Privacy Policy

Effective: 20 April 2026Last updated: 20 April 2026Version: 1.2
01

Introduction

1.1 Who We Are

This Privacy Policy describes how BillBird Holdings ("BillBird", "we", "us", "our"), a company registered under the laws of Poland with registered office at Warsaw, Poland, operates the BillBird subscription-tracking service available at www.billbird.io (the "Service").

Data ControllerBillBird Holdings, Warsaw, Poland
Contact Emailhello@billbird.io
DPONot required under GDPR Art. 37(1) — small business exemption applies. Privacy queries: hello@billbird.io

1.2 What BillBird Does

BillBird is an intelligent subscription management platform that gives you complete visibility and control over your software spending. By securely connecting to your email account via IMAP, BillBird automatically identifies recurring-payment and subscription emails, extracts key billing details — merchant name, amount, currency, billing frequency, and renewal dates — and presents them in a single, unified dashboard.

Beyond simple extraction, BillBird analyses your subscription portfolio to provide meaningful financial insights: spending breakdowns by software category, total monthly and annual cost summaries, and trends over time. This helps individuals and teams understand exactly where their budget is going and identify redundant or underused tools.

BillBird also goes a step further by surfacing market intelligence: for each subscription category, the platform analyses available alternatives and provides data-driven recommendations on the best tools based on features, pricing, and value. Whether you are overpaying for a tool that has a better-priced equivalent, or using multiple overlapping services that could be consolidated, BillBird helps you make smarter software decisions.

In short, BillBird is an all-in-one subscription intelligence tool — combining automated discovery, spend analysis, and AI-assisted alternative recommendations — designed to save you money and reduce the complexity of managing modern software stacks. Because the core service requires access to your email, we handle sensitive personal data and we take that responsibility seriously.

1.3 Scope

This Policy applies to all personal data processed through www.billbird.io, the BillBird application, and any related services, for all users globally, with heightened protections for EU/EEA residents under GDPR.

1.4 Changes

Material changes will be communicated by email at least 30 days before taking effect and by a prominent notice in the Service. Minor changes (wording clarifications, broken-link fixes) take effect on the updated date shown above. Continued use constitutes acceptance.

02

Personal Data We Collect

2.1 Account Information

Collected at registration:

  • Email address (login, communications, account recovery)
  • Password (bcrypt-hashed; never stored in plain text)
  • Name (optional, if provided)
  • Subscription tier (Free / Pro / Business)
  • Account creation date and last login timestamp

Legal basis: Contract performance (GDPR Art. 6(1)(b))

2.2 IMAP Credentials

High-Sensitivity Data
IMAP credentials give access to a user's email account. This is the highest-risk data category we handle. Users must be informed clearly and we must justify why we use IMAP rather than OAuth where available.

To connect an email account, we collect:

  • Email account address(es) connected by the user
  • IMAP app-specific password — AES-256 encrypted before storage using envelope encryption; keys stored separately; never in plain text at any point
  • Email provider (Gmail, Outlook, Yahoo, custom domain, etc.)
  • IMAP server details (host, port, TLS settings)
  • Connection status, last-scan timestamp

Why IMAP, not OAuth?
OAuth is limited to specific providers (Google, Microsoft). IMAP lets users connect any email service — Gmail, ProtonMail, custom business domains, older providers — without us being gated by provider approval programmes. This is a technical compatibility decision, not a data-collection choice. We access only the minimum email data needed for subscription detection. You can disconnect your email account at any time, which immediately deletes your stored credentials.

Legal basis: Contract performance (GDPR Art. 6(1)(b)) — necessary to deliver the core service

2.3 Email Content Data

When scanning connected accounts we process:

  • Email metadata: sender, subject, date, recipient
  • Email body text — only to the extent needed to identify subscription-related content
  • Extracted subscription fields: merchant/service name, payment amount and currency, billing date, frequency, payment method (last 4 digits only), plan type, invoice links, next payment date

What We Do NOT Collect
Full email content beyond subscription emails · Personal correspondence · Attachments (except invoice links in subscription emails) · Emails unrelated to subscriptions · Full card numbers · Passwords found in emails · Government IDs or SSNs

Once subscription data is extracted we do not retain the raw email content. We adhere strictly to the GDPR data-minimisation principle (Art. 5(1)(c)).

Legal basis: Contract performance (GDPR Art. 6(1)(b))

2.4 Payment Information

For paid plans, processed via Stripe:

  • Billing name and address
  • Payment method type and last 4 digits
  • Transaction IDs and dates
  • Subscription status

We never see or store complete card numbers. Full payment details are handled by Stripe (PCI-DSS Level 1 certified).

