Privacy Notice

1. Who we are

MySalaryPal is operated by Gary Curran, an individual based in Ireland trading as MySalaryPal. We act as the data controller for personal data processed through the Service. For payroll-admin accounts, the employer is the controller of employee payslip content; we act as processor on their behalf. If the Service transfers to an Irish limited company, we will update this notice and inform account holders.

2. What we collect & why

Payment data (card details, billing address) is collected directly by our payment provider Paddle and is not stored on our systems.

3. Who we share data with

• Hosting & infrastructure: Supabase (EU — Frankfurt) for database, authentication and file storage; the application runs on Cloudflare's EU edge.
• Edge delivery & abuse protection: Cloudflare for CDN, DDoS mitigation and Turnstile CAPTCHA.
• Transactional email: delivered through MySalaryPal's managed email service (run on EU infrastructure).
• AI processing: Payslip explanations are generated by Google Gemini, routed through the Lovable AI Gateway. Payslip text may be sent to Google for this purpose; outputs are not used to train Google's models.
• Payments: Paddle, our Merchant of Record, for sales, subscription management, tax compliance and invoicing.
• Professional advisers (accountants, legal) where strictly needed.
• Authorities where required by law.

4. International transfers

Primary processing takes place in the European Union (database in Frankfurt; application on Cloudflare's EU edge). Google Gemini is served from Google's EU multi-region, and payslip text is not routed to any US-based AI provider. Where any processor transfers data outside the EEA, transfers are protected by Standard Contractual Clauses or adequacy decisions. Copies of applicable transfer safeguards are available upon request.

5. Data retention

We align retention with statutory payroll record-keeping rules in each jurisdiction we serve. Where the law sets a longer period, the longer period applies.

• Payslip and payroll records: retained for 7 years after the end of the tax year they relate to (covers Revenue IE 6-year rule, HMRC UK 6-year rule, German GoBD 10-year rule applied per-tenant where relevant).
• Tamper-evident audit logs: retained for 7 years to support payroll and compliance investigations.
• Account & profile data: retained while the account remains active.
• Support enquiries: retained for up to 24 months.
• Authentication and security logs: retained for 12 months.
• Encrypted backups: retained for 30 days (point-in-time recovery).

If you delete your account, we delete or anonymise your personal data within 30 days, except for records we are legally required to keep (statutory payroll records and the tamper-evident audit log). Those are kept locked-down and used only to respond to lawful requests from tax authorities or to defend legal claims.

Where your employer places a legal hold on its workspace — for example because a pay-discrimination claim or investigation is open — automated deletion is suspended for the affected records until the hold is released, as permitted by Articles 22–23 of the EU Pay Transparency Directive and the establishment or defence of legal claims under GDPR.

6. Your rights (GDPR)

You have the right to access, rectify, erase, restrict, port, or object to processing of your personal data, and to withdraw consent at any time. You can also lodge a complaint with the Irish Data Protection Commission. To exercise any right, email hello@mysalarypal.com — we'll respond within one month.

6b. Pay transparency requests (EU Directive 2023/970)

Separately from your GDPR rights, if your employer uses MySalaryPal you can ask them, through the portal, for your individual pay level and the average pay levels — broken down by sex — for workers doing the same work or work of equal value. Your employer must answer within two months. Requests are logged with a deadline clock, and the answer is generated from your employer's payroll data and released by their administrators, not by us. Employers may not require you to keep your own pay confidential, and asking for this information may not be used against you.

You can also report victimisation or detriment arising from exercising these rights (Art. 24) through the portal. Those reports are visible only to your employer's designated administrators and are stored separately from your payroll record.

For this purpose your employer is the data controller; we process the request, any pay averages, gender pay-gap reports, joint pay assessment records and victimisation reports on their instructions. Category averages are computed from aggregated payroll data and never disclose another named individual's pay.

7. Security

Access to payslip content is restricted according to role-based permissions and least-privilege principles. Users only have access to data required for their role. We use encryption in transit (TLS), encryption at rest, row-level access controls, and least-privilege service accounts.

7b. Statutory filing exports

Where your employer generates a statutory filing file (Revenue, HMRC, ELSTER, DmfA or DSN), that file is built inside MySalaryPal from payroll data already held in their workspace and downloaded by their administrator. We do not transmit payroll data to any tax authority. Submission is carried out by the employer through the authority's own channel, and the employer remains the data controller for it.

8. Cookies

We only use strictly-necessary cookies (session and authentication). We do not use advertising or third-party analytics cookies.

9. Data Protection Officer

MySalaryPal is not required to appoint a Data Protection Officer under Article 37 GDPR. Privacy enquiries can be directed to hello@mysalarypal.com.

10. Contact

MySalaryPal · hello@mysalarypal.com