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Crest — Privacy Policy and Terms of Use
| Product | Crest — Personal Finance App |
| Document version | 0.7 (Draft, English only) — Cloudflare removed from the providers: the domain name service is Biznet Gio's, and no service forwards mail sent to contact@ (the Crest app is a web app in the first release: browser storage, one login cookie, no app stores) |
| Date | 2026-10-06 |
| Based on | BusinessRequirements.md v0.23, TechnicalDesign.md v0.12 |
| Owner | Reizkian Y. Radityatama |
| Status | Draft — not legal advice; to be reviewed before the first user is invited, then translated into Bahasa Indonesia |
Notes for the editor (remove before publishing)
contact@radityatama.web.idmust forward to the owner's personal inbox before publishing (see Technical Design §11.3).- Both texts are published at
crest.radityatama.web.id/privacyand/terms, linked from the request form (FR-REQ-6) and from Settings.- The Bahasa Indonesia version must say the same thing. If the two versions ever differ, state which one prevails (see Terms §15).
- This text describes the first release, where the Crest app is a web app. When native Android and iPhone apps or push notifications are added, update A2, A8, A12, and B3 before they ship.
- As elsewhere in the Crest documents, "account" is not used on its own: a person has a Crest login, and money is held in financial accounts.
Part A — Privacy Policy
Effective date: 29 September 2026
A1. Who we are
Crest is a personal finance app run by Reizkian Y. Radityatama ("we", "us"), based in Kabupaten Tangerang, Indonesia. We decide how your personal data is used, which makes us the data controller under Indonesia's Personal Data Protection Law (UU No. 27 Tahun 2022, "PDP Law") and, where it applies, the EU/UK General Data Protection Regulation ("GDPR").
Crest is invite-only, free, and built for a small circle of people we know. It is not a bank and never moves money. This policy covers the Crest app (a web app at app.crest.radityatama.web.id that you can add to your home screen), the public website (crest.radityatama.web.id), and the Super Admin portal.
Contact: contact@radityatama.web.id
A2. The short version
- You type in your own financial information. Crest doesn't connect to your bank or e-wallet.
- Your data is stored on a server in Indonesia.
- We don't sell your data, show ads, or use tracking or analytics tools, in the app or on the website.
- The Crest admin portal cannot show your financial data. The operator has technical access to the server and commits never to look at your financial data unless you ask for help with a problem (see A7).
- If you join a shared space, everyone in that space sees everything in it, including what you add.
- You can export your data and delete your Crest login at any time. Deleted data is gone from our backups within 90 days.
A3. What data we collect
| Category | What | Where it comes from |
|---|---|---|
| Access request | Full name, email, country, your optional message, the time you accepted this policy and the Terms, and a scrambled (hashed) version of your IP address | You, on the request form |
| Crest login and profile | Name, email, status, language, time zone, base currency, theme, reminder time, last login time | You and your device |
| Login security | Password (stored only as a one-way hash), app-lock PIN (hashed), two-factor data for admins, and the devices and browsers you are logged in on. Crest never receives biometric data such as Face ID or fingerprints | You and your device |
| Financial data you enter | Financial accounts (name, type, currency, balance, optional provider name and last 4 digits only), transactions (amount, date, category, notes), categories, budgets, savings goals, recurring transactions, exchange rates you enter | You, and members of shared spaces you belong to |
| Shared spaces | Spaces you create or join, your role, who added or edited each transaction, invitations | You and other members |
| Device and notifications | The app version and a device name (such as "Safari on iPhone"). If browser notifications are added later and you allow them: a notification address for your browser | Your device; the notification address only if you allow notifications |
| Technical logs | Server logs with time, requested page, error details, and IP address | Automatically, for security and fixing problems |
| Admin records | A log of actions taken by Super Admins (e.g. "request approved") | Automatically |
| Contributions (only if introduced later) | Your "paid until" date and notes about payments | Recorded by a Super Admin |
We never collect or store: full card or bank numbers, CVV codes, PINs of your bank or cards, or login details for your bank or e-wallet.
A4. Why we use your data, and on what basis
| Purpose | Legal basis |
|---|---|
| Reviewing your access request and creating your Crest login | Your consent (request form) and steps before an agreement |
| Providing Crest: storing and showing your data, calculations, budgets, shared spaces | Performing our agreement with you (the Terms) |
| Sending emails you need (activation, password reset, invitations) and notifications you turned on | Performing our agreement; your consent for optional notifications |
| Keeping Crest secure, preventing spam and abuse, fixing problems | Our legitimate interest in a safe service |
| Keeping your transactions in a shared space after you leave, so the other members' records stay complete | Our and the other members' legitimate interest (see A6) |
| Meeting legal obligations | Legal obligation |
We do not use your data for advertising, profiling, selling, or automated decisions that affect you.
