Privacy Policy

Last updated: April 2026

Filtercode LTD ("we", "us", "our") operates the Folio application and the folioapp.uk website. This Privacy Policy explains how we handle your information when you use our app and visit our website.

Folio is designed around a simple principle: your data stays on your device. We do not operate servers, we do not collect personal data, and we cannot access your documents, subscriptions, or financial information.

Data Controller

Filtercode LTD is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Contact: support@folioscan.uk

Information We Process

We categorise information into four types based on where it is processed and stored:

a) Data Processed On-Device (never leaves your device)

All documents, subscriptions, financial data, and AI analysis are processed entirely on your device using Apple's on-device Foundation Models. This includes:

• Scanned documents (invoices, receipts, contracts, bills)
• Extracted metadata (provider names, amounts, dates, categories)
• Subscription records and renewal tracking
• Natural language search queries and results
• Spending insights and summaries

This data is stored locally on your device. Filtercode LTD does not operate servers and has no infrastructure to receive, store, or access this data.

b) Data Stored in Your iCloud (optional)

If you enable iCloud sync, your data is stored in your personal CloudKit container — a private area of your own iCloud account. This data is encrypted in transit and at rest by Apple. Filtercode LTD cannot access your CloudKit container. iCloud sync is governed by Apple's Privacy Policy.

c) Data Accessed via Email Providers (processed on-device, not retained)

Folio offers an optional email scanning feature that connects to your email provider to discover subscriptions and billing information. See the "Email Scanning" section below for full details.

d) Anonymous Website Analytics

Our website (folioapp.uk) uses Google Analytics via Firebase in cookieless mode. No tracking cookies are set, no personally identifiable information is collected, and no data is linked to your identity. We collect only aggregate, anonymous usage data (page views, button clicks) to improve the website. This data is processed by Google under their Privacy Policy and may be transferred to the US under Google's Standard Contractual Clauses.

Lawful Basis for Processing

Under UK GDPR Article 6(1), we rely on the following lawful bases:

• Contract performance — processing your documents and subscriptions on-device is necessary to provide the core app functionality you have requested.
• Consent — email scanning (connecting to Gmail, Outlook, or IMAP) and iCloud sync are optional features that require your explicit opt-in. You can withdraw consent at any time by disconnecting the service within the app.
• Legitimate interests — anonymous website analytics help us understand how visitors use our website and improve the experience. This does not involve personal data or tracking.

On-Device AI Processing

Folio uses Apple's Foundation Models framework to power intelligent document scanning, metadata extraction, natural language search, and spending insights. All AI processing runs entirely on your device. No data is sent to any server — not to Filtercode LTD, not to Apple, and not to any third party — for AI processing. The Foundation Models framework requires iPhone 15 Pro or later, or an iPad/Mac with an M-series chip.

Email Scanning

Folio offers an optional email scanning feature that connects to your email provider to automatically discover subscriptions, trials, invoices, and price changes.

How it works

• Authentication: You sign in directly with your email provider (Gmail, Outlook, or IMAP) using OAuth 2.0. Folio never sees or stores your email password.
• Data accessed: Folio requests read-only access to your emails. For Gmail, this uses the gmail.readonly scope. For Outlook, this uses the Mail.Read scope.
• On-device processing: Emails are fetched to your device and processed locally by Foundation Models. Only subscription metadata (provider name, amount, billing frequency, dates) is extracted.
• No data retained: Raw email content is held in memory only during the scan and is immediately discarded. No email content is stored, saved, or transmitted anywhere.
• Token storage: OAuth tokens are stored in your device's Keychain with device-only access (kSecAttrAccessibleWhenUnlockedThisDeviceOnly). Tokens are not backed up to iCloud.
• Disconnect at any time: You can disconnect your email provider from within the app at any time, which immediately revokes Folio's access and deletes stored tokens.

