Privacy Policy

Last updated: August 2, 2026

This page contains important information about your rights and obligations. If anything here conflicts with rights that cannot be waived under applicable law, those rights apply.

1. Overview

This Privacy Policy explains how Frobly collects, uses, stores, shares, and protects personal information when you use our website, apps, subscription tracking tools, import/audit features, billing pages, and related services.

Frobly is operated by Panon Valley LLC.
Controller/contact: Panon Valley LLC, 30 N Gould St Ste R, Sheridan, WY 82801, United States, privacy@frobly.com.

2. Important note

Frobly helps you organize subscription and recurring payment information. Do not upload information that is not needed for this purpose. Do not upload full card numbers, security codes, government IDs, passwords, or data belonging to someone else unless you are authorized to do so.

3. Information we collect

Account information

• email address;
• password hash if you use email/password login;
• Google or Apple account identifiers if you use social sign-in — we store the provider's stable account identifier and your email address, not your Google or Apple profile name or picture;
• account preferences and settings, such as your preferred currency;
• your plan and entitlement status.

Frobly does not ask for or store a real name, display name, postal address, or phone number for your Frobly account. If you buy Guard, Stripe collects a name and billing address at checkout for payment and tax purposes and holds them under its own controls — see section 8.

Subscription and audit information

These are the subscriptions you track in Frobly, such as a streaming service or a gym — not your Frobly plan.

• merchant/subscription names;
• amounts, currencies, billing cycles, renewal dates, trial end dates, categories, notes, cancellation links, and status;
• reminder settings for each tracked subscription;
• the results of each statement scan: the recurring-charge candidates we detected, the dates that matched each candidate, and which candidates you imported;
• a summary of each scan — counts of rows parsed, rejected and reviewed, any warnings, the column names detected in a CSV, and the number of pages processed.

Statement files you upload (web CSV and text-PDF import)

When you upload a CSV or text-based PDF statement, the file is read in memory to extract transactions and is then discarded.

• We do not store the uploaded file. No copy of your statement file, and no image of it, is written to our servers or our database.
• We do not store the individual transaction rows read out of it. What is saved is the detected recurring-charge candidates and the scan summary described above.
• A detected candidate does include a merchant name derived from the transaction description, together with the amount, currency, and the dates that matched.

Statement scanning in the Frobly mobile apps works differently and is described in section 9a.

Payment and billing information we hold

When you buy Guard, Frobly stores only the references it needs to know what you are entitled to:

• your Stripe customer ID and subscription ID;
• the price ID of the plan you bought (Guard monthly or Guard yearly);
• the subscription status, the current billing period's start and end, whether it is set to cancel at period end, whether it is paused, and when it was canceled;
• a short record of the Stripe events we have processed — the event's identifier, type, and timestamps.

Frobly does not receive or store your card number, card security code, card brand, or the last four digits of your card. Payment details are collected and held by Stripe/Link as merchant of record — see section 8.

Technical and usage information

• IP address;
• device/browser/app information;
• operating system;
• log data;
• approximate location derived from IP;
• pages or features used;
• error, security, and diagnostic events.

Support communications

• messages you send to support;
• attachments you choose to provide;
• information needed to respond to your request.

Cookies and local storage

We may use cookies, local storage, or similar technologies for login sessions, security, preferences, analytics, and service functionality.

4. How we use information

We use information to:

• create and secure accounts;
• provide subscription tracking, imports, audits, dashboards, and reminders;
• process payments and manage plans;
• prevent abuse, fraud, and unauthorized access;
• troubleshoot bugs and provide support;
• improve Frobly's reliability and usability;
• comply with legal, tax, accounting, security, and dispute obligations;
• communicate service, billing, security, and policy updates.

5. Legal bases for processing

Depending on your location, we process personal information under these legal bases:

• Contract: to provide Frobly and paid features you request.
• Consent: where required, such as optional permissions, certain cookies, or connecting third-party accounts.
• Legitimate interests: to secure, maintain, debug, improve, and prevent abuse of the service.
• Legal obligations: to comply with tax, accounting, consumer protection, payment, and lawful request obligations.
• Legal claims: to establish, exercise, or defend legal rights.

6. Google API and Limited Use disclosure

If you connect Google services or use Google sign-in, Frobly may receive information authorized by you and permitted by Google.

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

We do not sell Google user data. We do not use Google user data for advertising. We do not use Google user data to train generalized artificial intelligence or machine learning models. We only use Google user data to provide or improve user-facing Frobly features that you choose to use, secure the service, comply with law, or as otherwise permitted by Google's policies and disclosed to you.

7. How we share information

We may share information with:

• hosting and infrastructure providers;
• database, storage, monitoring, and security providers;
• Stripe and Link, which sell and process the Guard subscription as merchant of record (section 8);
• authentication providers such as Google and Apple;
• email/support providers;
• analytics or diagnostics providers, if enabled;
• professional advisers, auditors, accountants, lawyers, or insurers;
• authorities or third parties where required by law, lawful process, safety, fraud prevention, or protection of rights;
• successors in a merger, acquisition, financing, restructuring, or sale of assets.

We do not sell personal information.

8. Payment processing — Stripe and Link

The Guard subscription is sold using Stripe's Managed Payments, which makes Stripe, through Link, the merchant of record for the payment. Checkout and your receipts may show that the purchase was "Sold through Link".

This means Stripe collects and controls the payment data: your payment method, the name and billing address it requires for payment and tax purposes, the transaction and order records, receipts and invoices, and any refund or dispute records. Stripe processes that information under its own terms and privacy policy, and retains or deletes it according to its own policies, legal obligations, and Managed Payments processes — not according to this Policy. Payment, order-history and refund support for the transaction is handled by Link support.

