Privacy Policy

Who we are

Mirror is operated by Ivannikov Denys, based in Ukraine, the data controller responsible for your personal data. You can reach us at mymirrortracker@gmail.com.

The short version

Mirror is a local-first app. Your transactions, plans, and reflections are stored on your iPhone and synced only through your own Apple iCloud account. We do not run an ad network, we do not sell or rent your data, and we do not build advertising profiles. The data we do process is limited to what keeps the app working and lets us fix problems.

One exception is worth naming up front. When Mirror writes an AI reflection for you, a short statistical summary of the period — counts and percentages, never amounts, merchants, notes, or dates — is sent to an AI provider so it can write that paragraph. Nothing in it identifies you, and we do not keep it. The AI-generated reflections section below sets out exactly what is and is not included.

A second exception: to tell whether the ads we run on Meta and TikTok actually bring people to Mirror, those two platforms receive a handful of anonymous installation-level signals — never your name, email, or anything about your spending. The Ad measurement section below is the exact list.

Data we process

The information involved in running Mirror falls into a few categories:

• Your financial entries. Transactions, plans, and reflections you create. These stay on your device and sync through your private iCloud database. We cannot read them.
• Account identifiers. When you sign in with Apple or Google, we receive an identifier and, depending on your choice, an email or Apple private-relay address — used only to associate your subscription and restore access across your devices.
• Subscription status. Purchase and trial state, and transaction identifiers, handled by our subscription providers to unlock premium features.
• Product analytics. De-identified usage events (for example, which screens are opened) that help us understand how the app is used in aggregate.
• Diagnostics. Crash and error reports, with personal information scrubbed, so we can fix bugs.
• Anonymous spending summaries. Only if AI reflections are switched on: counts, percentages, and your Spending Score for a finished period, sent so an AI model can write that reflection. Never amounts, dates, merchants, or notes. See the dedicated section below.

Third-party processors

We use a small set of vetted providers. Each receives only the data needed for its function:

• Mixpanel — product analytics (de-identified usage events).
• Sentry — crash and error diagnostics (personal data scrubbed).
• RevenueCat — subscription management and entitlements (purchase status, transaction identifiers).
• Superwall — paywall presentation and conversion measurement.
• Sign in with Apple / Google Sign-In — authentication (account identifier, email or private relay).
• Apple iCloud / CloudKit — storage and sync of your financial entries in your own private iCloud database. Apple acts as a processor; the data is not visible to us.
• Supabase — optional email accounts (email address, password credential, account identifier) and the server that brokers AI reflections, which keeps a monthly usage counter per account.
• Anthropic — writes the text of AI reflections from the anonymous statistical summary described below. Anthropic receives no account identifier, and under its commercial API terms this data is not used to train its models.
• Meta (Facebook and Instagram) and TikTok— measure whether the ads we run on their platforms lead to an install, using each platform's own privacy-preserving attribution mechanism rather than your device's advertising identifier. See Ad measurement below for exactly what each receives.

International data transfers

Some of our processors — for example Mixpanel, Sentry, RevenueCat, Superwall, Supabase, Anthropic, Meta, and TikTok — are based in the United States, so your data may be processed outside your country. Where we transfer personal data outside the European Economic Area or the UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework.

Legal bases for processing

If you are in the European Economic Area or the UK, we process your personal data on the following legal bases:

• Performance of a contract — to provide the app, manage your subscription, and restore your purchases.
• Legitimate interests — to keep the app secure, diagnose and fix bugs, and understand aggregate usage to improve the product, balanced against your rights.
• Consent — where required, for example optional analytics, anonymous comparison, and AI-written reflections. Each has its own switch in Settings → Privacy, and you can withdraw your consent at any time.
• Legal obligation — where we are required to retain or disclose data to comply with the law.

