PENDING LEGAL REVIEW. Draft with no legal effect: it describes the data the app processes today, but it must be reviewed by a professional (GDPR) before publishing.

Lowco privacy policy

Version 2026-10-18. Last updated: [PENDING: date]

1. Controller

[PENDING: legal name, tax ID, address, privacy email and, if applicable, data protection officer]

2. Data we process

Account: email; hashed password if you sign up with email; Apple or Google identifier if you sign in with them; language and country.
Service use: the links and products you track, the alert type you choose, the alerts sent and whether you open them or report them as wrong, the stores you ask us to add, the products you stop tracking and, if you choose to tell us, why (for example, that you bought it).
Notifications: your device's push notification token.
Invitations: your invite code, who invited you and whom you have invited, and an app installation identifier to prevent people from inviting themselves.
Subscription: whether you have a paid plan (Pro or Pro Plus) and its status, and any "hunt mode" passes you buy. We don't see or store payment details: Apple or Google handle them.
Waiting list: if you join on the website before launch, your email, the page language, which link you came from and when you accepted this policy.
Technical data: server logs (IP address, date and requests) for security.
Fraud prevention: sign-up IP and device, and app attestation (see section 7).

3. Purposes and legal basis

To provide the service you request (performance of a contract): tracking prices, sending alerts and managing your subscription. For service security (legitimate interest). For aggregated, anonymous price and demand statistics (which products and stores people are interested in, at what price they buy) that SingularBrain uses internally in Singular Price, its price analysis service: they never include user identifiers (no ID, email or installation identifier), each data point aggregates at least 50 users and no individual data is shared with anyone (legitimate interest) [PENDING: validate the legal basis in the legal review]. To tell you about the launch if you join the waiting list (consent, which you can withdraw at any time by asking us to delete your email) [PENDING: how long the waiting list is kept after launch].

4. Who we share it with (processors)

EU server provider hosting the platform [PENDING: OVH or other].
Expo (notification service), which delivers alerts through Apple Push Notification service and Google's Firebase Cloud Messaging.
RevenueCat, to manage subscriptions bought on the App Store and Google Play.
Apple and Google, if you sign in with them, and to attest the app (App Attest and Play Integrity).
To read some store pages we use web access services; they only receive the product link, not your data.
Anthropic (Claude AI model), to extract prices from store pages we can't read otherwise: it receives the public content of the product page, not your data.

[PENDING: international transfers and applicable safeguards]

5. Retention

Products you stop tracking: we keep them for 12 months under "Previously tracked", so you can track them again with their history, along with the reason if you gave one. After that we delete them, together with the alerts we sent you about them.

[PENDING: retention periods for accounts, alerts and logs; product price history is not personal data]

6. Your rights

You can access, rectify, erase, object to, restrict and port your data by writing to [PENDING: email], and lodge a complaint with your data protection authority. [PENDING: in-app account deletion]

7. Fraud prevention

PENDING LEGAL REVIEW. This section describes the app's anti-abuse measures (ADR 068); a professional must validate the legal basis, retention periods and the information on automated decisions before it is published.

To prevent accounts from being created in bulk to abuse the free plan, we process, based on our legitimate interest in keeping the service secure:

The IP address used to sign up (and its network: the IP or, for IPv6, your line's prefix), to limit how many accounts are created from the same connection. From data centre or VPN addresses, accounts can only be created with Apple or Google.
App attestation: each time it is used, the app asks Apple (App Attest) or Google (Play Integrity) to confirm it is the genuine app, installed from their store, on a real device. We store the result and a technical identifier of that installation or of its attestation key; we do not access any other device data.
The sign-up device (that technical identifier) and whether your email is verified.
One free account per device: when an account is created we check and set, with Apple (DeviceCheck) or Google Play (device recall), a flag meaning "this device has already had a free account". Apple and Google store it against the device, not against you; we receive no device identifier. If it was already set, the new account doesn't include free watches.

Every day an automated process compares new accounts (sign-up IP, device, similar emails and watched products). If it finds a suspicious group, the account is placed under review: you can still view, export and delete your data, and a member of our team reviews it and restores it if it was a mistake. You can also write to us to request a review. [PENDING: retention period for this data and fit with Article 22 GDPR]