Privacy Policy

Last Updated: February 11, 2026

1. Introduction

Welcome to Splitro's Privacy Policy. This Privacy Policy explains how Splitro ("we", "us", or "our") collects, uses, shares, and protects your personal information when you use our crowdfunding platform available at https://splitro.com (the "Service" or "Platform").

We are committed to protecting your privacy and ensuring transparency about our data practices. This Privacy Policy should be read in conjunction with our Terms and Conditions.

Your Rights

We respect your privacy rights and are committed to compliance with:

  • • UK GDPR (United Kingdom General Data Protection Regulation)
  • • EU GDPR (European Union General Data Protection Regulation)
  • • UK Data Protection Act 2018
  • • Other applicable privacy laws

This Privacy Policy applies to all Users of the Service, including visitors, registered Users (Creators and Supporters), and anyone who interacts with our Platform.

2. Data Controller Information

Identity of Data Controller

Splitro is the data controller responsible for your personal information collected through the Service.

Operating Entities

SPLITRO LTD

Company registered in England and Wales (United Kingdom)

PEGASUS SOLUTIONS, INC.

US Parent Company (registered in United States)

Email

support@splitro.com

Data Protection Officer

For questions related to data protection and privacy:

support@splitro.com

EU Representative

For EU users with data protection questions:

support@splitro.com

3. Information We Collect

We collect several types of information to provide and improve our Service.

Authentication Data

  • • Email address (stored in Firebase Authentication)
  • • Password (hashed, never stored in plain text)
  • • Email verification status

Profile Information

  • • Username (unique, 4-15 characters)
  • • Display name (1-50 characters)
  • • Bio (0-160 characters)
  • • Profile picture and banner image
  • • Social media links (optional)
  • • Website URL (optional)

Creator-Specific Information

  • • Country (required for Stripe zone determination)
  • • Payout currency preference (GBP, USD, EUR, or others)

Financial Data

  • • Stripe Customer ID (for payment processing)
  • • Stripe Connect Account ID (for Creators)
  • • Payment card information (stored by Stripe, NOT Splitro)
  • • Transaction history and payout records
  • • Monthly spending totals

🔒 Payment cards are stored by Stripe (PCI-DSS certified), never by Splitro

Group and Activity Data

  • • Groups created or joined
  • • Splits created or contributed to
  • • Auto-Split schedules (for recurring contributions)
  • • Group membership status

Information Collected Automatically

  • • IP address
  • • Browser type and version
  • • Device type and operating system
  • • Pages visited and features used
  • • Date and time of access

5. How We Use Your Information

5.1 Core Service Provision

  • • Create and manage your Account
  • • Authenticate your identity and maintain session security
  • • Process payments and contributions via Stripe
  • • Calculate and distribute funds to Creators
  • • Manage Groups, Splits, and Auto-Splits
  • • Track contribution history and milestones
  • • Generate payout reports for Creators

5.2 Communication

We use your information to send:

  • Transactional emails (payment confirmations, receipts, payout notifications, failed payment alerts)
  • Milestone notifications (25%, 50%, 75%, and 100% funding progress)
  • Security alerts (password resets, login from new devices, suspicious activity)
  • Service updates (important changes to Terms, Privacy Policy, or Platform functionality)

5.4 Fraud Prevention and Security

  • • Detect and prevent fraudulent transactions
  • • Monitor for suspicious activity
  • • Enforce our Terms and Conditions
  • • Comply with legal obligations
  • • Protect the rights and safety of Users

6. How We Share Your Information

We do NOT sell your personal information to third parties.

We share your information only in the following limited circumstances:

Third-Party Service Providers

We share your information with trusted service providers who help us operate the Platform:

Stripe, Inc.

