taken together this describes what you earn, who you earn it from and when it arrives. We treat it accordingly. It is not shared with employers, not shared with lenders, not used for credit scoring, not used for advertising, and not sold. It is not special category data under Article 9 of the UK GDPR, but we hold it to the standard the sensitivity deserves.
Your device
The app stores a copy of your data on your own device so it works without a connection, using your device's own storage. That copy is under your control and is removed when you uninstall the app.
We also collect technical information through Google Analytics for Firebase: app version, device model, operating system version, language, approximate location derived from your IP address at country or city level, a randomly generated app instance identifier, and which screens and features are used. This is described in analytics and your device below, because your consent governs it.
When you contact us
If you email support@getshillings.com we hold your email address, what you wrote, and anything you attach or include.
Why we use it, and our legal basis
We must have a lawful basis for everything we do with your data. Here is each purpose and the basis we rely on.
| What we do | Data | Legal basis |
|---|---|---|
| Run your account and sync your data across your devices | Account, everything you enter | Performance of a contract — the terms you accepted |
| Produce your forecast, tracking and goal progress | Everything you enter | Performance of a contract |
| Keep the app secure and stop abuse of it | Account, technical | Legitimate interests — protecting the service and the people using it |
| Answer your support email | Your correspondence | Legitimate interests — dealing with an enquiry you chose to send |
| Understand which features are used, and fix what is broken | Analytics | Consent |
| Meet legal obligations and defend legal claims | Whatever is relevant | Legal obligation, and legitimate interests in establishing or defending claims |
Where we rely on legitimate interests we have weighed our interest against your rights and concluded ours does not override them. You can ask us for that assessment, and you can object — see your rights.
Analytics and your device
Analytics involves storing and reading information on your device, which under the Privacy and Electronic Communications Regulations means we need your consent before it happens. It is not necessary to deliver Shillings — the app works fully without it — so we ask, and you are free to say no.
You can withdraw consent at any time in the app's settings. Withdrawing stops further collection; it does not undo what was already collected, though you can ask us to delete that too.
Storing your own data on your own device so the app works offline is a different matter: that is strictly necessary to provide a service you asked for, so it does not require separate consent.
We do not use advertising SDKs, cross-app tracking, or third-party marketing cookies in Shillings.
Who else sees it
We do not sell personal data and we do not share it for anyone else's marketing. We use the following service providers, who process data on our instructions:
| Provider | What they do for us |
|---|---|
| Google Cloud (Firebase Authentication, Cloud Firestore) | Sign-in and the database your data sits in |
| Google (Analytics for Firebase) | Usage analytics, only where you have consented |
| Google Workspace | Our support mailbox |
Google and Apple also act as controllers in their own right for the sign-in you choose to use. What they do with that is governed by their own privacy policies, not this one.
Beyond that we disclose data only where we are legally required to — a court order, or a lawful request from a regulator or law enforcement — or to our professional advisers under a duty of confidence, or to a buyer if the business is sold, in which case we would tell you first.
Where it is kept
Your account and everything you enter into Shillings are stored in the United Kingdom and the European Economic Area.
Analytics data is the exception. Google processes it on servers in the United States. That transfer is covered by the International Data Transfer Addendum to the European Commission's standard contractual clauses, issued by the Information Commissioner under section 119A of the Data Protection Act 2018, which forms part of our contract with Google. If you do not consent to analytics, no analytics data about you leaves the UK or EEA, because none is collected.
How long we keep it
| Data | Kept for |
|---|---|
| Your account, and everything you entered | As long as your account is open. Deleted within 30 days of you asking us to close it — see deleting your account. |
| Analytics | Up to 14 months from collection, then deleted automatically. |
| Support correspondence | 24 months from the last message, so we have the history if you come back to us. |
| Records we must keep by law, or need to defend a claim | As long as the relevant obligation or limitation period runs. |
| Encrypted backups | Deleted data persists in backups for up to 90 days before it is overwritten. |
Your rights
UK data protection law gives you rights over the personal data we hold about you. They are not all absolute: some apply only in particular circumstances, and some are limited where we have to keep data to meet a legal obligation or to establish, exercise or defend a legal claim.
| Right | What it means |
|---|---|
| Access | Ask for a copy of the personal data we hold about you, and for an explanation of how and why we use it. |
| Rectification | Have inaccurate data corrected, and incomplete data completed. |
| Erasure | Ask us to delete your data — for example where we no longer need it, where you withdraw consent we were relying on, or where you object and we have no overriding grounds to continue. |
| Restriction | Ask us to stop using your data, while keeping it, when you are contesting its accuracy or our grounds for holding it. |
| Objection | Object to processing we carry out on the basis of our legitimate interests. Where we process for direct marketing, your objection is absolute and we must stop. |
| Portability | Receive the data you gave us in a structured, commonly used, machine-readable format, and have it transmitted to another provider where that is technically feasible. |
| Withdraw consent | Withdraw consent at any time where consent is the basis we rely on. This does not affect the lawfulness of processing carried out before you withdrew it. |
| Automated decisions | Not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. |
To exercise any of these, email support@getshillings.com. We may need to confirm your identity before we act, so that we do not disclose your data to somebody else. We respond within one month. We can extend that by a further two months where a request is complex or where you have made several — if we need to, we will tell you within the first month and explain why. There is no charge, unless a request is manifestly unfounded or excessive.
If you are unhappy with how we have handled your data or your request, you can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint, by telephone on 0303 123 1113, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would rather you came to us first so we have a chance to put it right, but you do not have to.
Security
Data is encrypted in transit and at rest. Access to production systems is restricted to the people who need it and is protected by multi-factor authentication. Our database rules are written so that one person's records cannot be read by another.
No system is perfectly secure. If a breach occurs that is likely to result in a risk to your rights and freedoms, we will report it to the ICO within 72 hours of becoming aware of it, and we will tell you directly if the risk to you is high.
Children
Shillings is not intended for under-16s and we do not knowingly collect data from them. If you believe a child has given us personal data, email support@getshillings.com and we will delete it.
Automated decision-making
Shillings forecasts what you are due to be paid by doing arithmetic on figures you entered. That is a calculation shown to you, not a decision made about you. We do not carry out profiling or solely automated decision-making that produces legal effects concerning you or similarly significantly affects you.
Changes to this policy
When we change this policy we publish it with a new version date at the top. Where a change materially affects how we use your data we will tell you in the app or by email before it takes effect, and where the change requires your consent we will ask for it rather than assume it.
Contact us
For anything in this policy, including a request to exercise your rights, email support@getshillings.com or write to us at 7 Thorter Way, Dundee, DD1 3DF.