JCW Solutions

Freeday

Freeday Privacy Policy

Last updated: 27 October 2026 · Applies to the Freeday app for iPhone

The short version
  • Your financial data stays on your iPhone and in your own private iCloud. We don't receive a copy and we can't see it.
  • Apple Wallet data is processed only on your device and is never sent to us or anyone else.
  • Dawn, Freeday's optional AI assistant, runs on your iPhone where it can. Otherwise our UK server gets your question and a short summary of your totals, plus a summary of anything you attach, which you see first. It never gets your transaction list or Apple Wallet data, and it keeps nothing.
  • No accounts, no ads, no analytics, no tracking, and we never sell or share your data.
  • You can delete everything in the app at any time.

1. Who we are

Freeday is made by JCW Solutions, a trading name of JCW Digital Ltd ("we", "us"). Registered in England and Wales, company number 17532846. Registered office: 6 Cornwallis Grove, London N9 0JS.

For any personal data we process in connection with Freeday, we are the data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Contact us about privacy at josh@jcw.solutions.

2. What Freeday stores, and where

What you add, import or connect: your budget, accounts and balances, debts, payslips, goals and settings, and the transactions you import or connect.

  • On your device. This data is protected by iOS data protection, so it's encrypted when your iPhone is locked.
  • In iCloud. If you're signed in to iCloud, it syncs to your private iCloud database, which only your Apple Account can read, so your other devices stay up to date. This is held by Apple under your Apple Account.
  • No copy on our servers. We don't receive a copy of your financial data, and we can't see it.

3. Apple Wallet (FinanceKit)

If you connect Apple Wallet, iOS asks your permission and you choose which accounts Freeday can read. Freeday reads their balances and transactions on your device to show your spending, bills, net worth and progress. This data:

  • is processed only on your device;
  • is stored as described in section 2, on your device and in your private iCloud;
  • is never sent to us or anyone else, including Dawn and any connection you choose;
  • is never used for advertising, marketing or credit decisions, and is never sold.

You can change or remove access at any time in your iPhone's Settings.

4. Connections you choose

Freeday can connect to services you choose. When you do, Freeday talks to that service directly from your device. We don't sit in the middle and we don't receive a copy. These are:

  • Notion, if you choose to keep your records in your own Notion workspace;
  • Trading 212, to show your investments;
  • a Google Sheet you link;
  • statement files you import, such as your bank's CSV export;
  • your own Freeday server, if you run one.

Each service's own privacy policy applies to what you send it. Keys and tokens you enter are kept in your device's Keychain.

5. Dawn, the AI assistant

Dawn answers questions about your goals and your money, and can make changes to your records when you ask and confirm. Dawn is optional.

  • On iPhones with Apple Intelligence: Dawn runs on your device using Apple's on-device model, and nothing leaves your iPhone.
  • On other iPhones: you can use Dawn's server, which we run in the UK. It receives only:
    • your question and your last few messages in the conversation;
    • a short summary of figures Freeday has already worked out, such as your net worth, your FI number and progress, your debt total and this month's spending by category against your budget;
    • a text summary of anything you attach to a question (see below).
    It never receives your transaction list, merchant history or Apple Wallet data. Requests are tied only to a random key for your installation, not to you. We don't store your questions, answers, figures or attachment summaries, they are not used to train any AI model, and no other company's AI receives them.
  • On your own server: if you choose to use one, the same information goes only to that server.

Attachments

You can add a photo, screenshot, PDF or bank CSV to a question. Freeday turns it into a short text summary on your iPhone before anything is sent:

  • Photos and PDFs: the text Freeday reads from them. If you attach a statement or receipt, that text can include the amounts and descriptions on it.
  • Bank CSV files: totals by month and category only, never the individual rows.

You see the summary before sending and can edit or remove it. The file itself never leaves your iPhone, and any lines or receipts you choose to add to your records are handled on your iPhone.

Data sent to Dawn's server is encrypted in transit (HTTPS).

6. What we don't do

  • We have no accounts. You don't sign up to use Freeday.
  • We don't use analytics or advertising tools, and Freeday contains no third-party tracking code. If you've chosen to share analytics with app developers in iOS Settings, Apple may give us aggregated, anonymous crash and usage statistics.
  • We don't track you across apps or websites.
  • We don't sell, rent or share your data.
  • We don't use information from our consultancy clients in Freeday, or Freeday data in our consultancy work.

7. How we use information, and our lawful bases

PurposeLawful basis (UK GDPR)
Answering questions you ask Dawn on our server, when you choose to use itPerformance of our contract with you (providing the feature you asked for)
Limiting how many questions each installation can ask, to keep the service availableLegitimate interests
Replying to support emailsLegitimate interests in helping you use Freeday
Meeting legal obligationsLegal obligation

Everything else Freeday does with your data happens on your device and in your own iCloud, outside our control.

8. Where processing happens

Dawn's server is in the United Kingdom. Data in your iCloud account is handled by Apple under its own terms. Services you connect (section 4) process data under their own terms and locations.

9. How long we keep information

  • Your financial data: we don't hold it. It stays on your device and in your iCloud until you delete it.
  • Questions to Dawn, figure summaries and attachment summaries: not stored. They are used to produce the answer and then discarded.
  • Support emails: kept for up to 12 months.

10. Security

Freeday relies on iOS security, including data protection on your device, the Keychain for keys you enter, and Apple's encrypted iCloud sync. Dawn's server only accepts encrypted connections. No system is perfectly secure; if a breach affecting your data occurs, we will act on it and tell you and the Information Commissioner's Office where the law requires.

11. Your rights

Under UK GDPR you can ask what we hold about you, and ask us to correct or erase it, restrict or object to our use of it, or give you a copy. Email josh@jcw.solutions and we'll reply within one month. Apart from support emails, we hold nothing about you.

If you're unhappy with how we've handled your data, please contact us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint.

12. Deleting your data

In Freeday, Settings → Delete all my data removes everything Freeday stores on your device and in your iCloud. Deleting the app also removes the data on that device. You can remove Apple Wallet access in your iPhone's Settings.

13. Children

Freeday is intended for people aged 18 and over and is not directed at children.

14. Changes and contact

We'll update this page and its date if anything changes, and tell you in the app before significant changes take effect.

Questions: josh@jcw.solutions
JCW Solutions, a trading name of JCW Digital Ltd
Registered in England and Wales, company number 17532846. Registered office: 6 Cornwallis Grove, London N9 0JS.