Legal basis: Contract performance (Art. 6(1)(b)) and legal obligation — tax/accounting records (Art. 6(1)(c))

2.5 Usage and Analytics Data

Automatically collected:

  • Device info: browser, OS, device type
  • Usage data: features used, pages visited, session duration
  • IP address (security and fraud prevention)
  • Log data: access times, errors, performance metrics

Legal basis: Legitimate interests (Art. 6(1)(f)) — service improvement, security, fraud prevention

2.6 Communications Data

When you contact us:

  • Support enquiries: email content you send
  • Feedback and survey responses
  • Marketing email engagement (only with explicit opt-in)

Legal basis: Consent (Art. 6(1)(a)) for marketing; legitimate interests (Art. 6(1)(f)) for support

2.7 Cookies and Tracking

We use minimal cookies:

  • Essential cookies: session management, CSRF protection (no consent required)
  • Functional cookies: user preferences, theme, language (consent required in some jurisdictions)
  • Analytics cookies: usage statistics — only with consent where required by law

We Do NOT Use
Third-party advertising cookies · Social media tracking pixels · Cross-site tracking cookies · Behavioural profiling cookies

Legal basis: Consent (Art. 6(1)(a)) for non-essential cookies; legitimate interests (Art. 6(1)(f)) for essential cookies

03

How We Use Your Data

3.1 Service Delivery

We use personal data to: create and manage your account; authenticate your identity; connect to email via IMAP; scan for subscription emails; extract and display subscription data; send renewal reminders; and provide customer support. Legal basis: contract performance (Art. 6(1)(b)).

3.2 Communications

We send: transactional emails (account confirmation, password reset, subscription changes); service update notices; support responses; renewal reminders; and policy-change notifications. Promotional / marketing emails are sent only with your explicit opt-in consent (Art. 6(1)(a)) and you may unsubscribe at any time via the link in each email.

3.3 Service Improvement

We use anonymised and aggregated data to analyse usage patterns, improve detection accuracy, develop features, fix bugs, and conduct internal R&D. Legal basis: legitimate interests (Art. 6(1)(f)).

3.4 Security & Fraud Prevention

We process data to detect and prevent fraud, abuse, and security incidents; monitor for suspicious activity; enforce our Terms of Service; and comply with legal obligations. Legal basis: legitimate interests (Art. 6(1)(f)) and legal obligation (Art. 6(1)(c)).

3.5 Legal Compliance

We process data to comply with tax, accounting, and regulatory obligations; respond to lawful authority requests; and protect against legal claims. Legal basis: legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)).

04

Data Sharing & Third-Party Processors

4.1 Our Sub-Processors

We share data only with the processors listed below, all under GDPR-compliant Data Processing Agreements (Art. 28 DPAs):

ProcessorPurposeData SharedLocationSafeguards
Supabase Inc.Database, storage, auth, Edge Functions (email scanning & IMAP testing)All account & subscription data, IMAP credentials (encrypted), extracted subscription dataUS (AWS us-east-1)DPA in Supabase dashboard; AES-256; TLS; SOC 2 Type II; SCCs for EU transfers
Cloudflare, Inc.Frontend hosting (Pages), DNS, CDN, DDoS protection, SSLUsage logs, IP addresses, session dataGlobal edge (US-HQ); EU traffic on EU nodesDPA v6.3; EU SCCs Module 2; UK Addendum; ISO 27001; SOC 2 Type II; PCI DSS L1; Data Privacy Framework
Vercel Inc.IMAP extraction engine hosting (serverless functions)Email content during processing, IMAP credentials (encrypted), extracted subscription dataUS primary (AWS/Azure/GCP); EU SCCs 2021 + UK IDTADPA; EU SCCs Module 2; UK IDTA; SOC 2 Type II; AES-256; TLS 1.2+; Irish DPC supervisory authority
N8N GmbHWorkflow automation & email processing engineIMAP credentials (encrypted), email content during job processingEU — Azure West Central (Frankfurt, Germany)DPA executed (DocuSign); EU SCCs 2021 Module 2; UK Addendum; Berlin Commissioner; 72-hr breach notification; annual audit rights; EU region enforced
Stripe Inc.Payment processingBilling name/address, last 4 card digits, transaction recordsUS (EU operations)DPA via standard Stripe terms; EU SCCs; PCI-DSS Level 1
Resend (Plus Five Five, Inc.)Transactional email delivery (renewal reminders, account notifications)User email addresses, email content of notifications sentUS (San Francisco)DPA; EU SCCs 2021 Module 2; UK Addendum; EU-US Data Privacy Framework certified; SOC 2 Type II; annual penetration testing
Email Providers (Gmail, Outlook, etc.)IMAP connection for email retrievalIMAP credentials supplied by userVaries by providerTLS/SSL; app-specific passwords only

4.2 Data Processing Agreement Requirements

Under GDPR Art. 28, every DPA must ensure each processor: processes data only on our documented instructions; implements appropriate technical and organisational security measures; assists us in responding to data-subject rights requests; does not engage further sub-processors without prior written authorisation; deletes or returns data upon termination; and maintains records of processing activities.

