Drizzle DCA Privacy Policy

Last updated: November 7, 2025

1. Data Controller

Lizerd ("we", "our", or "us") is the data controller responsible for Drizzle DCA. We are committed to protecting your privacy and handling data in an open and transparent manner.

2. Information We Collect and Process

2.1 Data Collected Automatically

• Investment Configuration: DCA schedules, amount settings, frequency preferences (stored locally)
• Portfolio Data: Investment performance, transaction history, asset allocation
• Device Information: iOS version, device model, app version, unique device identifiers
• Usage Analytics: Feature usage patterns, session duration, investment activity
• Technical Data: Crash logs, error reports, performance metrics

2.2 Financial Data

• Investment Amounts: DCA investment amounts and frequency settings
• Portfolio Values: Total portfolio value and individual asset holdings
• Performance Metrics: Returns, gains/losses, investment performance over time

2.3 Legal Basis for Processing

We process your data based on legitimate interest to provide investment tracking services and comply with financial regulations. Investment data is processed with your consent for portfolio management purposes.

3. Data Storage and Security

Local Storage: Investment configurations and portfolio data are stored locally on your device using iOS secure storage mechanisms with encryption.

iCloud Sync: If enabled, investment configurations may sync across your devices through Apple's iCloud service, subject to Apple's privacy policy.

Financial Data Security: All financial data is encrypted both at rest and in transit using bank-grade security protocols.

Data Retention: Analytics data is retained for 26 months maximum. Investment data persists until app deletion or manual removal.

4. Third-Party Services and Data Sharing

We use the following third-party services that may process anonymized data:

• Analytics: Apple App Analytics (anonymized usage data)
• Crash Reporting: Apple Crash Reports (device and app version data)
• Market Data: Cryptocurrency price feeds (no personal data shared)

Important: We never share your investment amounts, portfolio values, or personal financial information with third parties.

5. Investment Data Processing

Drizzle DCA processes investment data to provide its core functionality:

• DCA Scheduling: Investment amounts, frequencies, and automation settings
• Portfolio Tracking: Asset values, performance metrics, allocation percentages
• Performance Analytics: Returns calculation, trend analysis, investment insights
• Market Data: Real-time prices, market trends (aggregated, non-personal data)

Data Protection: All investment data is encrypted and stored locally. We do not access your specific investment amounts or portfolio values.

6. Your Rights (GDPR, CCPA, and Other Privacy Laws)

Depending on your location, you may have the following rights:

• Access: Request information about data we process
• Deletion: Request deletion of your data (delete app to remove local data)
• Portability: Request investment data in a portable format
• Opt-out: Disable analytics in iOS Settings > Privacy & Security > Analytics & Improvements
• Non-discrimination: We will not discriminate for exercising privacy rights

To exercise your rights, contact us at hello@lizerd.tech. We will respond within 30 days (or as required by applicable law).

7. Financial Data Compliance

We comply with applicable financial data protection regulations and maintain appropriate safeguards for investment information. Your financial data is never sold or used for purposes other than providing DCA investment services.

8. International Data Transfers

As data is stored locally on your device and we use Apple's services, any international transfers are governed by Apple's data processing agreements and adequate protection mechanisms.

9. Data Breach Procedures

In the unlikely event of a data security incident affecting financial data, we will notify affected users and relevant authorities within 72 hours as required by applicable law, and provide clear information about the incident and remedial actions.

10. Changes to This Privacy Policy

We may update this policy to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through the app or this page with at least 30 days advance notice. Continued use constitutes acceptance of changes.

11. Contact Information

For privacy questions, concerns, or to exercise your rights:

Email: hello@lizerd.tech

Response Time: Within 30 days

Data Protection Officer: Available upon request for EU residents