Privacy Policy

Last updated: 13 May 2026

Stock Average Cost Calculator ("Stock Avg", "the app", "we", "us", "our") is a calculator app for tracking stock cost-averaging trades. This policy explains how the app handles data and what rights you have.

1. Summary

We practice data minimization. You do not create an account, sign in, or provide a name, email, or phone number to use the core features. The app does not send your buys, your positions, or any of the numbers you enter to us or to any other party. All of that stays inside your phone's local storage. The only external service involved is the in-app purchase / subscription flow, which is operated by Apple (on iOS), Google (on Android), and our payments partner RevenueCat. In connection with that flow, RevenueCat generates an anonymous identifier for your installation; what that identifier is and how it is used is described below.

2. What we collect

The app collects very little from you, and only in connection with the in-app purchase flow. Specifically:

  • • Anonymous RevenueCat subscriber identifier. A random alphanumeric string RevenueCat generates the first time the app communicates with their servers. It is not derived from any personal information you have (no name, no email, no phone number, no advertising identifier), and we never connect it to such information. It allows RevenueCat to associate your purchase with your installation so the "Restore purchase" feature works across devices that share your App Store or Google Play account. The identifier is displayed on the Settings screen of the app so you can include it when contacting us for support.
  • • Purchase metadata. If you purchase, the product you purchased, the date and time of the purchase, the price paid, the currency, and the country reported by the platform. RevenueCat receives this from the App Store / Google Play receipt.

That is the complete list of what leaves your device. Apple's App Privacy framework treats the subscriber identifier as a user identifier linked to your purchase record within RevenueCat's records; we declare it accordingly in our App Store listing.

3. What we do NOT collect

Apart from the anonymous identifier and purchase metadata listed in the section above, the app does not collect, transmit to a server, store on a server, or share with any third party:

  • • Your name, email address, phone number, or any other contact details.
  • • Tickers you enter, share counts, prices, capital deployed, P&L figures, or any other position information.
  • • Your IP address, your precise location, your approximate location, or any device geolocation signal.
  • • Your device's advertising identifier (Apple IDFA, Google AAID) or any cross-app tracking signal.
  • • Browsing history, cookies, or analytics events about your activity inside the app.
  • • Crash reports, performance traces, or diagnostic logs.

The app does not request the App Tracking Transparency permission on iOS, because the app does not track you across other apps or websites.

4. What stays on your device

The following information is created by you, stored locally on the device where you installed the app, inside the app's operating-system-sandboxed storage area, and never transmitted anywhere:

  • • Positions you save (ticker symbol, open/closed status, creation date, closing date).
  • • Tranches (each executed buy and each planned buy: number of shares, price per share, order, date).
  • • Closed-trade exit data (exit price, exit shares).
  • • Your Settings preferences (the price-target multipliers you have configured and your chosen display currency symbol).
  • • Whether you have completed the initial onboarding walkthrough.

This data lives in a private SQLite database that only this app can access on this device. It is removed automatically when you uninstall the app. We have no copy of it; we cannot recover it if you uninstall the app, wipe its storage, or lose the device.

5. Purchases (in-app)

If you purchase a subscription or one-time access, three parties handle the transaction:

  1. Apple (App Store) or Google (Google Play). The platform processes the payment, holds your billing information, and issues a digital purchase receipt. We never see your credit card or banking details. Apple's and Google's respective privacy policies govern that flow.
  2. RevenueCat, Inc. Our subscription-management provider. The first time the app talks to RevenueCat's servers, RevenueCat generates a random anonymous identifier — the RevenueCat subscriber ID — for your installation. RevenueCat receives that ID, the platform receipt, and the purchase metadata listed above. The subscriber ID is treated by Apple's App Privacy framework as a user identifier linked to your purchase record within RevenueCat's records; it is not derived from any personal information on your side, and we never connect it to such information. RevenueCat uses this data exclusively to validate the purchase, keep track of whether your access is currently active, and power the dashboard analytics that we (the developer) see. This is also what enables the "Restore purchase" feature on a new device or after reinstalling. RevenueCat's own privacy policy is published at https://www.revenuecat.com/privacy.
  3. Loheden AI Solutions AB (us). We see an aggregated record of purchases through RevenueCat's dashboard — for example, the count of purchases on a given day, the country breakdown, and the revenue total. We do not see your name, your email address, your payment details, or any of the position data you entered into the app. The only identifier visible to us in connection with your purchase is the anonymous RevenueCat subscriber ID, which is also visible to you on the app's Settings screen.

If you do not purchase, RevenueCat receives nothing from your installation.

6. Sharing and Disclosures

We share data only as described in this policy, primarily with service providers (like RevenueCat) who help us operate the purchase infrastructure.

Corporate transactions: If we merge, acquire, or sell assets (for example, if the app is sold to another developer), the anonymous purchase records and subscriber identifiers may transfer to the new owner under this policy to ensure your subscription continues uninterrupted.

Legal requirements: We may disclose data to comply with applicable law, regulation, legal process, or governmental request, or to protect our rights, security, or integrity.

