earmarkIQ
Last updated: 12 August 2026
earmarkIQ ("we", "us", "our") is a personal finance application operated by earmarkIQ Ltd, a company registered in England and Wales (company number 17056081). Registered office: Flat 3, Ash Lodge, Northbourne Road, London, SW4 7DS, United Kingdom.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, we are the data controller. We are registered with the Information Commissioner's Office (registration number CSN2001882).
earmarkIQ Ltd is an FCA Appointed Representative of Finexer Ltd (FCA firm reference 925695), which is authorised and regulated by the Financial Conduct Authority.
Contact: privacy@earmarkiq.app
When you register, we collect:
When you connect your bank account, we access your transaction data through Open Banking provided by Finexer Ltd (FCA firm reference 925695), an FCA-authorised Account Information Service Provider. earmarkIQ Ltd operates as an FCA Appointed Representative of Finexer. The data we retrieve includes:
| Purpose | Legal Basis (UK GDPR) |
|---|---|
| Provide spending analysis and financial insights | Contract performance (Art. 6(1)(b)) |
| Generate your financial profile and habit persona | Contract performance (Art. 6(1)(b)) |
| AI processing: transaction classification, Ask IQ chat, weekly briefings, annual recaps (see section 4) | Contract performance (Art. 6(1)(b)) |
| Personalised product recommendations | Legitimate interest (Art. 6(1)(f)) |
| Send push notifications (insights, alerts) | Consent (Art. 6(1)(a)) |
| Detect subscription price increases | Contract performance (Art. 6(1)(b)) |
| Process subscription payments | Contract performance (Art. 6(1)(b)) |
| Prevent fraud and ensure security | Legitimate interest (Art. 6(1)(f)) |
| Improve our service and fix bugs | Legitimate interest (Art. 6(1)(f)) |
The app's core features are powered by AI. Our AI provider is Anthropic PBC, whose Claude models process your data for the following purposes:
To perform the processing above, we send Anthropic:
We never send Anthropic: your bank credentials, your account numbers, or full account identifiers.
Under Anthropic's commercial terms, Anthropic does not use your data to train its models. We store your chat history on our own servers so you can reference past conversations.
Our lawful basis for this processing is performance of a contract (UK GDPR Art. 6(1)(b)): AI classification and analysis are how the service works, so this processing is necessary to deliver the app you signed up for. It is not based on consent. If you do not want your data processed this way, the way to stop it is to delete your account, which you can do in the app at any time (Settings → Delete Account).
No automated decisions with legal or similarly significant effects are made about you without human involvement.
| Recipient | Purpose | Data Shared |
|---|---|---|
| Finexer Ltd (Open Banking provider, FCA firm reference 925695) | Retrieve your bank transactions via Account Information Services (read-only) | Bank connection tokens (not your credentials) |
| Anthropic PBC (AI provider) | Transaction classification, Ask IQ chat responses, weekly briefings, annual recaps | Transaction descriptions, amounts, dates and category context; your chat messages. Never bank credentials, account numbers or full account identifiers |
| Railway (hosting provider, Netherlands — Amsterdam region) | Host our servers and database | All data (encrypted at rest and in transit) |
| Apple (App Store) | Process subscription payments | Purchase receipts (not financial data) |
| Affiliate partners (via Awin) | Track product recommendation clicks | Anonymous click data only — never transaction data |
Every third party listed above is contractually required to protect your data to at least the same standard described in this policy, and may only use it to provide their service to us — never for their own purposes.
The app and this website may feature product recommendations from financial service providers. Some of these are affiliate links — if you click through and sign up, we may receive a commission from the provider. This does not cost you anything extra.
Recommendations are ranked by relevance to your financial profile, not by commission amount. We clearly label affiliate links with an "Affiliate" badge.
You have the right to:
To exercise any of these rights, email privacy@earmarkiq.app. We will respond within 30 days.
You can delete your account directly in the app: Settings → Delete Account. This removes all your data immediately.
When you connect your bank account:
earmarkIQ is not intended for anyone under the age of 18. We do not knowingly collect data from children. If we become aware that we have collected data from a child under 18, we will delete it promptly.
Your data is stored on servers in the Netherlands (our hosting provider Railway's Amsterdam region), encrypted at rest and in transit.
Some of the third parties we use to provide the service process data outside the United Kingdom. Where that happens, we rely on appropriate safeguards permitted under UK data protection law, which may include the International Data Transfer Agreement, the UK Addendum to the European Commission's Standard Contractual Clauses, or a finding of adequacy for the country concerned.
Our AI processing is carried out by Anthropic PBC, which is based in the United States. Our backend and database are hosted by Railway in the Netherlands.
Our mobile app does not use cookies. Our website (earmarkiq.app) uses only essential cookies required for the website to function. We do not use advertising cookies or tracking pixels.
We may update this privacy policy from time to time. We will notify you of material changes via email or in-app notification. Continued use of the app after changes constitutes acceptance of the updated policy.
If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
For any questions about this privacy policy or your data: