privacy policy
how we handle your personal data.
This policy explains what personal data we collect, how we use it, who we share it with, and your rights under GDPR.
Who we are
Applies to withpilar.com (marketing website) and app.withpilar.com (Pilar application). Sections that apply only to one are noted.
With Pilar S.L. ("Pilar", "we", "us") is a Spanish limited liability company registered at Plaça de la Fira, 1, 08261 Cardona, Barcelona, Spain, with Spanish tax identification number (NIF) B05575998.
We operate the Pilar financial wellbeing platform, provided to individual employees through their employers or, potentially in future, via direct subscription.
Data Protection Officer: [email protected]
General privacy inquiries: [email protected]
Pre-launch waitlist
If you joined the waitlist, this section explains exactly how we handle your data.
The waitlist is separate from the main Pilar service. It exists to notify prospective users when Pilar becomes available. The disclosures in this section apply to your waitlist data and satisfy our obligations under Article 13 GDPR for that specific processing.
What we collect from the waitlist
- —First name — used to personalise our emails to you
- —Email address — used to send you product updates and launch notifications
- —An optional access code, if you were invited by an existing user
- —Submission timestamp and a Cloudflare Turnstile verification token, used to prevent automated bot submissions
- —IP address, retained transiently for abuse prevention only and discarded once the submission is validated
Legal basis
We process your waitlist data on the basis of your consent under Article 6(1)(a) GDPR. By submitting the waitlist form you consent to receive product updates from Pilar until you withdraw that consent. Providing the data is entirely voluntary — you can use Pilar once it launches without ever having joined the waitlist.
How we use it
We use your waitlist data only to:
- —Send you occasional updates about Pilar's development and launch — typically once a month or less
- —Notify you when the product becomes available for signup
- —Prevent automated submissions (Cloudflare Turnstile verification)
We do not use waitlist emails for any other purpose. We do not sell them. We do not share them with employers, marketing partners, or any third party outside the subprocessor list below. We do not use them to train third-party AI models.
Who processes your waitlist data
Waitlist data is stored in Supabase (EU data region, encrypted at rest with AES-256), transactional emails are sent via Resend, and bot protection is provided by Cloudflare Turnstile. The full subprocessor list, including data protection safeguards, is on our Trust page. Where a subprocessor is US-headquartered, transfers are governed by European Commission Standard Contractual Clauses and supplementary technical measures consistent with Schrems II guidance.
How long we keep it
Waitlist emails are retained until you either (a) complete signup for a Pilar account once the service becomes available, or (b) unsubscribe — whichever comes first. On signup, your waitlist entry is either merged into your service account or deleted, at your choice. On unsubscribe, your entry is deleted within 30 days. If Pilar is discontinued before launch, all waitlist data is deleted within 30 days of the discontinuation announcement.
Your rights
- —Unsubscribe at any time — every email includes a one-click unsubscribe link
- —Access, correct, delete, restrict, port, or object to processing of your waitlist data — write to [email protected]
- —Withdraw consent at any time (withdrawal does not affect the lawfulness of processing before it was withdrawn)
- —Lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, aepd.es) or your local supervisory authority
What personal data we collect
We collect what we need to operate the service. Nothing more.
Identity data
- —Name and email address (required for account creation)
- —Employer name (required to associate you with the correct workspace)
- —Optional profile information you choose to add (role, tenure, other demographic information relevant to peer benchmarking)
Financial data (only if you choose to add it)
- —Bank account balances, transactions, and holdings retrieved via connected bank accounts through our regulated open banking partner, Powens (see Section 07 for how this data flows)
- —Account balances and holdings from CSV bank statements you upload
- —Transaction descriptions and categorisations
- —Assets you record (property, pension, other investments)
- —Stated financial goals and plans
Behavioural data
- —Course chapters started, completed, and time spent
- —Wellbeing score progression over time
- —NPS ratings you submit
Technical data
- —Session logs (login times, device type, general location)
- —Application error logs (for debugging)
- —IP addresses (retained for security purposes only)
How we use your personal data
We use your data to:
- —Provide the Pilar service to you personally
- —Show you insights about your own finances (privately, only to you)
- —Generate aggregated, anonymised reports for your employer (see Section 05)
- —Improve our educational content and product
- —Communicate with you about service updates, security, and administrative matters
- —Meet legal and regulatory obligations
We do not sell your personal data to anyone. We do not use your data to train third-party AI models. We do not share your data with your employer at an individual level.
