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Privacy Policy

Last updated: October 6, 2026

1. Data Controller

Binary Spirit S.L.
Tax ID (CIF): B86508181, registered address in Madrid, Spain (see the Legal Notice)
Contact: privacy@fairdivider.com

2. What Data We Collect

Fair Divider collects the minimum data necessary to provide the fair division service:

We do not collect email addresses, phone numbers, payment information or precise geolocation data, and we do not require user accounts. If analytics are active (website: only if you opt in; apps: on by default), an approximate country- or region-level location is derived from your IP address.

3. How We Use Your Data

5. Data Retention

6. Cookies and Similar Technologies

Fair Divider relies on strictly necessary cookies and equivalent storage technologies, which are exempt from prior consent under Article 22.2 of the Spanish LSSI-CE and the AEPD 2023 Cookie Guide. The website additionally offers optional analytics cookies that load only after you opt in, as described in section 7. The full inventory (strictly necessary own cookies, Cloudflare Turnstile cookies served on the multi-device page, browser-storage entries, and the optional analytics cookies set only after opt-in) is documented in our Cookie Policy.

We do not use advertising cookies, tracking pixels, or third-party cookies for profiling or behavioural advertising. On the website, the only non-essential technologies are the optional analytics described in section 7, which run solely with your consent. The apps' analytics is described in section 14. Cloudflare Turnstile is loaded on /multi for anti-abuse purposes only and sets no analytics or advertising cookies.

In addition to the strictly necessary technologies above, the Fair Divider website can load two optional analytics tools. They are disabled by default and run only after you give explicit consent. The mobile app analytics is separate (on by default in the apps, with an off switch) and is described in section 14.

Legal basis — your consent (Art. 6.1.a GDPR; Art. 22 LSSI-CE, which requires prior opt-in for non-essential cookies). When you first use the website we ask whether to enable analytics. You can choose "Accept" (strictly necessary + analytics) or "Reject" (no analytics); both are equally easy, analytics stays off unless you accept, and the sheet stays on screen until you choose without blocking this policy or the other legal pages. Your choice is stored in your browser under the fd-analytics key, with its date under fd-consent-at, and we ask again after 12 months.

What the website analytics receive. Only if you accept: the pages you open (without share-link or room codes), clicks on the calculator button and on the App Store and Google Play badges, the steps of a division (started, completed, shared, abandoned), language and theme changes, errors shown, that you pressed Accept, the language of the page, and which version of an interface test you were shown ("A" or "B"). Pages that do not exist are counted as such. Never names, amounts, descriptions or room codes. Google Analytics and Clarity assign your browser a pseudonymous identifier, so this is pseudonymous, not anonymous, data.

Consent-mode sequence. Google Analytics starts with every consent signal (analytics storage, advertising storage, advertising user data and ad personalisation) denied and sends nothing that identifies a browser. Only when you press Accept does it move analytics storage to granted; the advertising signals stay denied. Microsoft Clarity is not loaded at all until you accept. Clarity may set its own cookies on its own domains in addition to those on ours; they are listed in the Cookie Policy.

Withdrawing consent. You can change your mind at any time — withdrawing is as easy as giving consent. This applies to the website. (The apps' analytics does not rest on consent: it is on by default and you can object to it at any time under Art. 21 GDPR by turning off the "Share usage statistics" switch in the info menu; see section 14.) On the website, use the "Cookie settings" link in the footer of the Fair Divider app (the calculator pages) to reopen the chooser and switch analytics off; the analytics tools will no longer load. Withdrawing stops future collection and deletes the four analytics cookies (_ga, _ga_<id>, _clck, _clsk) on our domain, and tells Google and Microsoft that consent is withdrawn; it does not erase data Google and Microsoft already hold, which you can ask us to delete at privacy@fairdivider.com.

International transfers. Google and Microsoft may process analytics data outside the European Economic Area (for example, in the United States) under the EU Standard Contractual Clauses and/or the EU-US Data Privacy Framework, in accordance with Chapter V of the GDPR.

Retention. Google Analytics data is retained for approximately 14 months; Microsoft Clarity data is retained for approximately 90 days (the providers' configured/standard retention periods).

8. Data Sharing

We do not sell, rent, or share your personal data with third parties. The one exception is a shared result link, which you create and send yourself: the result becomes readable by anyone holding that link until it expires (section 5). Our infrastructure providers process data on our behalf:

If you opt in to the optional website analytics described in section 7, Google Ireland Limited (Google Analytics 4) and Microsoft Ireland Operations Limited (Microsoft Clarity) also act as data processors on our behalf. For the app analytics (section 14, on by default until you switch it off), Google Ireland Limited likewise acts as a processor. We never sell your personal data.

9. International Transfers

Your data is primarily processed within the European Union (Hetzner Germany, MongoDB Atlas EU). Cloudflare may process traffic through global edge servers under Standard Contractual Clauses (SCCs) compliant with GDPR Chapter V.

If analytics are on, Google and Microsoft may also process data outside the EEA (for example, in the United States) under the EU Standard Contractual Clauses and/or the EU-US Data Privacy Framework, as detailed in section 7.

10. Your Rights (GDPR Articles 15-22)

You have the right to:

To exercise any right, contact privacy@fairdivider.com with your division session code. We will respond within 30 days.

How to exercise your rights: Send an email to privacy@fairdivider.com identifying yourself. We will respond within a maximum of 1 month as required by Article 12.3 GDPR. If your request requires extraordinary complexity, we may extend this period by up to 2 additional months with prior notice.

