Privacy Policy

Last updated: 3 September 2026

This Privacy Policy explains how ALEXANDER GOLOVKOV, an Individual Entrepreneur registered in Georgia, Registration/ID No. 305866649, registered address Georgia, Tbilisi, Amberki Tabidze Street, N 43, Floor 11 ("Company," "we," "us"), handles information in connection with WealthMind Statements Converter at statementconverter.app (the "Service"). We act as the data controller for the personal data described in this Policy, except where stated otherwise (e.g. payment data handled by Paddle as an independent controller).

1. Our Core Privacy Commitment: We Do Not Store Your File Content

The Service exists to convert bank statement files you upload. Unlike many document-processing tools, we designed the Service so that:

• your uploaded files, and any transaction or account data contained in them, are processed transiently - in memory or temporary storage - solely to perform the requested conversion;
• once the conversion is complete or your session ends, that content is automatically and irreversibly deleted; we do not keep a copy;
• we do not read, review, sell, or use the substantive content of your bank statements for any purpose other than performing the conversion you requested; and
• we cannot retrieve a past conversion for you after your session ends, precisely because we don't keep it - please download and save your converted output before closing your session.

The service is intended for limited-size conversions (up to 3 statement files per session, and up to 150 transaction rows per file). Files above those limits are not supported and may fail or return incomplete output.

2. What We Do Collect

We deliberately do not collect or store: the content of your bank statements, the transactions listed in them, account numbers, or any other data extracted from your uploaded files, beyond the transient processing described in Section 1.

3. Payment Data (Handled by Paddle)

Payments are processed by Paddle (Paddle.com Market Ltd / Paddle.com Inc.), acting as our Merchant of Record and as an independent data controller for your payment details (e.g. card number, billing address). Paddle's own Privacy Policy governs how it handles that information. We only receive limited transaction metadata from Paddle (e.g. that a payment succeeded, the amount, and your Session ID) - we do not receive or store your full card details.

4. Legal Bases for Processing (EU/UK GDPR)

Where the GDPR or UK GDPR applies, we process personal data on the following legal bases:

• Performance of a contract (Art. 6(1)(b)) - to provide the Service you requested, process payments, and handle support/refund requests;
• Legitimate interests (Art. 6(1)(f)) - to secure the Service, prevent fraud and abuse, and perform basic analytics, balanced against your privacy interests;
• Legal obligation (Art. 6(1)(c)) - to meet accounting, tax, and record-keeping requirements; and
• Consent (Art. 6(1)(a)) - for optional cookies/analytics or marketing communications, where required, which you may withdraw at any time.

5. How We Use Personal Data

We use the limited personal data described above to: provide and maintain the Service; process payments through Paddle; respond to support and refund requests using your Session ID; detect, prevent, and investigate fraud, abuse, or security incidents; comply with legal, tax, and accounting obligations; and, where you've consented, send you service-related or marketing communications (you can opt out at any time via an unsubscribe link or by emailing support@statementconverter.app).

6. Who We Share Data With

We share limited personal data with:

• Paddle - for payment processing, invoicing, tax collection, and refund execution (as an independent controller for payment data);
• Hosting and infrastructure providers - to run the Service (e.g. [cloud hosting provider - insert name]);
• Analytics providers, if used - to understand aggregate usage of the Service; and
• Authorities, where required by law, court order, or to protect our legal rights, or the safety of the Service or its users.

We do not sell your personal data. We do not share the content of your uploaded files with any third party, because we do not retain it beyond the transient processing described in Section 1.

7. International Data Transfers

We are established in Georgia, which does not currently have a European Commission adequacy decision under the GDPR. If you are located in the European Economic Area, United Kingdom, or another region with data-transfer restrictions, your data may be transferred to and processed in Georgia and other countries (e.g. where our hosting provider or Paddle operate). Where such transfers occur, we rely on appropriate safeguards recognized under applicable law, such as: performance of the contract you asked us to fulfil (e.g. Art. 49(1)(b) GDPR, given the conversion is provided at your request and requires processing outside the EEA), your explicit consent where applicable, or, where relevant, Standard Contractual Clauses with our processors. Payment data transfers are handled under Paddle's own safeguards as described in Paddle's Privacy Policy.

8. Data Retention

• Uploaded file content: not retained - deleted immediately upon completion of the conversion or expiry of the session (see Section 1).
• Session ID and transaction/billing metadata: retained for up to 6 months to support refund handling, dispute resolution, fraud prevention, and accounting/tax record-keeping, or longer where required by applicable law (e.g. tax law in Georgia or your billing country).
• Account information: retained for as long as your account is active, plus a reasonable period afterward to comply with legal obligations or resolve disputes.
• Support communications: retained for a reasonable period to handle your request and for quality/record purposes.

9. Security

We use reasonable technical and organizational measures to protect personal data, including encryption of data in transit (TLS/HTTPS), restricted access to systems, and automatic deletion of uploaded file content after processing. No system is completely secure, and we cannot guarantee absolute security of information transmitted to the Service.

10. Your Rights

Depending on your location, you may have the right to: access the personal data we hold about you; correct inaccurate data; request deletion of your data; restrict or object to certain processing; receive a portable copy of your data; and withdraw consent at any time (without affecting processing carried out before withdrawal). To exercise any of these rights, email support@statementconverter.app. If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection supervisory authority.

Note that because we do not retain your uploaded file content, an access or deletion request for that content will generally return "nothing on file" - it was already deleted automatically after your session.

11. Cookies and Similar Technologies

We may use essential cookies necessary for the Service to function (e.g. maintaining your session), and, where enabled, optional analytics cookies to understand aggregate usage. Where required by law, we will ask for your consent before setting non-essential cookies, and you can manage your preferences via your browser settings.

12. Children's Privacy

The Service is not directed at, and we do not knowingly collect personal data from, individuals under 18 years of age. If we learn that we have inadvertently collected personal data from a minor, we will delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will post the updated Policy with a new "Last updated" date and, for material changes, take reasonable steps to notify you (e.g. by email or a notice on the Service).

14. Contact Us

For any privacy question or to exercise your rights, contact:

support@statementconverter.app

Alexander Golovkov Individual Entrepreneur, Georgia, Registration No. 305866649 Registered address: Georgia, Tbilisi, Amberki Tabidze Street, N 43, Floor 11