What your employer sees and does not see
Your employer never sees your individual financial data or personal Pilar activity.
This separation is architectural, not policy-based. See our Trust page for the full technical detail.
Your employer sees:
- —Total number and percentage of employees who have activated their account
- —Aggregate engagement metrics (average sessions per month, course completion rates)
- —Aggregate wellbeing score movement over time
- —Anonymous NPS responses
- —Content performance data (which chapters are completed most)
- —Aggregate opt-in demographic breakdown
Your employer never sees:
- —Your individual financial accounts, balances, transactions, income, savings, debts, or net worth
- —Your individual wellbeing score or NPS response
- —Your individual session activity, content history, or specific completions
- —Any aggregate report below a minimum group size (to prevent re-identification)
- —Any identification information linking behavioural or financial data to you personally
Legal basis for processing
Under GDPR Article 6, we process your personal data on the following legal bases:
- —Consent (Article 6(1)(a)): for optional data you choose to add (financial accounts, demographic information) and for waitlist processing (see Section 02)
- —Contract performance (Article 6(1)(b)): for essential data needed to provide the service (identity, account credentials)
- —Legal obligation (Article 6(1)(c)): for tax, accounting, and regulatory record-keeping
- —Legitimate interest (Article 6(1)(f)): for security monitoring, service improvement, and fraud prevention
Where processing is based on consent, you may withdraw that consent at any time through your account settings or by writing to [email protected]. Withdrawal does not affect the lawfulness of processing before withdrawal.
How long we keep your data
While your account is active
Personal profile and financial data are retained for as long as you have an active account.
When you deactivate
If your employer contract ends or you leave the organisation, your personal data is automatically anonymised 90 days after deactivation unless you migrate to a personal subscription or object to anonymisation.
If you delete your account
Full account deletion, requested via account settings or [email protected], is completed within 30 days. You will receive email confirmation.
Waitlist data
See Section 02 for retention rules that apply specifically to waitlist email addresses.
Bank connections via Powens
While a bank connection is active, banking data is held by Powens for the duration of your consent (renewable every 180 days under PSD2). If you disconnect a bank account or your Pilar account terminates, Powens retains the associated data for a maximum of 30 days before permanent destruction, in accordance with our contract with Powens. Data previously delivered to Pilar and stored in your Pilar account is retained per the general rules in this section.
Anonymised aggregate data
May be retained indefinitely for product improvement and academic research. Anonymised data cannot be linked back to you.
Your rights
Under GDPR, you have the right to:
- —Access the personal data we hold about you
- —Correct inaccurate or incomplete data
- —Delete your data ("right to be forgotten")
- —Restrict or object to certain processing
- —Receive your data in a portable format
- —Withdraw consent where processing is based on it
- —Lodge a complaint with a data protection authority
To exercise any of these rights, contact [email protected]. We respond within 30 days.
You may also lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, aepd.es).
Because Powens acts as an independent Data Controller for banking data collected via PSD2, your rights over data held by Powens may also be exercised directly with Powens, per their own Privacy Policy.
How we protect your data
All personal data is encrypted at rest (AES-256) and in transit (TLS). Sensitive fields carry additional field-level encryption.
Banking data collected via Powens is encrypted at rest on Powens' infrastructure (France, EU) and transmitted to Pilar over encrypted TLS channels. Powens' own security certifications and controls are described on our Trust page.
Full technical details on encryption, authentication, incident response, and security audits are on our Trust page.
Changes to this policy
We may update this policy to reflect changes in our practices or legal requirements. Material changes will be notified to you by email at least 30 days before they take effect.
The current version of this policy is always available at withpilar.com/legal/privacy. The date at the top indicates when the policy was last updated.