A5. Who can see your data
| Who | What they can see |
|---|---|
| You | Everything in your Personal space and in shared spaces you belong to |
| Members of a shared space | Everything inside that space, including transactions you add and your name next to them. They cannot see your Personal space or other spaces |
| Super Admins | Your name, email, status, sign-up and last-login dates, and your access request. The admin portal cannot show financial accounts, transactions, budgets, or anything about your spaces |
| The operator (server access) | See A7 |
| Service providers | Only what they need to do their job (see A8) |
| Authorities | Only if Indonesian law requires it |
A6. Shared spaces
A shared space is where a group (for example a couple, or a business owner and staff) tracks money together.
- Everyone in a space sees everything in it: its financial accounts, all transactions, who added or edited each one, budgets, goals, and the member list.
- When you add something to a shared space, the other members see it. Check which space a financial account belongs to before saving.
- When you leave or are removed, you lose access immediately, but the transactions you added stay in the space, with your name, so the others' records remain complete.
- When your Crest login is deleted, those transactions stay but show "Former member" instead of your name.
- If a space you are in is deleted by its Owner, everything in it is deleted for all members.
- Transfers between your Personal space and a shared space show the other members only the shared side (for example "+500,000 from Andi"), never your personal financial account or its balance.
A7. Operator access to the server
Crest runs on a server that the operator manages. Security rules in the database stop the app and the admin portal from showing your financial data to anyone who isn't allowed to see it. However, the person who runs the server has technical access to the database, as with any service.
We commit to never looking at your financial data, except when you report a problem and ask us to investigate it, and then only as much as needed to fix it. Server access is protected with keys, a firewall, and automatic security updates.
A8. Service providers and where data is stored
| Provider | What for | Where |
|---|---|---|
| Biznet Gio (PT Biznet Gio Nusantara) | Server hosting, domain name service, and encrypted backup storage | Indonesia |
| Brevo | Sending emails (activation, reset, invitations, reminders) | EU |
| Your browser's notification service (run by Apple, Google, or Mozilla, depending on your browser) | Only if browser notifications are added later and you allow them: delivering those notifications | Global |
| UptimeRobot | Checking that Crest is online (receives no personal data) | — |
Your data is stored in Indonesia. Only your name, email, and the email content are shared with the email provider, and only short notification texts with push services. Where data leaves Indonesia, we rely on providers that apply protection at least equivalent to the PDP Law.
A9. How long we keep data
| Data | How long |
|---|---|
| Your Crest login, profile, and financial data | Until you delete your Crest login (or a Super Admin deletes it) |
| A single item you delete (e.g. a transaction) | Hidden immediately; fully removed from the live database within 90 days |
| After your Crest login is deleted | Removed from the live database immediately, except transactions you added in shared spaces (A6) |
| Backups | Encrypted; kept for at most 90 days (30 daily + 3 monthly copies). Deleted data is gone from all backups within 90 days |
| Rejected access requests | 6 months, then deleted |
| Server logs | 14 days |
| Admin action log | At least 1 year, then deleted |
| Contribution records (if introduced) | As long as required for bookkeeping |
A10. How we protect your data
- Encrypted connections (HTTPS) everywhere, and encrypted backups.
- Database-level rules so each person only reaches the spaces they belong to.
- Passwords stored only as one-way hashes; app lock with a PIN on each device; your login kept in a cookie that the page's own code cannot read; two-factor authentication for Super Admins.
- No full card or bank numbers, ever.
- A hardened server in Indonesia with automatic security updates.
No system is perfectly secure. If a data breach affects your personal data, we will tell you and the relevant authority as required by the PDP Law (within 3 × 24 hours of becoming aware of it), explaining what happened and what we are doing.
A11. Your rights
Under the PDP Law (and the GDPR where it applies), you can:
- Know and access what data we hold about you, and get a copy (Settings → Export, or ask us).
- Correct inaccurate data (most of it you can edit yourself).
- Delete your Crest login and data (Settings → Delete my Crest login and data).
- Withdraw consent, for example turn off notifications, or stop using Crest and delete your data.
- Object to or restrict certain uses of your data.
- Receive your data in a portable format (CSV export).
- Complain to us first at contact@radityatama.web.id, and to the Indonesian data protection authority (or your local authority in the EU/UK).
We answer requests within 3 × 24 hours where the PDP Law requires it, and otherwise as soon as possible and within 30 days.
A12. Storage on your device, and cookies
Crest uses only what it needs to work:
- In the Crest app: one essential cookie keeps you logged in. A copy of the app itself and of your recent data is kept in your browser's storage so Crest opens quickly and can be viewed offline, together with a hashed copy of your app-lock PIN. Logging out, or five wrong PIN attempts, erases your data from that browser. Your browser may also clear this storage by itself; your data stays safe on our server.
- On the public website: no cookies at all.
- In the Super Admin portal: one essential cookie to keep the admin logged in.
There are no advertising, tracking, or analytics tools or cookies anywhere in Crest.
A13. Age
Crest is for people aged 18 or older. We don't knowingly accept access requests from anyone younger.
A14. Changes to this policy
If we change this policy, we will show the new version in Crest and email you before it takes effect, at least 14 days in advance for important changes.
