Sarah · Legal
Privacy Policy
Effective 4 November 2026. Operated by Modulus Systems Europe Ltd, company number 09981544, c/o JSP Accountants Ltd, First Floor, 10 College Road, Harrow, Middlesex, HA1 1BE, United Kingdom.
1. Who we are
Sarah (sarah-app.com) is operated by Modulus Systems Europe Ltd, a company registered in England and Wales (company number 09981544) with its registered office at c/o JSP Accountants Ltd, First Floor, 10 College Road, Harrow, Middlesex, HA1 1BE, United Kingdom. We are the data controller for the personal data described in this policy. You can reach our privacy team at privacy@sarah-app.com.
2. What Sarah does with your data, in one paragraph
Sarah reads your bank account and card data through Open Banking (with your explicit consent, via Finexer Ltd), combines it with information you type in about your property, mortgage, pensions and investments, and uses it to calculate your net worth and to suggest ways to save money. We do not move money, we do not sell your data, and we do not let third parties pay to influence what Sarah suggests.
3. The data we collect
| Data | Where it comes from | Why |
|---|---|---|
| Account details: email address, name, password (stored as a one-way hash), sign-in method | You, when you create an account or sign in with Google | To create and secure your account and to contact you about it |
| Financial account data: account names, balances, transactions (date, amount, description, merchant), direct debits and standing orders | Your bank or card provider, via Finexer Ltd, only after you give consent on Finexer's consent screen | To calculate net worth, categorise spending, detect recurring bills and generate money moves |
| Statements you upload, if you choose to: the transactions in the file (date, amount, description, and the running balance where shown), and the account number when the file includes one, kept only as a one-way code so a later statement for the same account can be recognised | You, as a CSV or PDF file downloaded from your bank | The same as bank data: to calculate net worth, categorise spending, detect recurring bills and generate money moves. The file is read in memory by our statement reader (hosted with the rest of Sarah in London) and is not stored; the transactions are kept as for a bank connection and deleted when you remove the account |
| Information you enter: property values, your home's postcode and type, what you paid for it and when, mortgage balance and rate, pensions, investments, loans, credit cards, interest rates, 0% end dates, your contracts (provider, monthly price and when the deal ends or renews), and which steps you have ticked on the remortgage checklist | You | To complete the net-worth picture, power the mortgage, credit and contract prompts, and remind you before a deal ends |
| Tax check answers, if you choose to give them: your income range, whether you pay Scottish Income Tax, whether you are married or in a civil partnership and your partner's income range, whether other adults live with you, the month and year each child under 20 was born, and, if you give it, the month and year you were born | You | Only to check for tax relief, government top-ups and money you may be owed (for example Marriage Allowance, Child Benefit, Tax-Free Childcare or a Child Trust Fund). Optional; change or clear them at any time on the Help Sarah help you page |
| Access tokens for your bank connections | Finexer Ltd | To refresh your data; stored encrypted and deleted when you disconnect |
| Technical data: IP address, browser type, timestamps, device identifiers in logs | Your device, automatically | Security, fraud prevention and keeping the service running |
| Your responses to money moves (done, dismissed) and a savings ledger: each move you mark done, when, and what we estimate it is worth, with how sure we are (you tapped Done, you told us, or we saw it in your payments) | You, and your own payment data we already hold | To personalise what Sarah shows you and to show you what you have saved. When you delete your account, your savings are added to an anonymous combined total (below) unless you untick it |
We do not knowingly collect data from anyone under 18. Sarah is for UK residents aged 18 and over.
4. Open Banking and Finexer
Bank connections are provided by Finexer Ltd, an authorised payment institution regulated by the Financial Conduct Authority (FRN 925695), which provides the account information service under its own end user terms. During the private beta, only Sarah's founders can connect real bank accounts; everyone else connects to a test bank with made-up data. When you connect a bank you are redirected to Finexer and then to your bank; Sarah never sees your bank login credentials. Finexer is a controller in its own right for the connection and consent records, as set out in its privacy policy. Sarah does not give Finexer your name or email address: it gets a placeholder name, an email address we generate and your Sarah user ID, so it can tell connections apart. Access is read-only, lasts for the period shown on the consent screen (typically 90 days before you are asked to reconfirm), and you can withdraw it at any time through Sarah, through Finexer, or through your bank. Shortly before access to a bank ends, Sarah reminds you in the app and by email and asks whether you want to keep it; if you do nothing, access ends and Sarah stops updating that bank.
