529 Tracker — Privacy Policy

Version 3.0 — Last Updated: June 2026

Effective immediately or upon release of the app by Apple to the public, whichever occurs later.

Our Privacy Commitment

We are committed to protecting your personal and financial information. 529 Tracker securely stores your data using Google Firebase, employs industry-standard encryption, and never sells your information.

What We Collect and Why

1. Financial Information

Your expense and reimbursement entries, 529-eligible spending records, and related amounts.

Used only to generate reports, sync data across your devices, and calculate cost-of-attendance caps and related totals.

No banking, card, or account-number information is stored.

Subscription Payments. All payment processing for 529 Tracker subscriptions — including your credit card, billing address, and Apple ID — is handled by Apple through the App Store. We never see, receive, or store your payment information. Your subscription status is verified directly between your device and Apple's servers using StoreKit; we do not store subscription records on our servers. You can review Apple's privacy practices at https://www.apple.com/legal/privacy/.

2. User Content

Receipt images or photos you choose to upload.

Stored in Firebase Storage to let you organize and retrieve receipts for tax documentation.

3. Identifiers

A randomly generated Firebase User ID and anonymous Device ID.

Each entry stored in Firestore is linked to your unique Firebase User ID to ensure that only you can access your own records.

These identifiers are used solely for authentication, syncing, and data protection — never for marketing, profiling, or advertising.

4. Contact Information

Email address and name (if entered).

Used for authentication, subscription management, and customer support, and occasional communications such as feedback requests or important product updates.

The name field may also be used within the app to label student profiles, personalize exports and reports for tax preparation, and help users differentiate between multiple students or accounts.

This information is never sold, shared, or used for marketing or advertising purposes.

5. How We Protect Your Data

• Encryption in Transit — All communication uses HTTPS (TLS 1.2+)

• Encryption at Rest — Firebase encrypts data with AES-256

• Authentication — Secure sign-in via Firebase Auth; passwords are never visible to us

• Access Controls — Only you (and authorized family-sharing users) can view your records

6. How We Use Your Data

• Provide core features such as syncing, exporting, and report generation

• Process your subscription through Apple's StoreKit

• Maintain anonymized logs for error detection and performance analytics

We do not use your data for advertising, profiling, or resale.

7. Data Access and Administrative Visibility

Receipt images and financial entries you upload are securely stored in Google Firebase. While these files are private to your account inside the app, authorized administrators of Charlie Mike Studios (the operator of 529 Tracker) can technically access stored data through the Firebase Console.

Administrative access is used only when necessary to:

• Provide direct support at your request

• Diagnose and fix technical problems

• Investigate suspected abuse, fraud, or security issues

• Comply with valid legal requests or obligations

We do not routinely review or analyze individual user data, and we never sell, share, or use this content for marketing or advertising. Console access is restricted to a minimal number of authorized personnel, protected by multi-factor authentication, and governed by strict internal confidentiality controls.

8. Data Retention

• Active accounts: kept while your account remains active

• Deleted accounts: all personal data and receipts are permanently erased

• Minimal pseudonymized compliance records (hashed ID + timestamp + policy version) are retained for legal confirmation only

9. Third-Party Services

We rely on:

• Firebase (Google Cloud) for authentication, storage, and sync

• Apple StoreKit for subscription purchases

• Google Gemini, via Firebase AI Logic, to power the optional AI Assistant when you choose to use it (see Section 10)

These services follow their own published privacy policies and industry certifications (SOC 2 Type II, ISO 27001). No other third parties receive or process your data.

10. AI Assistant (Optional Feature)

529 Tracker includes an optional AI Assistant you can use to ask questions about your own records in plain language. It is only active when you choose to open it and submit a question.

When you ask a question, your question text and the specific figures needed to answer it — such as a student's name and amounts calculated from your entries — are sent to Google's Gemini model through Firebase AI Logic (Google Cloud) to generate a written response. All underlying calculations are performed within the app; the AI only puts the results into words for organizational purposes.

Because our use of Google's Gemini API is billing-enabled, Google processes your question and the figures sent to answer it only to generate that response; under Google's terms for paid use, this content is not used to train or improve Google's models and is retained only briefly for abuse detection.

529 Tracker itself does not store your questions or the Assistant's answers on our servers.

Charlie Mike Studios does not use these interactions for marketing, profiling, or advertising. The Assistant is provided for organizational purposes and is informed by IRS Publication 970 guidelines; it is not tax, legal, or financial advice. Please confirm any figures with a qualified tax professional or accountant before relying on them, and avoid entering information you would not want processed by Google.

11. Your Rights & Choices

• Export reports (PDF or CSV) anytime

• Delete your account and all data

• Contact support for questions or assistance

12. Transparency Promise

Your information is used only to operate and improve 529 Tracker. We will promptly notify users of any material policy changes.

Contact

Questions about privacy or security: support@charliemikestudios.com

This policy is also available on our website at charliemikestudios.com/privacy-policy

© 2026 Charlie Mike Studios LLC. All Rights Reserved.