11. Right to Complain

You have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es, or with your local supervisory authority.

12. Children

Fair Divider is not directed at children under 16 years of age. We do not knowingly collect data from children.

13. Automated Decision-Making

Fair Divider uses a mathematical optimization to calculate fair divisions. This is a mathematical computation, not profiling or automated decision-making with legal effects as defined in GDPR Art. 22.

14. Mobile Apps

The Fair Divider apps for iOS and Android use the same /api/v1 backend described in this policy, with the same purposes, the same retention periods and the same rights.

Analytics in the apps. The apps include analytics based on Google Analytics for Firebase. It is on by default, and you can turn it off at any time with the "Share usage statistics" switch in the app's info menu. Turning it off stops collection that same instant.

What is sent while it is on. The name of the actions you take (for example starting, completing, sharing or joining a division, changing the currency or language, errors shown), the screen you are on (from a fixed list), the mode of use (single device or several), the language of the app and, if you opened a share or join link that carried campaign tags, the source, medium and campaign of that link. The apps run Google Analytics for Firebase with every consent signal (analytics storage, advertising storage, advertising user data and ad personalisation) permanently denied, so the analytics code stores and reads no identifier on your device (no installation or app-instance ID) and sends identifier-free pings: they carry no persistent device or installation identifier and cannot be linked from one session to the next by an ID. A ping still travels over the network from your IP address, so Google receives standard device and usage data, such as the model, system version and language, and derives an approximate country-level location from the IP address. We therefore do not call this data anonymous: it is pseudonymous and IP-derived, and only coarse.

What is never sent. Participant names, room or item descriptions and amounts never leave the app for analytics, under any circumstances. The device advertising identifier is not used either: on Android we explicitly remove that permission from the app. We show no ads, build no profiles and do not track you across apps or websites.

Legal basis: our legitimate interest (art. 6(1)(f) GDPR) in understanding aggregate use of the apps in order to improve them, limited to the closed set of events described above (pseudonymous data, see above). You can object at any time, and switching the "Share usage statistics" switch off stops it that same instant; this does not affect the lawfulness of processing carried out before.

Processor, destination and retention. The data is processed by Google Ireland Limited on our behalf, in the same Google Analytics 4 property used by the website, and is retained for approximately 14 months. Google may process it outside the European Economic Area under the conditions in section 9. Your rights and how to exercise them are those of sections 10 and 11.

The apps do not include Microsoft Clarity or any advertising SDK, and do not request device permissions beyond what is strictly required for the user-initiated action (for example, sharing a division link). Diagnostic data sent by the operating system to its respective app store (Apple App Analytics, Google Play Console) is governed by the privacy policies of Apple and Google respectively, and not by Binary Spirit S.L.

15. Account & Data Deletion

Fair Divider does not require a user account. Multi-device sessions and shared result links auto-expire 7 days after they are created, and the division itself is dropped from server memory after 24 hours of inactivity. To delete your data sooner, or to remove all locally stored data on your device, see our dedicated Account & Data Deletion page.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date.

30 August 2026 → 7 September 2026: shared result links are now described. When a division finishes on the website, a short share link is prepared for it, and that stores the division's result — the participant names, the room or item names, the total, each person's amount, the shared costs and how they are split, and the currency — in our database for 7 days, where anyone holding the link can read it; opening a link someone sent you stores nothing, because the long form carries the data in the address and never reaches our server. Sections 2, 3, 4, 5, 8 and 15 have been updated, and section 10 now gives the route to have a shared link removed before it expires.

6 October 2026, second revision: app analytics remain on by default with the same switch, but the apps now run Google Analytics for Firebase with all consent signals permanently denied, so no identifier is stored or read on the device and the analytics pings are identifier-free. Sections 6 and 14 no longer mention a random installation identifier; the data sent is otherwise unchanged. The legal basis (legitimate interest) and the right to object by switching the setting off are unchanged.

5 October 2026 → 6 October 2026: wording clarified, no change in the data processed. Section 14 now states that the app event data is pseudonymous; section 6 distinguishes the website from the apps; section 7 explains that turning off the apps' switch is an objection (Art. 21 GDPR), not a withdrawal of consent.

1 October 2026 → 5 October 2026: app analytics are now on by default, with a switch in the info menu to turn them off at any time (previously off by default and opt-in). The data collected is the same closed set of events described in section 14. The legal basis for app analytics is now legitimate interest instead of consent. Website analytics are unchanged: opt-in only.

24 August 2026 → 28 August 2026: the iOS and Android apps now include optional analytics (Google Analytics for Firebase), off by default and switched on from the info menu. Section 14 previously stated that the apps carried no analytics; it has been rewritten with the detail of what is and is not collected. Sections 2, 3, 4, 5, 7, 8 and 10 have been corrected to distinguish the website analytics from the app analytics.

20 August 2026 → 24 August 2026: sections 3, 5 and 15 corrected and one retention period extended. The division held in server memory now expires after 24 hours of inactivity instead of 2, so that a division survives being left overnight. The same sections previously described that memory store as applying only to deployments without a database, which was wrong: it applies to every deployment. Section 3 also corrected the owner token, which is stored in localStorage with a 24-hour self-expiry and not in sessionStorage.

27 June 2026 → 8 August 2026: section 7 corrected. The Microsoft Clarity masking mode was described as Strict; it was Balanced. Element-level masking has been applied to the calculator surfaces, and shared-result links no longer carry participant names in the address bar.

17. Contact

For privacy-related inquiries: privacy@fairdivider.com