5. Why we are allowed to use your data (lawful bases)
- Contract: providing the Sarah service you signed up for, including account creation, syncing your accounts and generating money moves.
- Consent: accessing your bank data through Open Banking. You can withdraw consent at any time.
- Legitimate interests: keeping the service secure, preventing fraud and abuse, improving how the rules work, and communicating with you about the service. We balance these against your rights.
- Legitimate interests (anonymous savings total): when you delete your account, we add your savings to an anonymous combined total, so we can show that our figures about money saved are true. We do this because we need that evidence to describe what Sarah does honestly. It is added only if you leave the box on the deletion screen ticked, and you can untick it. You can also object by emailing us before you delete.
- Legal obligation: where we must keep or disclose records under UK law.
Where Sarah makes suggestions based on your financial data, this is automated processing that helps you make your own decisions. Sarah does not make decisions with legal or similarly significant effects on you.
6. Who we share it with
- Finexer Ltd, to obtain your bank data with your consent.
- Google Cloud (Google Ireland Limited / Google LLC), which hosts Sarah and stores your data in the London region.
- Resend, our email delivery provider, to send sign-in links, account emails and the deadline reminders (for the dates you add, and the Self Assessment dates Sarah finds from your payments to HMRC) that you can turn off under Profile and data.
- Google, if you choose to sign in with Google, for authentication only.
- postcodes.io and HM Land Registry, if you give a postcode for your home, to look up local house prices for a rough estimate of its value. They receive the postcode only, never your name, what you paid or anything else about you, and it is sent again each day while you keep it in Sarah.
- Professional advisers, insurers, and authorities where required by law.
We do not sell personal data. We do not share your financial data with advertisers, and we do not accept payment to rank or feature products in your money moves.
7. International transfers
Your financial data is stored in the United Kingdom (Google Cloud, London). Resend sends our emails from the EU but stores your email address, the emails and delivery logs in the United States; for that transfer we rely on the UK Extension to the EU-US Data Privacy Framework and the UK Addendum to the EU standard contractual clauses. If you sign in with Google, Google may process your sign-in outside the UK under its own terms.
8. How long we keep it
- Account and financial data: for as long as you have an account. When you delete your account in Settings, we delete it straight away; if you ask us by email instead, within 30 days. Either way we keep only records we must keep by law.
- Bank access tokens: deleted immediately when you disconnect a bank or delete your account.
- What we keep after you delete your account: an anonymous, combined total of money Sarah helped people save, grouped by month and kind of money move. It has no name, email, bank, merchant or payment in it and cannot be linked to you. A group is only used once it covers at least five people. It is no longer personal data, so it is not part of your data download and not deleted with your account. If you untick the box on the deletion screen, your savings are left out.
- Security logs: up to 12 months.
9. Your rights
Under UK GDPR you can ask us to: access the data we hold about you; correct it; delete it; restrict or object to how we use it; and give you a copy in a portable format. You can withdraw consent for bank access at any time. You can do the main ones yourself in the app: disconnect a bank on the Accounts page, and download your data (JSON or CSV) or delete your account under Account and data. To exercise any right, or if you can't use the app, email privacy@sarah-app.com. We respond within one month. If you are unhappy with how we have handled your data, please complain to us first; you can also complain to the Information Commissioner's Office at ico.org.uk.
10. Security
Bank tokens are encrypted at rest. Passwords are stored as salted scrypt hashes. All traffic uses HTTPS. Access to production systems is limited to named staff. No system is perfectly secure; if we discover a breach that affects you, we will tell you and the ICO as the law requires.
11. Not financial advice
Sarah's money moves are information to help you make your own decisions. They are not regulated financial advice, and Modulus Systems Europe Ltd is not authorised by the FCA to give advice. Benchmarks and market rates used in calculations may be out of date; always check the current terms of any product before switching.
12. Changes
We will post any changes here and, for material changes, email you. This version is effective 23 September 2026.
Questions: hello@sarah-app.com. See also Privacy, Terms, Cookies and Complaints.