7. Refund-Related Data Sharing with Apple App Store Customers

If you request an Apple App Store refund, Apple may ask us to confirm limited purchase data — for example, the purchase identifier RevenueCat holds for your transaction and which subscription tier you bought. We share only what is necessary to help Apple verify refund eligibility and prevent misuse. Because the app does not collect usage analytics or keep time-stamped feature-access logs, we have nothing else to share beyond the basic purchase record.

8. Platform-level data we do not control

The App Store, Google Play, and the underlying operating systems may collect their own data about app downloads, crashes, performance, and store interactions under their own privacy policies. We have no control over and no access to this data beyond the aggregated, anonymous reports that the platforms make available to all developers (for example, total downloads per country). Those reports never contain personal identifiers.

9. International transfers

Loheden AI Solutions AB is based in Sweden. RevenueCat, Inc. is based in the United States. If you live in the European Economic Area, the United Kingdom, or Switzerland, the limited data RevenueCat receives in connection with your purchase is transferred to and processed in the United States. RevenueCat relies on the European Commission's Standard Contractual Clauses (Article 46 GDPR) as the legal mechanism for that transfer. No other personal data leaves the European Economic Area, because no other personal data leaves your device.

10. Children's privacy

The app is not directed at children under the age of 13 (under the age of 16 in the European Economic Area). We do not knowingly collect personal data from children. Because the app does not implement an account system and does not collect personal data from anyone beyond the anonymous purchase-related identifier described above, there is no children's-data exposure beyond what is stored locally on the device itself, which remains under the control of the device's user.

11. Your rights under the GDPR (EU/EEA, UK, Switzerland)

If you live in the European Union, the European Economic Area, the United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation and the corresponding UK and Swiss legislation:

  • • The right of access — to be told what personal data we hold about you.
  • • The right to rectification — to have inaccurate personal data corrected.
  • • The right to erasure — to have your personal data deleted.
  • • The right to restrict processing.
  • • The right to data portability — to receive your personal data in a structured, machine-readable format.
  • • The right to object to processing.
  • • The right to lodge a complaint with your national supervisory authority. In Sweden (the country where Loheden AI Solutions AB is established), that authority is the Integritetsskyddsmyndigheten (IMY).

For the data that stays on your device, these rights are fully exercisable by you at any time without contacting us: edit or delete your data inside the app, or uninstall the app to remove all locally stored data. For the limited data RevenueCat holds in connection with your purchase, write to us at the address at the bottom of this policy with your RevenueCat subscriber ID (shown on the app's Settings screen) and we will pass any access, correction, or erasure request on to RevenueCat, subject to the retention obligations described later in this policy.

The lawful basis for the limited processing that takes place if you make a purchase is the performance of a contract you initiated by tapping the purchase button (GDPR Article 6(1)(b)). That processing is strictly necessary to validate the purchase and keep your access active for as long as you have paid for it.

12. Your rights as a California resident (CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

  • • The right to know what personal information we collect, use, disclose, or share.
  • • The right to delete personal information we have collected.
  • • The right to correct inaccurate personal information.
  • • The right to opt out of the sale or sharing of personal information.
  • • The right to limit the use of sensitive personal information.
  • • The right to non-discrimination for exercising any of these rights.

We do not sell, share, or otherwise disclose your personal information within the meaning of the CCPA or CPRA. We have not done so in the preceding 12 months and we have no plans to do so. We do not process "sensitive personal information" as that term is defined by California law.

13. Data retention and deletion

We retain no personal data on our servers, because we do not operate any.

The data you create inside the app is retained on your device until you delete it inside the app (for example by deleting a position) or uninstall the app. Uninstalling the app permanently removes all locally stored data. There is no cloud backup. There is no recovery process.

If you would like RevenueCat to delete the anonymous purchase record associated with your installation, write to us at the contact details below with your RevenueCat subscriber ID (shown on the app's Settings screen) and we will pass the request on to RevenueCat. Deletion is subject to retention obligations RevenueCat has under tax, accounting, and consumer-protection law (typically up to seven years for purchase records), which we cannot waive.

14. Security

We apply technical and organizational measures appropriate to the risk to protect any limited data processed in connection with in-app purchases. The app itself stores its data inside the platform-provided, per-app sandbox, which is isolated by the operating system from other apps on the device, utilizing a local-first model. We do not operate any servers that hold your data, meaning there are no server-side credentials, databases, or customer lists that could leak from us. The only data flow that leaves the device is the in-app purchase, which is encrypted in transit by Apple, Google, and RevenueCat using standard industry transport-layer encryption (TLS).

While no system is entirely secure, we practice data minimization and rely primarily on device-level security for your core data.

15. Market data and third-party content

If the app displays third-party market, reference, or informational content (such as stock ticker prices), that content may be delayed, incomplete, or inaccurate. Limited request or device data may be processed by the third-party provider to serve that content. Loheden AI Solutions AB is not responsible for third-party content accuracy or reliability.

16. Changes to this policy

If we update this policy, we will revise the "Last updated" date at the top of this page. The policy will always be available at https://loheden.com/stock-avg-privacy. Because the app does not have your contact information, we are unable to notify you of changes individually — please check the URL above periodically to stay informed.

17. Contact

If you have any question about this policy or about how the app handles data, write to us at:

Loheden AI Solutions AB
Vretavägen 26
71993 Vintrosa
Sweden

Email: [email protected]