Terms of Service

Last updated: March 2026

Disclaimer: This is a provisional document pending final legal review. For any questions, contact us at hello@spendable.pro.

1. Acceptance of Terms

By accessing or using Spendable, you agree to be bound by these Terms of Service. If you do not agree, please do not use the service. We reserve the right to modify these terms at any time, and continued use of the service constitutes acceptance of any changes.

2. Description of Service

Spendable is a personal finance application that allows users to track bank accounts, cryptocurrency wallets, and stock portfolios in one interface. The service provides budgeting tools, financial insights, and net worth tracking. Spendable is not a financial advisor and does not provide investment advice.

3. User Accounts

You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You must provide accurate and complete information when creating your account. You agree to notify us immediately of any unauthorized use of your account.

4. Financial Data

For the closed beta, bank connections are provided by Salt Edge Limited, a licensed Account Information Service Provider (AISP) authorized by the UK Financial Conduct Authority (reference number 822499) and ISO 27001 certified. Spendable never sees or stores your banking credentials, and all connections are strictly read-only: we can view balances and transactions, but we cannot move, transfer, or modify any funds. Additional open-banking providers (such as Plaid) may be added as we move beyond the closed beta. Connections use TLS 1.3 in transit and AES-256 at rest.

5. Crypto-Asset Disclosure

Spendable allows you to track crypto-asset holdings in read-only mode only. We do not hold, custody, trade, execute orders, or provide advice on crypto-assets. The service does not fall within the scope of authorized activities under Regulation (EU) 2023/1114 (MiCA) for Crypto-Asset Service Providers (CASP) as defined in Art. 3(1)(16). Crypto-asset values are highly volatile; displayed prices are indicative only and may not reflect real-time market conditions. Past performance does not indicate future results.

6. Refund Policy

You may request a full refund within 30 (thirty) days of your purchase date, no questions asked. To request a refund, email hello@spendable.pro from the address used at checkout. Refunds are processed within 30 days of request to the original payment method. After the 30-day window, the lifetime-access purchase is non-refundable, except where mandatory consumer-protection law provides otherwise.

Consumer right of withdrawal (EU). Consumers in the EU have a 14-day right of withdrawal under Art. 52 of Italian Legislative Decree 206/2005 (Codice del Consumo). By proceeding with checkout and expressly requesting immediate access to the digital product during that period, you consent to the immediate performance of the contract and acknowledge the loss of the right of withdrawal pursuant to Art. 59(o) of the same Decree. The 30-day contractual refund policy above remains unaffected and applies in addition to your statutory rights.

7. Beta Product Disclosure

Spendable is offered as a closed beta via Apple TestFlight. The service is evolving, features may change, be added, or be removed without notice, and occasional interruptions or data loss incidents are possible. You accept these characteristics as part of participating in a beta program. This disclosure is provided in accordance with Art. 49 of the Italian Consumer Code.

8. Limitation of Liability

Spendable is provided "as is" without warranties of any kind, to the maximum extent permitted by applicable law. We are not a financial advisor and do not provide investment, tax, or legal advice. The Spendable Score, AI insights, and any information displayed in the app are informational only and do not constitute personalized recommendations within the meaning of MiFID II. You are solely responsible for financial decisions you make based on information displayed. Always verify important financial information directly with your institutions. Nothing in these Terms limits liability for gross negligence, wilful misconduct, or any other liability that cannot be limited under applicable law.

9. Governing Law and Dispute Resolution

These Terms are governed by Italian law, without prejudice to mandatory consumer-protection provisions of the country in which the consumer has their habitual residence. For consumers resident in the EU, the competent court is the court of the consumer's place of residence (Art. 66-bis of Italian Legislative Decree 206/2005). The European Commission provides an Online Dispute Resolution platform accessible at https://ec.europa.eu/consumers/odr. Consumers may also use any applicable alternative dispute resolution (ADR) body.

10. Contact

For questions about these Terms, contact us at hello@spendable.pro.