Summary: this is a personal, single-user financial planning application. It connects to the account holder's own bank accounts through Open Banking (PSD2) via Enable Banking, a licensed account information service provider, and is not offered to the public.
This application ("the Application", available at bank.labz.my) is operated by Pedro Lemos, acting as an individual and as the data controller for the purposes of the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Brazil's Lei Geral de Proteção de Dados (LGPD, Law No. 13.709/2018).
Contact: [email protected]
The Application provides financial support by connecting to the user's bank in order to help carry out proper financial planning. It retrieves account and transaction information through Open Banking connections and uses that information to produce planning insights (for example, spending overviews, balances, and projections) for the account holder.
The Application is currently operated in personal production/demo use by a single user: the data controller himself, using his own bank accounts only. It is not registered for, marketed to, or intended for use by the general public or by any other individual's accounts.
Through the Open Banking connection, the Application may access:
This data is obtained exclusively through connections that the account holder actively authorizes with his own bank(s), using Enable Banking (enablebanking.com) as the regulated technical provider that facilitates the Open Banking (PSD2) connection.
Data is processed solely to provide the account holder with financial planning support — that is, to help him understand and plan around his own finances. The legal basis for this processing is the account holder's explicit consent (GDPR Art. 6(1)(a) and, where applicable, Art. 9(2)(a) for any special category data incidentally present in transaction descriptions; LGPD Art. 7(I)), given directly through the bank's and/or Enable Banking's consent flow, and, where relevant, the controller's legitimate interest in managing his own personal finances (GDPR Art. 6(1)(f); LGPD Art. 7(IX)).
Because the Application is in personal, single-user production/demo use and under active development, its data storage and retention rules are still being finalized as the underlying system is built out. In the meantime, the following commitments apply:
Data is not sold, rented, or shared with third parties for marketing purposes. Data is processed with the help of the following processor, strictly to enable the service described above:
Data may also be disclosed where required by law or to a competent authority upon a valid legal request.
As the account holder, you may, at any time and free of charge, request to:
These rights derive from the GDPR (for processing connected to Portugal/the EU) and the LGPD (for processing connected to Brazil). Requests can be made by contacting [email protected]. You also have the right to lodge a complaint with the competent supervisory authority — the Comissão Nacional de Proteção de Dados (CNPD) in Portugal, or the Autoridade Nacional de Proteção de Dados (ANPD) in Brazil.
The Open Banking connection to your bank account is based on a consent that you can revoke at any time, either directly through your bank's own online/mobile banking channels, through Enable Banking's consent management, or by contacting [email protected]. Revoking consent stops further data retrieval and results in deletion of previously retained data, except where retention is required by law.
The public pages at bank.labz.my do not set tracking or advertising cookies. Only strictly necessary technical mechanisms (if any) required for the Application itself to function are used.
This Application is not directed at, and is not knowingly used by, children.
This policy may be updated as the Application evolves, in particular once concrete data retention and storage details are finalized (see Section 6). The effective date at the top of this page reflects the latest revision.
For any question about this policy or about your data, contact [email protected].