What we do NOT do with your email data

• We do not sell or share email data with any third party
• We do not use email data for advertising, retargeting, or marketing
• We do not use email data to assess creditworthiness or for lending purposes
• We do not use email data to train general-purpose AI or machine learning models
• We do not allow any human — including Filtercode LTD employees — to read your emails
• We do not store raw email content beyond the duration of a single scan session

Google API Services Compliance

Folio's use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Data obtained through the Gmail API is restricted to providing the email scanning feature described above. It is not transferred to third parties except as necessary for security investigations or legal compliance.

App Store Privacy Label

Folio's App Store privacy nutrition label declares "Data Not Collected". This is accurate because all data processed by Folio stays on your device or in your personal iCloud container. Filtercode LTD does not transmit, receive, or store any data from the app on our own servers — because we do not operate any servers.

Under Apple's definition, "collect" means transmitting data off the device in a way that allows the developer to access it for longer than necessary to service the request in real time. Since Folio never transmits data off your device to us, no data is "collected" as defined by Apple.

Third-Party Services

Folio integrates with the following third-party services:

• Apple (iCloud/CloudKit) — optional cross-device sync. Data is stored in your private iCloud container and governed by Apple's Privacy Policy.
• Apple (App Store/StoreKit) — in-app purchases and subscriptions. Payment processing is handled entirely by Apple.
• Google (Gmail API) — optional email scanning. Read-only access to your emails, processed on-device. Governed by Google's Privacy Policy.
• Microsoft (Graph API/Outlook) — optional email scanning. Read-only access to your emails, processed on-device. Governed by Microsoft's Privacy Statement.
• Google (Firebase/GA4) — anonymous website analytics only (not in the app). Cookieless mode, no PII collected.

Each third-party service provides protection of your data as described in their respective privacy policies. We do not share data between these services.

Data Retention

• On-device data: Retained until you delete the app or clear app data from your device settings.
• iCloud data: Retained until you remove it via Apple ID settings (Settings → [Your Name] → iCloud → Manage Storage → Folio).
• Email OAuth tokens: Retained in your device Keychain until you disconnect the email provider from within the app.
• Raw email content: Not retained. Held in memory only during a scan session and immediately discarded.
• Website analytics: Retained by Google per their standard GA4 retention policy (14 months, anonymised).

International Data Transfers

Folio does not transfer your app data outside your device or your iCloud region. The only international transfer relates to our website: anonymous website analytics data may be processed by Google in the United States under Google's Standard Contractual Clauses, as approved by the UK Information Commissioner's Office.

Automated Decision-Making

Folio does not perform automated decision-making or profiling as defined by UK GDPR Article 22. The AI features in Folio (document scanning, metadata extraction, natural language search, spending insights) are user-initiated tools that assist you in organising your information. They do not make decisions that produce legal effects or similarly significantly affect you.

Your Rights

Under the UK GDPR and Data Protection Act 2018, you have the following rights:

• Right of access — request a copy of your personal data
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your data
• Right to restrict processing — request that we limit how we use your data
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — withdraw consent at any time for optional features (email scanning, iCloud sync). Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Since Folio processes data on your device and we do not hold your personal data, most of these rights are exercised directly through your device and Apple's settings:

• Delete local data: Delete the Folio app or clear its data in device settings
• Delete iCloud data: Go to Settings → [Your Name] → iCloud → Manage Storage → Folio
• Disconnect email access: Go to Folio → Settings → Email Scanning → Disconnect

For any data-related requests, contact us at support@folioscan.uk. We will respond within one month.

Right to Complain

You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been infringed.

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
United Kingdom

Website: ico.org.uk
Telephone: 0303 123 1113

Children's Privacy

Folio is a financial management tool intended for users aged 16 and over. We do not knowingly process data from children under 16. If you believe a child has used Folio, please contact us at support@folioscan.uk.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The "Last updated" date at the top of this page indicates when the policy was most recently revised. For material changes, we will include a note in the app's update release notes. Your continued use of Folio after changes are posted constitutes your acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Filtercode LTD
Email: support@folioscan.uk