4.3 No Data Selling — Ever

Absolute Commitment
BillBird does not and will never: sell personal data to any third party · share data for advertising purposes · use email content for any purpose other than subscription detection · share subscription data with merchants or third-party services · allow third parties to access users' email accounts.

4.4 Legal Disclosures

We may disclose data if required by a valid court order, subpoena, or applicable law; to protect the rights, property, or safety of BillBird, our users, or the public; or in connection with legal claims or disputes. Where legally permitted, we will notify affected users before disclosure and will challenge overly broad requests.

4.5 Business Transfers

In a merger, acquisition, or asset sale, your data may be transferred. We will notify you by email and/or prominent in-Service notice at least 30 days before your data becomes subject to a different privacy policy, and you will have the option to delete your account.

05

International Data Transfers

5.1 Primary Storage

Your data is primarily stored on Supabase infrastructure hosted on AWS us-east-1 (United States). EU user data is transferred to and stored in the US under Standard Contractual Clauses (SCCs). If you wish to request EU-region storage, contact hello@billbird.io — we are actively reviewing data localisation options.

5.2 Transfers Outside the EU/EEA

Several processors are US-headquartered or store data in the US. Specifically: Supabase stores data in AWS us-east-1 (US); Vercel executes IMAP extraction on US servers; Cloudflare is US-headquartered though EU traffic is processed on EU edge nodes; Stripe and Resend operate in the US with EU operations. N8N processes data exclusively on EU servers (Azure West Central, Frankfurt). Safeguards in place:

  • Standard Contractual Clauses — EU Commission-approved SCCs, 2021 version
  • Adequacy decisions where applicable
  • Supplementary measures: AES-256 encryption, strict access controls, data minimisation

Transfer Impact Assessments (TIAs) have been conducted for all US-based processors as required under GDPR Chapter V and the Schrems II framework. N8N processes data exclusively in the EU and does not require a TIA. Cloudflare and Resend are EU-US Data Privacy Framework certified, providing additional transfer protections. Copies of transfer safeguards are available on request by emailing hello@billbird.io.

06

Data Security

6.1 Technical Safeguards

  • Encryption in transit: TLS 1.2+ (HTTPS) for all data transmission
  • Encryption at rest: AES-256 for database storage
  • IMAP credential encryption: envelope encryption before storage; keys stored separately from ciphertext; automated key rotation; zero plain-text storage at any point
  • Password hashing: bcrypt with salt
  • Multi-factor authentication available
  • Role-based access control, principle of least privilege
  • Firewall protection and intrusion detection
  • Regular automated security patching
  • Encrypted backups with geographic redundancy

6.2 Organisational Safeguards

  • Staff security-awareness and GDPR training
  • Confidentiality agreements for all personnel
  • Audit trails of data access
  • Documented incident-response procedures
  • Periodic security reviews and vendor due-diligence

6.3 Your Responsibilities

Users are responsible for: using strong unique passwords; enabling two-factor authentication; using app-specific passwords (not main account passwords) for IMAP; logging out from shared devices; and reporting suspicious activity to hello@billbird.io immediately.

6.4 Breach Notification

In the event of a personal data breach we will: notify the relevant supervisory authority within 72 hours of discovery (GDPR Art. 33); notify affected users without undue delay via email (Art. 34); provide details of the breach, its impact, and remedial steps taken.

07

Data Retention

7.1 Retention Schedule

Data CategoryRetention PeriodBasis
Account informationDuration of accountContract
IMAP credentialsUntil email disconnected or account deleted (immediate deletion)Contract / security
Extracted subscription dataWhile account active; 30 days post-deletionContract
Usage logs12 monthsLegitimate interest
Support communications24 months after resolutionLegitimate interest
Billing records7 yearsLegal obligation (tax/accounting)
Marketing consent recordsDuration of consent + 3 yearsLegal (proof of consent)
Aggregated analytics (anonymised)IndefiniteNo personal data

7.2 Free vs Paid Accounts on Cancellation

  • Free accounts: data deleted 12 months after inactivity
  • Paid accounts: personal data deleted within 30 days of cancellation (billing records retained 7 years)

7.3 Deletion Process

When retention periods expire or deletion is requested: personal data deleted from production systems within 30 days; backup copies purged within 90 days; secure deletion methods ensuring data is unrecoverable; only anonymised aggregated data may be retained.

