Actual Budget | Privacy Policy

Effective Date: August 4, 2026

1. Introduction

This Privacy Policy explains how Halim Öztürk handles your information in Actual Budget, published on the App Store as "Actual Budget Spendıng Tracker". It is written to match, item for item, the App Privacy label shown on the app's App Store product page.

An earlier version of this page said we collected nothing and that everything stayed in your private iCloud. That was not accurate, and this version corrects it. Your budget records really do live on your device and in your private iCloud — but the app also sends usage analytics, and some of those analytics events include monetary amounts. Section 3 says exactly which. You never create an account, we never connect to your bank, and nothing is sold or given to advertisers or data brokers.

2. Your budget records

Everything you enter — transactions, categories, budgets, savings goals, bills, accounts and net-worth entries — is stored on your device using Apple's on-device database. If iCloud is enabled, it syncs across your Apple devices through Apple's CloudKit, in your private iCloud database. That database belongs to your Apple Account: Halim Öztürk cannot access, read, or retrieve its contents. Your use of iCloud is governed by Apple's Privacy Policy.

There is no login and no account. We never ask you to connect a bank, and the app does not use Plaid or any bank-aggregation service. Merchant names, notes, individual transaction descriptions and account names never leave your device.

3. Analytics — including the financial amounts we send

To understand how the app is used and whether it actually helps, we send product-usage events to Mixpanel and Firebase Analytics: which screens and features you use, that onboarding progressed, that the paywall appeared, plus basic technical information such as app version, device model and operating system.

Some of those events carry monetary amounts. Event properties include amount, budget_amount, income, monthly_income and spending. This is why our App Store privacy label declares Financial Info → Other Financial Info. We use these figures to understand the scale of budgets people are managing and whether the app changes their outcomes — not to build a profile of you.

These events are not attached to your name or an account, because the app has neither. They are keyed to the random per-install identifiers described in section 4.

4. Identifiers, notifications, and our backend

Identifiers. Analytics and subscription data are keyed to random, per-install identifiers — Mixpanel's distinct ID, RevenueCat's anonymous app-user ID, and a Firebase push token. None of these is your name, e-mail, Apple ID or advertising identifier, and deleting and reinstalling the app produces new ones.

Notifications. Reminders you schedule — weekly spending summaries, bill reminders, budget alerts, savings milestones — are local notifications delivered by your own device. In addition, the app registers for remote push notifications through Firebase Cloud Messaging. To make that work, a Firebase Cloud Function operated by us stores, on our Firebase backend: your push token, your anonymous app-user ID, the platform, the app version, your language, your selected currency, and your subscription status. This is the one place where we hold data on a server of our own. It contains no budget records, no transactions, and no amounts.

Approximate location. The app does not use Location Services or GPS and never asks for your location. Mixpanel and Firebase nevertheless see the IP address that any internet request carries, and derive an approximate city, region and country from it on their own servers. That IP-derived approximation is why Coarse Location appears on our privacy label. It is city-level at best and never precise.

5. Apple Search Ads attribution

When you install the app after seeing one of our App Store search ads, iOS provides us with an Apple Search Ads attribution token (Apple's AdServices framework). We use it to learn which of our own campaigns brought you in, and we record the associated keyword, campaign and ad-group alongside your anonymous subscription profile at RevenueCat. This is why our privacy label lists Developer's Advertising or Marketing as a purpose for Identifiers and Purchases.

To be precise about what this is not: Apple Search Ads attribution is Apple's own first-party measurement. It is not cross-app tracking, it does not use the advertising identifier (IDFA), and the app contains no third-party ad network. That is why the app never shows an App Tracking Transparency prompt and why our label's "Data Used to Track You" section is empty.

6. Who processes data on our behalf

• Mixpanel — product analytics. See Mixpanel's Privacy Policy.
• Google Firebase — analytics, push notifications (Cloud Messaging), remote configuration, and abuse protection (App Check). See Firebase's privacy information.
• RevenueCat — subscription management and receipt validation. See RevenueCat's Privacy Policy.
• Apple — App Store payments, CloudKit sync, and Search Ads attribution. See Apple's Privacy Policy.
• Frankfurter — a public exchange-rate service the app queries at most once a day to refresh currency rates. The request contains only currency codes (for example USD, EUR) — no identifier and nothing about you or your money.

7. Payments

Subscriptions are purchased through the App Store. Payment is handled entirely by Apple — we never see or store your card details, billing address, or Apple Account credentials.

8. What we do NOT do

• We do not track you across other companies' apps or websites, and we collect no advertising identifier (IDFA).
• We do not sell, rent, or trade your data, and we share nothing with advertisers or data brokers.
• We do not connect to your bank or import data from financial institutions.
• We do not use a crash-reporting or diagnostics SDK.
• We do not require an account, e-mail address, or login.

9. Data retention and deletion

Your budget records live on your device and in your private iCloud, so you control them: delete entries in the app, delete the app to remove the local copy, and clear its iCloud data from your Apple Account settings. Analytics held by Mixpanel and Firebase, subscription records held by RevenueCat, and the push-token record on our Firebase backend are retained only as long as needed for the purposes above. To have the records associated with your installation deleted, e-mail us at the address below.

10. Security

Your records benefit from Apple's device-level protections and encrypted iCloud sync, and all network requests use encrypted HTTPS connections. No method of storage or transmission is ever completely secure, but keeping your records on-device and off our servers meaningfully reduces risk.

11. Your rights (GDPR / KVKK / CCPA)

Depending on where you live you may have the right to access, correct, delete, or port your personal data, to restrict or object to its processing, and to opt out of its sale or sharing. We do not sell or share your personal information as those terms are defined by the CCPA, and we do not use it for cross-context behavioural advertising. Because we hold no account and no directly identifying information, we may be unable to link a request to a specific installation without further detail from you. Contact us and we will help where we can.

12. Children's data

Actual Budget is a personal-finance tool intended for adults and is not directed to children. We do not knowingly collect personal information from children.

13. International transfers

The app is available in many regions. Our providers may process the data described above in countries other than your own, subject to the safeguards set out in their respective privacy policies.

14. Policy updates

We may update this policy. Material changes will be reflected here, in the date above, and in the App Store privacy label.

15. Contact