Privacy Policy

Dily is a Solana-based payments and bill-splitting application. It is operated by Andrea Kovacic and Niko Jugovac, two individuals based in Croatia, European Union. For the purposes of the General Data Protection Regulation (GDPR), we are the joint data controllers for any personal data processed through this app.

Contact: privacy@dilyapp.com

We collect only what is strictly necessary to provide the service. We do not sell any data to third parties.

Data type — Purpose / notes

• Wallet address — Used to identify you within the app and route Solana transactions. Treated as pseudonymous personal data under GDPR.
• .sol domain — Used as a human-readable identifier, if you have one. Optional.
• Nickname (your own) — A display name you assign to yourself. Visible only to you, not to other users. Stored locally on your device only.
• Nicknames (for friends) — Labels you assign to contacts within the app. These are visible only to you. Stored locally on your device only.
• Friend birthdays / dates — Dates you optionally enter for your own contacts to receive reminders. Stored locally on your device only, never transmitted to our servers.
• Waitlist email address — If you sign up for our waitlist on dilyapp.com, we collect your email address solely to notify you when the product launches or when relevant updates are available.
• Analytics (aggregate) — We use Plausible Analytics, a privacy-first tool that does not use cookies and does not collect personal data. Only aggregate, anonymised page statistics are collected.

We do not collect: real names, phone numbers, location data, device identifiers, or any biometric data.

We rely on the following legal bases:

• Wallet address and .sol domain: Article 6(1)(b) — processing necessary to perform the service you requested.
• Waitlist email: Article 6(1)(a) — your explicit consent, given at the point of sign-up. You may withdraw consent at any time by unsubscribing.
• Nicknames and friend data stored locally: these remain on your device and are under your control. To the extent this constitutes processing, it falls under Article 2(2)(c), the household/personal activity exemption.
• Plausible Analytics: Article 6(1)(f) — legitimate interest in understanding aggregate usage, with no impact on individual privacy.

Friend data (nicknames, birthdays, dates): stored exclusively on your device. We do not have access to this data and it is not backed up to our servers.

Wallet address / .sol domain: retained for as long as you use the app. If you disconnect your wallet, no further data is retained by us.

Waitlist emails: retained until you unsubscribe or the waitlist is closed, whichever comes first.

Analytics: Plausible retains aggregate statistics for 24 months. No individual records are kept.

We do not sell, rent, or share your personal data with third parties for commercial purposes. Limited sharing occurs only in these cases:

• Solana blockchain: by design, all on-chain transactions are public and permanent. Your wallet address and transaction details are visible on the Solana blockchain to anyone. This is inherent to how the network functions and is not within our control.
• Plausible Analytics: anonymised, aggregate data only. No personal identifiers. Plausible is based in the EU and GDPR-compliant.
• Legal obligation: if required by applicable law or a competent authority.

As a data subject in the EU, you have the following rights:

• Right of access: you may request a copy of the personal data we hold about you.
• Right to rectification: you may ask us to correct inaccurate data.
• Right to erasure (right to be forgotten): you may ask us to delete your data. For data stored locally on your device, you can delete it directly by clearing app data or uninstalling the app.
• Right to restriction: you may request that we limit how we use your data.
• Right to data portability: you may request your data in a portable format.
• Right to object: you may object to processing based on legitimate interest.
• Right to withdraw consent: for waitlist emails, you may unsubscribe at any time.

To exercise any of these rights, contact us at privacy@dilyapp.com. We will respond within 30 days. You also have the right to lodge a complaint with the Croatian Data Protection Authority (AZOP): azop.hr.

The Dily mobile app does not use cookies. Our website (dilyapp.com) does not use tracking or advertising cookies. Plausible Analytics, used for aggregate statistics, is entirely cookie-free.

Dily is not directed at children under the age of 16. We do not knowingly collect data from minors. If you believe a minor has provided us with personal data, please contact us at privacy@dilyapp.com and we will delete it promptly.

We may update this Privacy Policy from time to time. We will notify users of material changes through the app or via email (for waitlist subscribers). The effective date at the top of this document reflects the most recent version.

For any privacy-related questions or requests:

Email: privacy@dilyapp.com
Website: dily.app/privacy
Mailing address: Turistička 5, Croatia, EU

Dily is operated by individuals based in Croatia, EU. This policy is governed by GDPR.