Panon Valley LLC does not process card payments and does not receive or hold your payment credentials. What Frobly holds is the small set of billing references listed in section 3, which is what lets us know whether your account is entitled to Guard.

Deleting your Frobly account does not, by itself, delete the records Stripe/Link holds about the payment. To ask about the data Stripe/Link holds, contact Stripe or Link directly.

9. Retention

We keep personal information only as long as reasonably necessary for the purposes described in this Policy, including providing the service, maintaining records, resolving disputes, preventing fraud, complying with law, and enforcing agreements.

What we actually keep:

• Uploaded statement files — not kept at all. A CSV or text-PDF you upload is read in memory and discarded. No copy is written to our servers or database. Statement images and PDF pages on mobile never reach us in the first place (section 9a).
• Individual transaction rows — not kept. The rows read out of a statement are used to detect recurring charges and are not stored. What is stored is the detected candidates and the scan summary.
• Scan records (audits) and tracked subscriptions — kept until you delete them or delete your account. They are not automatically expired, and they are not deleted if your Guard subscription ends. Deleting a tracked subscription or deleting your account removes them.
• Account data — kept while your account exists. On deletion it is anonymized rather than kept (section 13).
• Billing records held by Frobly — retained after account deletion. The billing record described in section 3 is the record of a payment relationship that actually existed. It is kept, marked as belonging to a deleted account, for tax, accounting, dispute, fraud-prevention and legal purposes. It contains no name, no address and no card data, and it grants no access to anything.
• Stripe event records — kept for 90 days. The short log of processed payment events is automatically deleted 90 days after it is received. It holds an event identifier, an event type and timestamps.
• Payment data held by Stripe/Link — governed by Stripe, not by us. See section 8.
• Server and security logs — retained for a limited period for security, fraud prevention, debugging, and legal protection. We do not log statement text, transaction descriptions, account numbers, or the rows you submit.
• Support messages — retained as needed to handle your request and to maintain business records.

We may keep information longer than described above where we are required or permitted to do so — for example to comply with a legal, tax or accounting obligation, to establish or defend a legal claim, to handle a payment dispute or chargeback, or to prevent fraud and abuse.

9a. On-device statement scanning (Frobly mobile apps)

The Frobly apps for iPhone and Android can read a bank or card statement from photos, screenshots, or a scanned PDF. This reading happens on your device.

• Your statement images are not uploaded to Frobly for text recognition. The recognition runs locally on your phone using on-device text recognition. No third-party text-recognition service receives your images.
• While a scan is in progress, the app writes temporary working copies of the pages into its own private storage on the device. Frobly deletes those copies when the scan finishes or is abandoned. Frobly does not delete photos or files you selected or created yourself — those remain under your control and your device's control.
• After you review the extracted rows, the transaction details you choose to submit are sent to Frobly — the date, description, amount, currency, and whether the row is money in or money out — so that we can look for recurring charges. Nothing is submitted until you confirm.
• Card and account numbers detected inside a description are removed before a row can be submitted.
• The resulting audit and any subscriptions you choose to import are stored in your account, as described elsewhere in this policy. Frobly does not store the original statement images or rendered pages.

Text recognition is not perfect. You review and correct the extracted rows before anything is submitted, and Frobly does not guarantee that every charge or subscription is detected.

10. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information, including encryption in transit, access controls, authentication, logging, and least-privilege practices where appropriate.

No system is perfectly secure. You are responsible for protecting your account credentials and devices.

11. International transfers

Frobly and our service providers may process information in countries other than where you live. Where required, we rely on appropriate safeguards or legal mechanisms for cross-border transfers.

12. Your privacy rights

Depending on your location, you may have rights to:

• access your personal information;
• correct inaccurate information;
• delete your information;
• export or receive a copy of your information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• opt out of certain uses where applicable;
• lodge a complaint with a data protection authority.

To make a request, contact privacy@frobly.com. We may need to verify your identity before responding.

13. Account deletion — what actually happens

You can delete your account yourself from Profile → Delete account in the app, or by contacting privacy@frobly.com. Deletion runs in a fixed order, and we describe it here precisely rather than promising that everything disappears.

1. Your Guard subscription is canceled first. If the payment provider cannot be reached or the cancellation fails, the deletion is refused and nothing is removed — your account, data and subscription are left exactly as they were and you can try again. This ordering exists so a deleted account can never leave a live recurring charge behind.
2. Your tracked subscriptions and your scan/audit records are deleted.
3. Your identity is anonymized and disabled. Your email address is replaced with a non-deliverable placeholder, your password hash and any Google or Apple account identifiers are cleared, and the account is disabled so nobody can sign in as it. The record itself is kept in an anonymized state rather than erased, because other records reference it.
4. The billing record is retained and marked as belonging to a deleted account, as described in section 9. It contains no name, no address and no card data.

Deletion does not remove the payment data held by Stripe/Link. As merchant of record, Stripe holds the transaction, receipt, tax and refund records for your purchase and retains or deletes them under its own policies and legal obligations. Contact Stripe or Link about that data.

We may also retain information where required or permitted for legal, tax, accounting, security, fraud-prevention, dispute or backup reasons. Backups are not rewritten on request; information removed from live systems can persist in backups until they age out.

14. Children

Frobly is not intended for children and may only be used by adults. We do not knowingly collect personal information from children. If you believe a child provided information to Frobly, contact privacy@frobly.com.

15. Automated decisions

Frobly may automatically classify transactions or suggest possible subscriptions. These suggestions are for organization only and may be inaccurate. Frobly does not make legal, credit, employment, insurance, or similarly significant automated decisions about you.

16. Changes

We may update this Privacy Policy from time to time. If changes are material, we will provide notice as appropriate.

17. Contact

Privacy questions and requests: privacy@frobly.com.