Privacy Policy
1. Introduction
This Privacy Policy explains how Central Nordic Services Oy ("we", "us", "our") handles personal data when you visit this website, create an account or use the Secure Clean app. We designed Secure Clean so that the content of your photos and contacts stays on your device, and this policy describes exactly where that line sits.
By using our website or app you confirm that you have read this policy. If you do not agree with it, please do not use the service.
2. Data controller
The controller responsible for your personal data is Central Nordic Services Oy, Åkerlundinkatu 11, 33100 Tampere, Suomi. You can reach us about any privacy question at contact@simplecapitalfinance.com.
We are established in Finland, and we process personal data in line with the EU General Data Protection Regulation (GDPR) and the Finnish Data Protection Act.
3. Information we collect
We collect only what we need to run the service. This includes:
- Account data: your email address and the password issued to you after purchase.
- Order data: the plan you chose, price, billing dates, payment status and renewal status.
- Messages: anything you write to us through the contact form or by email.
- Technical data: device model, iOS version, app version, language, and approximate region derived from your IP address.
4. Photos, contacts and device permissions
Secure Clean asks for access to your Photo Library and Contacts so that its tools can find duplicates, compress images, remove metadata and tidy your address book. This analysis runs locally on your iPhone.
The content of your photos and contacts is not uploaded to Secure Clean servers, is not sold and is not used to build advertising profiles. You choose which items to change or delete, and you can withdraw access at any time in iOS Settings.
5. How we use your information
We use personal data to:
- create and secure your account and give you access to Premium features;
- process payments, renewals, cancellations and refunds;
- answer questions and provide customer support;
- send important service messages such as receipts, password details and changes to our terms;
- detect abuse, prevent fraud and keep the service stable;
- understand how the product is used so we can improve it.
6. Legal bases for processing
We rely on the following bases under GDPR: performance of a contract (providing your subscription and account), legitimate interests (security, fraud prevention, product improvement and support), legal obligation (accounting and tax records) and consent where required, for example for optional notifications or non-essential cookies.
Where we rely on consent, you may withdraw it at any time without affecting processing that took place before withdrawal.
7. Sharing and service providers
We do not sell your personal data. We share it only with trusted providers acting on our instructions, such as payment processors, email delivery services, hosting and customer-support tools, and with authorities when the law requires it.
Each provider receives only the data it needs for its task and is bound by contractual confidentiality and data protection obligations.
8. International transfers
Some providers may process data outside the European Economic Area. When that happens we use safeguards recognised by EU law, such as the European Commission's Standard Contractual Clauses or an adequacy decision, together with additional technical and organisational measures where appropriate.
9. Data retention
We keep personal data only as long as needed for the purposes described above. Account and order data are kept while your account is active and afterwards for the period required by accounting and tax law. Support messages are generally deleted after they are resolved and the limitation period has passed.
When data is no longer needed we delete it or anonymise it.
10. Security
We protect personal data with encryption in transit, access controls, regular software updates and limited staff access. Local processing of photos and contacts on your device also reduces the amount of sensitive data we ever hold.
No system is perfectly secure. If a breach affects your rights and freedoms we will notify you and the supervisory authority as required by law.
11. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct inaccurate or incomplete data;
- request deletion of your data;
- restrict or object to certain processing;
- receive your data in a portable format;
- withdraw consent at any time.
To exercise a right, write to contact@simplecapitalfinance.com. We will reply within one month. You also have the right to complain to the Finnish Data Protection Ombudsman (tietosuoja.fi) or your local authority.
12. Children
Secure Clean is not directed at children under 16 and we do not knowingly collect their personal data. If you believe a child has provided us with information, contact contact@simplecapitalfinance.com and we will delete it promptly.
13. Changes and contact
We may update this policy when our service or the law changes. The new version will be published on this page with an updated date, and we will notify you of material changes by email or in the app.
Questions or requests? Contact Central Nordic Services Oy, Åkerlundinkatu 11, 33100 Tampere, Suomi, email contact@simplecapitalfinance.com.