On-device storage and sync

Your financial data is stored locally on your device and mirrored to your personal iCloud account so it can sync across the devices signed in to your Apple ID. Your entries themselves — amounts, merchants, notes, and dates — are never stored on Mirror-operated servers. The single case in which any information derived from them leaves Apple's ecosystem is the anonymous statistical summary behind AI reflections, described next.

AI-generated reflections

Some reflections in Mirror are written by an AI model rather than assembled from a template; those are labelled in the app. To write one, Mirror sends a small summary of the finished period through our own server to Anthropic. Because that summary is built to be unit-free, it is worth being precise about its contents.

What is sent: the kind and length of the period; how many expenses you logged; how many categories you used; the share of spending in your top categories as whole percentages; the percentage change against the previous period; your Spending Score, its movement and band; your spending personality; how many recurring payments are active; and, where available, how one category compares with similar households as a percentile.

What is never sent:any amount of money, your currency, any date, any merchant or payee, any note or description you wrote, your name, your email, your account identifier, or your device identifier. Category names travel only if they are one of Mirror's standard categories — anything you renamed or created yourself is sent as "Other", so a category named after your employer or your clinic never leaves your device.

The summary is not stored on our servers; it is passed through and discarded. What our server does keep is a monthly counter per account, so the feature can be capped — that counter records how many reflections you requested, never their contents. The finished text is stored on your device with the rest of your data, and where the model returns nothing usable Mirror falls back to the reflection it composes on your device.

You can turn this off. In the app, go to Settings → Privacy and switch off AI Reflections. Nothing is sent from then on, and Mirror writes your reflections on your device instead. You can switch it back on at any time.

Ad measurement

We run ads for Mirror on Meta (Facebook and Instagram) and TikTok. To learn whether they actually bring people to the app — not to target or profile you — we use each platform's own SDK for install and purchase measurement. This runs without ever asking for the system tracking permission (App Tracking Transparency): Meta measures through its Aggregated Event Measurement system, and TikTok through Apple's own SKAdNetwork. Both are privacy-preserving mechanisms Apple built specifically so ad measurement can work without your device's advertising identifier, and neither platform receives it from Mirror.

What is sent: that the app was installed and opened, that you reached a particular point in onboarding, and — if you subscribe — your plan and whether it is still in a free trial. Each platform also receives an anonymous, per-installation identifier used only to de-duplicate an install and connect it, at most, to an ad you may have seen.

What is never sent: your name, email, Mirror account identifier, or anything about your spending. Neither Meta nor TikTok can tie this activity back to who you are inside Mirror.

Data retention

Your entries persist on your device and in your iCloud until you delete them or delete your account. Analytics and diagnostic records are retained by the respective providers for a limited period in line with their standard retention windows. Deleting your account in Settings removes your local and iCloud data.

Automated processing

Mirror's Spending Score and Spending Personality are generated on your device to help you reflect on your own habits, and some reflections are written by an AI model from the anonymous summary described above. All of it is descriptive: Mirror tells you what your own numbers look like. None of it is financial advice, and none of it is used to make any decision that produces legal or similarly significant effects about you.

Your rights (GDPR / CCPA)

Depending on where you live, you may have the right to access, correct, export, or delete your personal data, and to object to or restrict certain processing. Because most of your data lives on your device, you can exercise much of this directly in the app — including deleting your account and all associated data. For any remaining requests, contact us at the address below.

You also have the right to withdraw consent at any time, where our processing is based on consent, and to lodge a complaint with your local data protection authority.

We do not sell or share your personal information — including for cross-context behavioral advertising — as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA), and we will not discriminate against you for exercising any of your privacy rights.

Children

Mirror is not directed to children. You must be at least 16 years old, or the minimum age of digital consent in your country if that is lower, to use Mirror — the same threshold set out in our Terms of Use. We do not knowingly collect personal data from anyone below that age. If you believe a child has provided us with personal data, please contact us so we can remove it.

Changes to this policy

We may update this policy as the app evolves. Material changes will be reflected here with an updated date at the top of the page.

Contact

Questions about privacy? Email us at mymirrortracker@gmail.com.