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This policy explains how CTA Solution Co., Ltd. (“CTA Solution”, “we”) processes personal data in the CTAS Life app on iOS and Android — a set of personal utilities made of mini-apps such as Chia Chia (group expense splitting), the Lunar calendar and memorial days, Lucky Draw and mini-apps added later.
CTA Solution is the data controller for all data in CTAS Life. This policy follows the Personal Data Protection Law No. 91/2025/QH15 and its implementing regulations, and applies together with the General privacy policy for CTAS accounts.
1. Use it without signing up
- The first time you open the app you use a guest account: the device creates a random identifier, no email or phone needed. The access key is stored securely on the device (Keychain on iOS, encrypted storage on Android).
- You can sign up or sign in with a CTAS account to keep your data when you change phones; your guest data is then moved into your account.
- A guest account inactive for 13 consecutive months may be deleted together with its data.
2. Data we process
2.1. Account
- Guest account: a random identifier and the display name you choose (if any).
- CTAS account: name, email, phone number, password (stored hashed), as in the General privacy policy.
2.2. What you enter in mini-apps
- Chia Chia: group names, members, expenses (description, amount, date and time, payer, split), repayments, receipt photos you attach, a log of additions, edits and deletions.
- VietQR payout profile (if you add one): bank, account number, account holder — used to generate the QR code; shown only to members of groups you are in.
- Lunar calendar: memorial days, lunar birthdays and family events you save (names, dates, notes, reminders).
- Lucky Draw and other mini-apps: the names, options and results you enter to use the feature.
2.3. Data about other people
In Chia Chia or the Lunar calendar you may enter the names of friends and relatives and amounts relating to them. You agree to enter only what is necessary and what the person has agreed to or knows about. People invited to a group pick their own name from the list and may ask the group owner or us to correct or remove it.
2.4. Camera, microphone, speech recognition, photos, calendar
- Camera: only when you tap to photograph a receipt or attach a photo.
- Microphone and speech recognition: only while you hold the Speak button. Speech is turned into text by the operating system; on supported devices this happens on the device. Where offline recognition is not supported, the operating system may send the audio to Apple’s or Google’s recognition service under their policies. CTA Solution never receives or stores audio — only the resulting text.
- Photo library: only to save a VietQR code when you tap Save image.
- Calendar: only when you turn on syncing of memorial days and lunar birthdays — the app writes to a separate calendar named “CTAS Life” and only edits or deletes events it created.
You can refuse or revoke these permissions in your device settings at any time; the related feature stops working and everything else keeps working. CTAS Life does not collect your location, contacts or health data.
2.5. Artificial intelligence (AI)
- Receipt scanning: the receipt photo you take is sent to an AI model to read each item and amount. Photos used for scanning are not stored after processing (photos you choose to attach to an expense are stored with it).
- Typing by voice: the text (not the audio) together with the group members’ names is sent to an AI model to pre-fill the expense.
- The first time you open each AI feature, the app asks whether you agree to send this data to a third-party AI provider; it is sent only if you agree, and choosing to type it yourself sends nothing.
- AI requests go through Vercel’s AI gateway to the model provider; the data is sent only to answer your request. AI results can be wrong — you always review and edit before saving.
2.6. Advertising
- The free version and guest accounts show Google AdMob ads (Google Ireland Limited / Google LLC): a banner on some list screens, now and then a full-screen ad between two actions, and a rewarded video when you choose to watch one for extra turns. The app never shows an ad while you are typing, and never in widgets or notifications.
- To serve, cap, measure and protect ads from fraud, Google collects the device advertising ID (IDFA on iOS when you allow it; the Android advertising ID), IP address (to estimate general location), device and performance information, the ads shown and your interactions with them. Google handles this data under how Google uses information from sites or apps that use its services.
- iOS — allow tracking: once you have used the app for a while (or when you choose to watch a rewarded video), the app asks once through Apple’s dialog. If you don’t allow it, every feature still works and you still see ads, but the IDFA is not sent. Change it any time in Settings › Privacy & Security › Tracking.
- Android — advertising ID: reset or delete it in Settings › Privacy › Ads (or Settings › Google › Ads, depending on the phone). Once deleted, Google no longer receives it.
