Effective date / Last updated: 2026-06-26
This Privacy Policy explains how the Nudge Invest mobile app (Android package com.nudgeinvest.app, the “app”) handles your data. The app is developed and operated by Sergiy Zyuzko, an individual developer (trading as “TreeSolutions”) (“we,” “us,” the “developer”).
Nudge Invest is a personal investment / portfolio tracker. It is offline-first: the app works on your device, and by default it keeps your information on your device.
This policy covers the app itself and the small developer-operated proxy server used by the optional AI Coach feature. It does not cover any third party’s own products or websites, which are governed by their own policies.
The following data is created and stored locally on your device and is not sent anywhere by default:
| Data | Stored where | Leaves the device? |
|---|---|---|
| Assets / holdings | Local on-device database (SQLite via WatermelonDB) | Only if you use an optional feature (Section 5) |
| Transactions | Local on-device database | Only if you use an optional feature |
| FX (exchange) rates you enter | Local on-device database | Only if you use an optional feature |
| Daily portfolio snapshots | Local on-device database | Only if you use the AI Coach — your portfolio value history can be sent as context when “Portfolio totals” is enabled (Section 5.1) |
| AI Coach chat history | Local on-device database | Stored locally; individual messages you send are processed as described in Section 5.1 |
| App lock PIN | Stored as a salted hash in the device secure keystore | Never transmitted |
You control this data. See Section 9 (Data retention, deletion, and your control).
You can optionally protect the app with a 4-digit PIN. The PIN is stored only as a salted hash in your device’s secure keystore — the PIN itself is never stored in plain text and is never transmitted off the device. You may also enable biometric unlock (e.g., fingerprint/face), which is handled entirely by your device’s operating system. All app-lock data stays on your device.
The app transmits data off your device only in the situations below. Each is optional.
When you chat with the AI Coach, the app sends selected portfolio data as context to a proxy server (a Cloudflare Worker operated by the developer), which forwards it to Anthropic (the Claude API) for processing and streams the reply back to you.
If you enable Price Refresh, the app fetches current market prices for your holdings. Through the same developer-operated proxy, it sends each holding’s ticker/symbol, asset type, and currency code to CoinGecko (for crypto) and Twelve Data (for stocks/ETFs/REITs).
In-app purchases are processed through Google Play Billing, and subscription state is managed by RevenueCat.
x-app-user-id header) so the proxy can verify that you have an active subscription before serving the AI Coach.The AI Coach can optionally look up current public facts (for example, a country’s latest inflation rate) using a web search tool. This is off by default and runs only when you turn on Web search in Settings → AI privacy.
The table below summarizes every situation in which data may leave your device, who receives it, why, and whether it is optional.
| Data type | When it leaves the device | Recipient | Purpose | Optional? |
|---|---|---|---|---|
| Selected portfolio data (totals, per-asset metrics, transactions — as you toggle) | Only when you chat with the AI Coach | Developer-operated proxy → Anthropic | Generate AI Coach responses | Yes |
| Free-text notes | Only if you opt in (off by default) | Developer-operated proxy → Anthropic | Provide additional context to the AI Coach | Yes (opt-in) |
| Attachments you add (images, PDFs, CSVs) | Only when you attach them in the AI Coach | Developer-operated proxy → Anthropic | Parse statements/files you provide | Yes |
| Holding symbols, asset types, currency codes | Only when you use Price Refresh | Developer-operated proxy → CoinGecko (crypto) and Twelve Data (stocks/ETFs/REITs) | Look up current market prices | Yes |
| Currency-pair codes (e.g. EUR, UAH) | Only when you ask the Coach to look up / update an FX rate | Developer-operated proxy → Twelve Data | Look up current exchange rates | Yes |
| Web-search queries the Coach generates | Only when Web search is on (off by default) and the Coach searches | Developer-operated proxy → Anthropic | Look up current public facts (e.g. inflation) | Yes (opt-in) |
| App-generated app-user identifier + purchase/receipt info | Only when you make/manage a purchase | RevenueCat; the app-user identifier is also sent to the developer-operated proxy | Manage subscription entitlements and verify active access | Yes |
| Payment details (card, etc.) | At purchase | Google (Google Play Billing) — not the developer | Process payment | Yes |
| Network transit (all of the above) | Whenever an optional feature sends data | Cloudflare (hosts the developer proxy) | Route requests over the network | Yes |
All transmissions above use encrypted connections (HTTPS/TLS). See Section 8 (Security).
The developer-operated proxy additionally stores limited usage counters and request metadata tied to your app-user identifier (no portfolio content) for rate-limiting and abuse prevention — see Section 5.1.
The app shares data with the following third parties only in connection with the optional features described above. Each operates under its own privacy policy and terms, which you can find on the provider’s website.
| Third party | Role | What it receives |
|---|---|---|
| Anthropic | AI processing (Claude API) for the AI Coach; web search when enabled | The portfolio context and attachments you choose to send to the Coach; and, when Web search is on, the search queries the Coach generates |
| CoinGecko | Market-price lookups (crypto) | Holding symbols, asset types, currency codes |
| Twelve Data | Market-price lookups (stocks/ETFs/REITs) + FX-rate lookups | Holding symbols, asset types, currency codes; and currency-pair codes for FX rates |
| RevenueCat | Subscription management | App-generated app-user identifier and purchase/receipt info |
| Cloudflare | Hosts the developer-operated proxy / handles data transit | Data passing through the proxy in transit |
| Google (Google Play) | App distribution and in-app billing | Payment details and purchase processing |
We do not sell your data, and we do not share it for advertising or marketing purposes. The data above is disclosed to these providers only to deliver the optional features you choose to use.
To be explicit, the app does not:
No method of transmission or storage is completely secure. We take reasonable measures, but we cannot guarantee absolute security.
Because your data lives on your device, you control it:
Depending on where you live, you may have rights under laws such as the EU/UK GDPR or the CCPA/CPRA, including the rights to access, correct, delete, or port your personal data, and to object to or restrict certain processing.
Because Nudge Invest stores your portfolio data locally on your device and keeps no server-side account, most of these rights are something you can already exercise directly: you can view, edit, export, or delete your data within the app, and uninstalling removes it. For data handled by the third parties named in Section 7 (Anthropic, CoinGecko, Twelve Data, RevenueCat, Cloudflare, Google), you may exercise applicable rights with those providers under their policies. If you have questions or a request relating to data the developer controls, contact us at the address in Section 14.
Nudge Invest is not directed to children. We do not knowingly collect personal data from children under 13 (or under 16 in the European Union). If you believe a child has provided us with personal data, please contact us so we can address it.
We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this document and post the updated version at the same public URL. Your continued use of the app after an update means you accept the revised policy.
If you have questions about this Privacy Policy or the app’s data practices, contact the developer:
This Privacy Policy is governed by the laws of Ukraine, without regard to conflict-of-law principles. If you use the app from the European Union / EEA, nothing here limits the data-protection rights you have under the EU GDPR (see Section 11).
Nudge Invest is a personal portfolio tracker with an optional educational AI assistant. It executes no trades, is not a broker or financial adviser, and does not provide personalized investment advice. This document addresses privacy only; it is not legal advice.