Purpose: Payment processing, Stripe Connect accounts, payout management

Data Shared: Payment cards, bank accounts, transaction data, identity verification

Privacy Policy: https://stripe.com/privacy

Firebase (Google Cloud)

Purpose: User authentication, database storage (Firestore)

Data Shared: Email, password (hashed), user profiles, Groups, Splits, transactions

Privacy Policy: https://firebase.google.com/support/privacy

SendGrid (Twilio)

Purpose: Transactional email delivery

Data Shared: Email addresses, recipient names, email content

Privacy Policy: https://www.twilio.com/legal/privacy

Cloudflare R2

Purpose: Storing user avatars, banners, Group images, Split images

Privacy Policy: https://www.cloudflare.com/privacypolicy/

Legal Requirements

We may disclose your information if required by law, including:

  • Court orders or subpoenas
  • Legal processes and investigations
  • Regulatory inquiries (tax authorities, financial regulators)
  • Law enforcement requests (with valid legal authority)
  • Protection of rights: To protect the rights, property, or safety of Splitro, our Users, or the public

7. International Data Transfers

Where Your Data is Processed

Splitro operates globally, and your data may be transferred to and processed in countries outside your country of residence, including:

  • United Kingdom (Firebase, Cloudflare)
  • European Economic Area (Firebase, Cloudflare, AWS)
  • United States (Stripe, SendGrid, AWS, Vercel, Open Exchange Rates, X/Twitter)

Safeguards for International Transfers

For data transfers from the UK and EU to countries without adequate data protection laws, we rely on:

  • Standard Contractual Clauses (SCCs) with service providers in the United States
  • Adequacy decisions by the European Commission where applicable
  • Service provider commitments to data protection frameworks and compliance

8. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations.

Data TypeRetention Period
User profile data (active accounts)Until account deletion
Transaction records7 years (legal requirement)
Images (avatars, banners, Split images)Until deleted by User or account closure
Rate limiting data (IP addresses, User IDs)60 seconds (automatic expiration)
Audit logs7 years (security and compliance)
Support tickets3 years after closure
Email delivery logs30 days (SendGrid retention)
Payout records7 years (financial compliance)

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

Right to Access (GDPR Article 15)

Request a copy of the personal information we hold about you.

📧 Email: support@splitro.com with "Data Access Request"

Right to Rectification (GDPR Article 16)

Correct inaccurate or incomplete personal information.

⚙️ Update directly in Account settings or contact support

Right to Erasure / "Right to be Forgotten" (GDPR Article 17)

Request deletion of your personal information (exceptions: transaction records retained for 7 years).

🗑️ Request account deletion at /settings/support

Right to Data Portability (GDPR Article 20)

Receive your data in JSON or CSV format.

📦 Email: support@splitro.com with "Data Portability Request"

Response Times

We will respond to all data subject requests within:

  • 30 days (standard)
  • 60 days (for complex requests, with notification)

10. Security Measures

We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

🔐 Authentication Security

  • • Firebase Authentication with email verification
  • • HttpOnly cookies (XSS protection)
  • • Token refresh mechanism (3600s expiry)
  • • Password hashing (never stored in plain text)

🛡️ Data Transmission

  • • HTTPS/TLS encryption (end-to-end)
  • • Stripe PCI-DSS Level 1 certification
  • • Signed URLs for images (7-day expiration)

⚡ API & Network Security

  • • Rate limiting via Upstash Redis
  • • CSRF protection (SvelteKit built-in)
  • • Webhook signature verification
  • • DDoS protection via Vercel & Cloudflare

💳 Payment Security

  • • PCI-DSS compliance via Stripe
  • • 3D Secure authentication
  • • Fraud detection via Stripe Radar
  • • Atomic database transactions

11. Cookies and Tracking Technologies

Essential Cookies Only

We use only essential cookies necessary for the Service to function:

Cookie NamePurposeDuration
fb_id_tokenFirebase authentication ID token3600s (1 hour)
fb_rf_tokenFirebase refresh token for session renewal3600s (1 hour)

Cookie Properties:

  • HttpOnly: Yes (prevents XSS attacks)
  • Secure: Yes (HTTPS only)
  • SameSite: Lax (CSRF protection)

❌ What We Do NOT Use

  • • Third-party tracking cookies (Google Analytics, Facebook Pixel, etc.)
  • • Advertising cookies
  • • Social media cookies (except when you explicitly connect X/Twitter)
  • • Marketing or analytics cookies

12. Children's Privacy

Age Restriction

The Service is NOT intended for children under the age of 18. We do not knowingly collect personal information from anyone under 18 years of age.

Parental Notice

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at support@splitro.com, and we will delete the information promptly.

Verification

By using the Service, you represent and warrant that you are at least 18 years old.