Part B — Terms of Use
Effective date: 29 September 2026
B1. Agreement
These Terms are an agreement between you and Reizkian Y. Radityatama ("we", "us"), who runs Crest. By requesting access, activating your Crest login, or using Crest, you agree to these Terms and to the Privacy Policy (Part A).
B2. What Crest is, and what it isn't
Crest helps you record and understand your money: financial accounts, transactions, budgets, goals, and shared spaces.
Crest is not:
- a bank, e-wallet, or payment service; Crest never moves money or connects to your bank;
- financial, investment, tax, or legal advice;
- an official record for tax or accounting purposes.
Exchange rates in Crest are the ones you enter. Converted totals are estimates.
B3. Access by invitation
- Crest is invite-only. Anyone can request access, and a Super Admin decides whether to approve it. We may decline a request without giving a reason.
- You must be 18 or older.
- Your Crest login is personal. Don't share your password, PIN, or devices, and tell us at contact@radityatama.web.id if you think someone else has accessed your login.
- Crest uses only its own login (email and password, plus a PIN to unlock the app). There is no sign-in with Google, Apple, or other services.
- Crest is a web app: you open it in your browser and can add it to your home screen. It is not distributed through Google Play or the App Store.
B4. Your data and your responsibility
- You own the data you enter. You give us permission to store, process, and display it only to provide Crest to you and to the members of spaces you share it with.
- You are responsible for what you enter and for checking that it's accurate. Crest calculates from what you type.
- Never enter full card or bank numbers, card security codes, bank PINs, or bank login details. Crest only asks for the last 4 digits, and only optionally.
B5. Shared spaces
- If you create a shared space, you are its Owner. Owners decide who is invited, can change members' roles, can remove members (including other Owners, as long as one Owner remains), and can delete the space and everything in it.
- Members see everything in the space and can add transactions; they can edit or delete only their own.
- Only invite people who should see that space's information, and only add information to a shared space that its members may see.
- Requests for money between members (for example, staff asking for more funds) happen outside Crest. Crest only records what you enter.
- When you leave a space, the transactions you added stay in it (Privacy Policy A6).
B6. Acceptable use
You agree not to:
- use Crest for anything illegal, including money laundering or fraud;
- try to access other people's data, spaces, or the admin portal without permission;
- try to break, overload, scan, or reverse-engineer Crest or its server;
- use automated tools to create requests or data;
- upload harmful content or content that isn't yours to share.
B7. Cost and future contributions
Crest is free. If running costs need to be shared in the future, users may be asked for a small yearly contribution that only covers those costs (not profit). If this happens:
- we will tell you at least 30 days in advance, with the amount and how to pay;
- payment happens outside Crest; Crest never takes card or online payments;
- if a contribution is not paid after a grace period, your Crest login becomes read-only: you can still view and export all your data, and your data is never deleted because of non-payment.
B8. Availability and changes
- Keep the app up to date. Versions that are too old to work safely will ask you to update before you can continue.
- Crest is run by one person on a small budget. We try to keep it available and safe, but we don't guarantee it will always be available or free of errors.
- We may add, change, or remove features. For changes that significantly affect how you use Crest, we will tell you in advance where reasonable.
- Keep your own copy of important information using the CSV export.
B9. Suspension and ending your use
- You can stop using Crest and delete your Crest login and data at any time (Settings).
- A Super Admin may deactivate your Crest login if you break these Terms, if needed for security, or if Crest is shut down. Where reasonable we will tell you why and give you a chance to export your data.
- If we ever shut down Crest, we will give at least 30 days' notice so you can export your data, and then delete it.
B10. Intellectual property
Crest's software, name, and design belong to us. You may use Crest only as described in these Terms. Your data stays yours (B4).
B11. No warranty
Crest is provided "as is" and "as available", free of charge. To the extent Indonesian law allows, we give no warranties that Crest will be accurate, uninterrupted, or fit for a particular purpose.
B12. Limitation of liability
To the extent Indonesian law allows:
- we are not liable for financial decisions you make based on Crest, for errors in data you or other members entered, or for indirect losses;
- because Crest is free, our total liability to you is limited to IDR 1,000,000, or, if contributions are introduced, the amount you paid in the previous 12 months, whichever is higher.
Nothing in these Terms limits liability that cannot be limited by law, including liability for intentional wrongdoing or gross negligence.
B13. Privacy
How we handle personal data is described in the Privacy Policy (Part A), which is part of these Terms.
B14. Changes to these Terms
We may update these Terms. We will show the new version in Crest and email you at least 14 days before important changes take effect. If you don't agree, you can export your data and delete your Crest login before then.
B15. Law, disputes, and language
- These Terms are governed by the laws of the Republic of Indonesia.
- If there's a problem, please contact us first at contact@radityatama.web.id; we'll try to resolve it amicably within 30 days.
- If that doesn't work, disputes go to the District Court (Pengadilan Negeri) with jurisdiction over Kabupaten Tangerang, unless the law gives you the right to another court.
- These Terms are provided in Bahasa Indonesia and English, as required by Law No. 24 of 2009. If the versions differ, the Bahasa Indonesia version prevails.