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Privacy Policy

Last updated 2 August 2026 · Version V1

On this page

  1. Who we are
  2. Information we collect
  3. How we use it
  4. How your transactions are processed
  5. Consent and legal basis
  6. Who we share it with
  7. Where your data is stored
  8. How long we keep it
  9. Cookies and analytics
  10. Your rights
  11. Children
  12. If something goes wrong
  13. Changes to this policy
  14. Contact and complaints

Who we are

TrackE5 is operated by 1521708 B.C. LTD., 13696 100 Ave #2808, Surrey, BC V3T 0L5, Canada.

For any privacy question, or to exercise the rights described below, contact our Privacy Officer at privacy@tracke5.com.

Quebec residents: Law 25 requires a named individual accountable for privacy. That person is Sushil Chaudhari, Founder & Privacy Officer.

Information we collect

We collect the following categories of personal information:

  • Account information — email address, and any name or profile detail you choose to provide.
  • Financial account and transaction data — when you connect a bank account, we receive account balances, transaction amounts, dates, merchant names and account metadata through our providers, Plaid and Flinks. We never receive or store your online banking username or password.
  • Content you add — receipt photographs, manual transactions, budgets, categories and notes.
  • Technical and usage data — IP address, device and browser type, and interactions with the app. Operational telemetry only — timestamps, service health and error types. No transaction content is written to logs.
  • Waitlist information — if you join the waitlist before launch, we collect your email address for the sole purpose of telling you when TrackE5 opens.
  • Support communications — messages you send us.

How we use it

  • To provide the service: importing, categorising, budgeting and reporting on your transactions. Categorisation runs on our servers, not on your device — see How your transactions are processed below.
  • To improve categorisation accuracy, including learning from corrections you make to your own data.
  • To secure the service and prevent fraud and abuse — including alerting you when your account is accessed from a new device, and protecting our sign-up forms from automated abuse.
  • To communicate with you about the service, and — where you have consented — about launch and product news.
  • To meet legal and regulatory obligations.

How your transactions are processed

We want to be precise about this, because it is the question people care about most.

Transaction categorisation runs on our servers in Canada, not on your device. To categorise a transaction, our systems read the merchant name, amount and date supplied by your bank. TrackE5 is not end-to-end encrypted and is not a zero-knowledge service.

Categorisation is deterministic and rule-based. We do not use machine learning models to categorise your spending, and we do not send your transaction data to any third-party AI or inference provider.

Your transaction data is never pooled with other customers' data and is never used to train or improve anything that benefits another customer. Corrections you make improve categorisation within your own account only.

Consent and legal basis

In Canada, we rely on your knowledge and consent under PIPEDA, and on express consent for sensitive financial information. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice; withdrawing consent for bank connections will disable automatic transaction import.

In the United States, we process your information to deliver the service you requested and as otherwise described here.

TrackE5 serves Quebec residents, so Law 25 applies in full: express consent for sensitive financial information, data portability, and a named privacy officer.

Who we share it with

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We share it only with the service providers needed to run TrackE5:

  • Plaid Inc. — bank connectivity in Canada and the United States.
  • Flinks Technology Inc. — bank connectivity in Canada.
  • Google Cloud Platform — hosting, database, storage, secrets and logging.
  • Firebase / Google Identity Platform — account authentication and push notifications.
  • Apple — Sign in with Apple, if you choose it.
  • Google — Google sign-in, if you choose it.
  • Google reCAPTCHA Enterprise — abuse prevention on our forms. It runs when you submit the waitlist or sign-up form and receives your IP address and interaction signals.
  • Google Analytics 4 — product analytics. Events record actions taken, not the contents of your transactions.
  • Resend — transactional and waitlist email.
  • ip-api.com — approximate location lookup from your IP address, used only to tell you where a new sign-in came from.
  • RevenueCat, with Apple, Google or Stripe as processor of record — subscription billing for Pro. We never store full card numbers.

A current list of sub-processors is maintained at https://tracke5.com/legal/subprocessors. We may also disclose information where required by law, or in connection with a merger or acquisition, in which case we will notify you.

Where your data is stored

Your information is stored in northamerica-northeast1 (Montreal, Canada) and may be processed in the United States by the providers listed above.

Information stored in or transferred to the United States may be accessible to US authorities under applicable law.

Before transferring personal information outside Quebec, we assess the privacy protection it will receive, as Quebec Law 25 requires. If you are a Quebec resident and would like to know more about that assessment, contact privacy@tracke5.com.

How long we keep it

We keep your account and transaction data for as long as your account is active, and until you close your account; encrypted backups are purged within 30 days, unless a longer period is required by law.

Waitlist emails are deleted at launch, or immediately on request.

Breach records are retained for 24 months as required under PIPEDA.

Cookies and analytics

We use a small number of cookies and similar technologies:

  • Strictly necessary — to keep you signed in and to keep the service secure. These cannot be turned off.
  • Analytics — Google Analytics 4, to understand which features are used and where people get stuck. Analytics records actions taken, such as creating an account or adding a transaction. It does not record the contents of your transactions.

We do not use advertising or cross-site tracking cookies, and we do not sell or share your information for behavioural advertising.

Analytics cookies are off until you agree to them. The first time you visit, we ask. If you choose "Necessary only", Google Analytics is never enabled and no analytics cookie is set. You can change your mind by clearing this site's data in your browser, which makes us ask again.

Separately, Google reCAPTCHA Enterprise runs when you submit a form, to stop automated abuse. We treat it as strictly necessary, so it is not covered by the choice above.

Your rights

Depending on where you live, you have some or all of the following rights:

  • Access — a copy of the personal information we hold about you.
  • Correction — to fix inaccurate or incomplete information.
  • Deletion — to have your information erased, subject to legal exceptions.
  • Portability — to receive your data in a structured, commonly used electronic format (a right under Quebec Law 25 and several US state laws).
  • Withdraw consent — at any time, as described above.
  • Opt out of sale or sharing — we do not sell or share personal information, so there is nothing to opt out of; we will honour Global Privacy Control signals regardless.
  • Non-discrimination — we will not degrade your service for exercising these rights.

To exercise any of these, contact privacy@tracke5.com. We will respond within 30 days (Canada) or 45 days (most US states). We may need to verify your identity first.

Children

TrackE5 is not directed to children. You must be at least 18 years old to create an account. If we learn we have collected information from anyone under 18, we will delete it.

If something goes wrong

If a breach creates a real risk of significant harm, we will report it to the Office of the Privacy Commissioner of Canada and notify affected individuals as soon as feasible, as required by PIPEDA, and comply with the equivalent obligations under Quebec Law 25 and applicable US state breach-notification laws.

Changes to this policy

We will post any changes on this page and update the date above. If the changes are material, we will notify you directly before they take effect.

Contact and complaints

Privacy Officer, 1521708 B.C. LTD. — privacy@tracke5.com.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Commission d'accès à l'information du Québec if you live in Quebec, or your state Attorney General if you live in the United States.

TrackE5

Automatic expense tracking, built for Canada and the US.

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