13. Third-Party Links and Services

External Links

The Platform may contain links to third-party websites, services, or resources (e.g., Creator websites, social media profiles).

We are NOT responsible for:

  • The privacy practices of third-party websites
  • The content or accuracy of third-party websites
  • Your interactions with third-party services

Third-Party Service Provider Privacy Policies

14. Changes to This Privacy Policy

Right to Modify

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform functionality.

Material Changes

  • • We will notify you via email at least 30 days before material changes take effect
  • • A prominent notice will be displayed on the Platform
  • • The "Last Updated" date at the top of this Policy will be updated

Non-Material Changes

  • • Minor updates (e.g., clarifications, formatting) may be made without advance notice
  • • The "Last Updated" date will be updated

Your Acceptance

  • • Continued use of the Service after the effective date constitutes acceptance of the updated Privacy Policy
  • • Material changes may require explicit re-acceptance
  • • If you do not agree to the changes, you must stop using the Service and may request Account deletion

15. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know

You have the right to request:

  • Categories of personal information collected
  • Categories of sources of personal information
  • Business or commercial purpose for collecting personal information
  • Categories of third parties with whom we share personal information

Right to Delete

You have the right to request deletion of your personal information (subject to legal retention requirements).

Right to Opt-Out of Sale

We do NOT sell your personal information. Therefore, there is no need to opt out of sale.

Exercising CCPA Rights

To exercise your CCPA rights, contact us at support@splitro.com with "CCPA Request" in the subject line.

16. Data Breach Notification

Our Commitment

In the event of a data breach that affects your personal information, we are committed to transparency and timely notification.

Notification Timeline

For UK/EU Users (GDPR):

We will notify affected Users within 72 hours of becoming aware of the breach

For All Users:

We will provide timely notification via email and/or Platform notice

Information Provided

  • • Nature of the breach and data affected
  • • Likely consequences of the breach
  • • Measures we have taken to mitigate harm
  • • Recommended steps for Users to protect themselves
  • • Contact information for questions

Prevention Measures

We continuously monitor our systems for security threats and implement measures to prevent unauthorized access, including:

  • Regular security audits
  • Penetration testing
  • Employee training on data security
  • Incident response plans

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

General Inquiries

Email

support@splitro.com

Data Protection

For GDPR inquiries

support@splitro.com

Subject: "Data Protection Inquiry"

Response Time

Privacy inquiries

Within 30 days

UK Operating Entity

SPLITRO LTD

Registered in England and Wales

US Parent Company

PEGASUS SOLUTIONS, INC.

Registered in United States

UK Supervisory Authority

Information Commissioner's Office (ICO)

Website: ico.org.uk

Phone: 0303 123 1113

18. Summary of Key Points

📊 What information do we collect?

  • • Account information (email, username, password)
  • • Profile information (display name, bio, images, social links)
  • • Financial data (via Stripe - payment cards, transactions, payouts)
  • • Usage data (IP address, device information, pages visited)

🎯 How do we use your information?

  • • To provide the Service (authentication, payments, Groups, Splits)
  • • To communicate with you (transactional emails, notifications)
  • • To improve the Platform (analytics, bug fixes)
  • • To prevent fraud and ensure security

🤝 Do we share your information?

  • • We do NOT sell your information
  • • We share with trusted service providers (Stripe, Firebase, SendGrid, etc.)
  • • We may disclose if required by law

⏱️ How long do we keep your information?

  • • Active accounts: Until you delete your Account
  • • Transaction records: 7 years (legal requirement)
  • • Images: Until deletion or account closure
  • • Rate limiting data: 60 seconds (automatic expiration)

19. Acknowledgment

BY USING THE SERVICE, YOU ACKNOWLEDGE THAT:

  1. You have read and understood this Privacy Policy
  2. You consent to the collection, use, and sharing of your information as described
  3. You understand your privacy rights and how to exercise them
  4. You understand that we use third-party service providers to operate the Platform
  5. You have reviewed the privacy policies of our third-party service providers
  6. You understand that transaction records are retained for 7 years for legal compliance

Thank you for trusting Splitro with your personal information. We are committed to protecting your privacy and providing a secure, transparent Platform.

Last Updated: February 11, 2026

For the most current version of this Privacy Policy, please visit: https://splitro.com/privacy

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