- Users in the European Economic Area, the UK and Switzerland: the app asks for GDPR consent through Google’s form before personalised ads are served; until you answer, ad slots only introduce CTAS Life Premium. Change your choice in Account, under Ad privacy choices (iOS) or Ad choices (Android).
- CTA Solution does not send your expenses, member names, memorial days or bank accounts to ad networks. When you watch a rewarded video we only record the kind of reward and the count (extra AI scans, voice entries, group slots; Lucky Draw plays and Good-day searches are counted on the phone only).
- CTAS Life Premium has no ads; with Premium the app loads no ads at all.
2.7. Buying Premium
Premium is an auto-renewing subscription (weekly, monthly or yearly) paid through the App Store or Google Play. Apple and Google process the payment; we only receive the transaction reference, plan, period and renewal status to unlock Premium — never your card number. Cancel renewal in your App Store or Google Play subscription settings before the next billing date.
2.8. Devices and usage
- App version, device model, OS, language, push token (if you turn on reminders), IP address and technical logs.
- Usage data (screens opened, key actions) linked to your account, used only to improve the product; crash and performance reports not linked to your account. You can turn this off under Account › Privacy.
3. Why we process it
- To provide the mini-apps: storing, calculating and syncing data across devices and group members; reminders.
- To scan receipts and understand typed speech with AI at your request; to cap usage against abuse.
- To show ads in the free version and handle Premium subscriptions.
- For support, security and abuse prevention; product improvement; legal compliance.
4. Legal bases
- Performing the contract when you use features and buy Premium.
- Your consent: camera, microphone, speech recognition, photos, calendar and notification permissions; tracking for personalised ads; usage data. You can withdraw it at any time in your device or app settings.
- Legal obligations and other cases permitted by law.
5. Who receives data
CTA Solution does not sell personal data.
- Members of your groups see your name, expenses, balances and VietQR profile within that group.
- Service providers under contract: servers, databases and storage (Laravel Cloud, MongoDB Atlas, Amazon Web Services, Cloudflare), the Vercel AI gateway and the AI model providers behind it, push notifications (Apple, Google).
- Google AdMob for ads (section 2.6); Apple and Google for Premium payments.
- Competent authorities on lawful request.
6. Transfers abroad
Servers, AI providers and ad networks may be located outside Vietnam. CTA Solution keeps an impact assessment of cross-border transfers, signs data protection terms with providers and completes the other formalities required by personal data protection law.
7. Retention
- Mini-app data: until you delete it or your account; group expenses remain for the other members when you leave a group (your name is hidden from new choices).
- Guest accounts: until you delete them or after 13 months of inactivity. CTAS accounts: deleted or anonymised within 30 days after you delete the account.
- AI scan photos: not stored. AI usage log (counts, cost): 12 months.
- Premium transactions: as long as accounting and tax law require. Usage data: 180 days; crash reports: 90 days; technical logs: up to 12 months.
8. Security
- HTTPS/TLS in transit; receipt photos stored privately and opened only through signed, expiring links.
- Only members who have claimed a name in a group can see its data; invite codes are rate-limited and the owner can change them.
9. Your rights
You have the right to be informed; to give or withdraw consent; to access and correct; to request deletion; to restrict or object to processing; to request your data; and to complain, report, sue and claim compensation. You can edit or delete most data in the app; send other requests to support@ctasolution.vn.
10. Deleting data and accounts
- Guest account: Account › Delete guest data — deletes the guest data on our servers immediately.
- CTAS account: Account › Delete account (deletes your shared CTAS account in every product); or email support@ctasolution.vn with the subject “Account deletion request”.
- Deleting your account does not cancel a Premium subscription — cancel renewal in the App Store or Google Play.
11. Children
CTAS Life is for people aged 16 and over. People under 16 may use it only with the consent of a parent or guardian. We do not knowingly collect children’s data; if we find it, we delete it as soon as possible.
12. Changes
New versions are posted here with their effective date and a summary of changes; for important changes the app notifies you and asks you to accept again where the law requires.
13. Contact
CTA Solution Co., Ltd. — personal data protection
Tax code: 0316683514
Address: 215 Bach Dang Street, Hanh Thong Ward, Ho Chi Minh City, Vietnam
Email: support@ctasolution.vn