08

Your Rights Under GDPR

EU/EEA residents have the following rights. All requests should be sent to hello@billbird.io with the relevant subject line. We respond within 30 days (extendable by 60 days for complex requests, with notification). All rights exercised free of charge for the first request.

RightWhat It MeansHow to Exercise
Access (Art. 15)Confirm whether we process your data; obtain a copyEmail: "Access Request"
Rectification (Art. 16)Correct inaccurate or incomplete dataAccount settings or email
Erasure (Art. 17)Delete your data (subject to legal exceptions)Account > Delete, or email
Restriction (Art. 18)Pause processing while a dispute is resolvedEmail: "Restriction Request"
Portability (Art. 20)Receive data as JSON/CSV for transferAccount > Export, or email
Object (Art. 21)Object to legitimate-interest processing; absolute right to stop direct marketingEmail or unsubscribe link
Withdraw consent (Art. 7(3))Withdraw consent at any time (doesn't affect prior lawful processing)Account settings or email
Complaint (Art. 77)Lodge a complaint with your supervisory authoritySee Section 8.1 below

8.1 Supervisory Authority

Your lead supervisory authority is the data protection authority of the EU country in which BillBird is incorporated: Urząd Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl. A full list of EU supervisory authorities: edpb.europa.eu. UK residents may contact the ICO at ico.org.uk.

10

Children's Privacy

The Service is not intended for users under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child, contact hello@billbird.io immediately and we will delete it and terminate the account promptly.

11

Cookies & Tracking Technologies

11.1 Cookies We Use

  • Strictly necessary (no consent required): session cookie, CSRF security cookie, preference cookie
  • Functional (consent required in some jurisdictions): persistent login, UI preferences
  • Analytics (consent required): usage statistics, performance monitoring

We do not use third-party advertising cookies, social media tracking pixels, cross-site tracking, or behavioural profiling cookies.

11.2 Third-Party Cookies

Stripe may set cookies necessary for payment processing. No other third-party cookies are used.

11.3 Managing Cookies

Control cookies via: browser settings (refuse, delete, block third-party); our cookie consent banner (accept/reject non-essential cookies on first visit). Disabling essential cookies will prevent access to the Service. We honour Do Not Track (DNT) signals — when received, analytics and non-essential tracking cookies are not set.

12

Automated Decision-Making & Profiling

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on users (GDPR Art. 22). Our subscription-detection algorithms scan emails to extract billing data — this is a purely functional service process, not profiling. You retain full control and can review, correct, or delete any extracted data at any time.

13

Data Protection Impact Assessment (DPIA)

We have conducted a Data Protection Impact Assessment (DPIA) under GDPR Art. 35, using the EDPB DPIA Template v1.0 (March 2026). The DPIA covers collection and storage of IMAP credentials, automated email content processing, and subscription data extraction. It concludes that all identified risks are mitigated to an acceptable level through encryption, data minimisation, strict purpose limitation, and full user control. The DPIA is available on request by contacting hello@billbird.io.

14

Non-EU Users

14.1 California Residents (CCPA/CPRA)

California residents have rights to: know what personal information is collected and for what purpose; know whether personal information is sold or disclosed (we do not sell); opt out of sale (not applicable — we do not sell); delete personal information; and non-discrimination for exercising rights. Submit California privacy rights requests to hello@billbird.io.

14.2 UK Residents (UK GDPR)

UK residents have the same rights as EU residents under UK GDPR. Our UK supervisory authority is the Information Commissioner's Office (ICO): ico.org.uk.

14.3 Other Jurisdictions

We comply with applicable data-protection laws in all jurisdictions where we operate. Contact hello@billbird.io with jurisdiction-specific questions.

15

Contact Us

General privacy enquirieshello@billbird.io — subject: "Privacy Inquiry" — response within 5 business days
GDPR rights requestshello@billbird.io — subject: "[Request Type] – [Your Name]"
Data breach reportshello@billbird.io — subject: "Security" — response within 24 hours
DPO (if applicable)Not required under GDPR Art. 37(1) — small business exemption. Privacy queries: hello@billbird.io
16

Our Transparency Commitments

BillBird commits to: being transparent about all data practices; collecting only the minimum data necessary; using data only for the purposes stated in this Policy; protecting data with industry-leading security; respecting and facilitating all user rights promptly; notifying users of breaches without undue delay; and never selling personal data — ever.

We will maintain a security page at www.billbird.io/security covering best practices, vulnerability disclosure, and security contact information.

Acknowledgment
By using the BillBird Service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein. If you do not agree, please do not use the Service.

© 2026 BillBird
Version 1.2 · 20 April 2026