Privacy Policy

Version 2.0 · Effective: 2026-10-26

Highlights

  • No account, and no sign-in is needed.
  • Neither the App nor the website has third-party analytics, advertising or tracking SDKs.
  • We have no servers that store your data: your watchlist, theses and trades are stored on your device.
  • When you use AI, content goes from your device directly to the AI provider you choose, after you agree.
  • Your AI key is stored only on your device.

Scope

This Policy applies to the iOS version, the Android version and the website of “TW Stock Lens AI”. “We” means QuantumElm Holdings Inc..

Data We Do Not Collect

We do not run servers that store your watchlist, theses or trade records, and we have no account system. The App does not automatically send this data or your AI key to us, and we do not sell anyone’s personal data. The App does not use advertising identifiers and does not track you across apps or websites. Information you provide when you write to us, diagnostic information that the platform provides to us according to your settings, and the connection logs of the website hosting service are handled as described in the sections below.

Data Stored on Your Device

The App stores the following data on your device. System backups on iOS and Android are governed by your device settings and may back up App data to the cloud or a computer (the Android version is set not to back up App data). System backups are a different mechanism from the in-App iCloud sync in Section 7.

  • Content you create: watchlist, theses, trade and dividend records, and scorecard settings.
  • Your Q&A records with the AI: your questions, the AI’s answers, the excerpts of data provided to the AI at the time (including public data and any web-search summaries used), and the source URLs of those web summaries (so that references can be traced). The most recent 50 per company are kept, and you can clear them in the Q&A screen or in Settings.
  • Thesis-check results: the content the AI generated for the check, the excerpts of data provided to the AI at the time (including your thesis text, public data and any web-search summaries used), the source URLs of those web summaries, and your replies to individual questions with the AI’s follow-up questions. They are kept with the thesis; editing the thesis does not update an existing check record, a new successful check replaces it, and it is deleted together with the thesis.
  • Market data and announcements obtained from public data sources. You can clear them in Settings, and they are also pruned automatically according to retention periods.
  • Cached AI outputs, including summaries and Q&A answers, kept for up to 90 days. Clearing Q&A records does not clear this cache; you can clear it separately in Settings.
  • The version and date of the Terms of Use you agreed to, your age confirmation, the time you confirmed the exception to the seven-day withdrawal right before buying Pro, and your consent records for each AI provider.
  • The reports you leave on AI content in the App, which include: the AI content concerned and its title (such as your question or the title of your thesis), your note, the name of the AI provider and model set at the time, and when the report was created. Reports are not uploaded to us automatically; you decide whether to export them and send them to us. They are synced as well when iCloud sync is on.
  • Crash and performance diagnostics (on iOS, provided by Apple’s MetricKit): up to 20 are kept on the phone. The App does not send these reports to us automatically; you can export them yourself, and the reports may also be preserved in iOS system backups.

Deleting the App removes its local data, but it does not delete existing system backups, files you exported, or data synced to iCloud; those copies must be managed separately. For what is synced to iCloud when iCloud sync is on, see “iCloud sync” below.

Connections to Public Data Sources

The App connects from your device to public data sources (for example, the Taiwan Stock Exchange and the Taipei Exchange) to retrieve end-of-day data and announcements. As with browsing any website, they can see connection information such as your IP address. The content of the requests includes none of your personal data.

Data Sent to AI Providers

This happens only when you set up an AI key (or sign in with an OpenRouter account) and use an AI feature.

  • Content goes from your device directly to the provider you choose (Google Gemini, OpenAI, OpenRouter or Anthropic), without passing through us. When you use OpenRouter, content goes first to OpenRouter, which then forwards it to the model’s provider according to the model, the routing and your account settings; both free and paid models may involve upstream processing.
  • Content falls into three scopes: public data (announcements, revenue, financial statements), text you write, and personal images or documents (such as brokerage statements). Before the first time each scope is sent to each provider, the App explains what will be sent and to whom, and sends it only with your consent. Switching providers or encountering a new scope asks for your consent again; switching to an OpenRouter model marked as free also asks for separate consent. A Gemini key belongs to either a free or a paid tier, which the App cannot tell apart; please confirm this yourself. You can withdraw consent in Settings.
  • Context for conversations and replies: when you use Ask AI, the App sends the text of up to your 3 most recent questions and answers for the same company that are still shown on screen (answers are shortened), together with the new question, to the provider you choose at the time, so that follow-ups make sense; with “Search the web” on, it also provides up to your 2 most recent questions for that company to generate search queries. When you reply to a question in a thesis check, the App also sends the data from the original check, that question, and your earlier replies to it with the AI’s follow-up questions. After you clear the Q&A records for a company, new questions and searches no longer include the cleared records; clearing does not cancel processing that has already started, so a question or search in progress may still send what it had already taken, and it does not delete data the provider has already received.
  • Web search (the “Search the web” option in thesis checks and Ask AI): when it is on, the App first sends the content described in this section to the provider you choose, which generates search queries and searches the web itself or through a search partner it uses; the queries may include wording you enter now or entered earlier. With OpenRouter, the App specifies that Exa runs the search; with Anthropic or OpenAI, each provider supplies the search feature and may use search partners it selects. This processing may take place outside Taiwan and is governed by the terms and policies of each provider and search partner. The App asks for separate consent before the first use; after you consent, “Search the web” is on by default and shared by thesis checks and Ask AI, and you can turn it off at any time. One action may run several searches; searches are billed separately from model usage, at the provider’s rates, to your provider account. This feature is not offered with Gemini. For how search partners handle data, see the documentation published by each AI provider; Exa’s privacy policy: https://exa.ai/privacy-policy.
  • Brokerage statement import (Pro): The iOS version first recognizes text on the phone. When you are on iOS 26 or later, the device supports Apple Intelligence, and the on-device model is enabled, available and supports the required language, the statement is organized on the phone first; in this case the statement is not sent anywhere and no AI key is needed. Only when the on-device model is unavailable, or the processing did not complete and you choose to use a provider instead, is the recognized text sent to the provider you choose, and images are sent only for pages from which no text could be recognized. If no trades can be read from the text, you can choose to send all pages as images to the same provider instead. The Android version does not recognize text on the phone: every page (up to the first 5) is sent as an image to the provider you choose, after you consent before it is sent. When a statement is to be sent to a third party, free models and routes whose actual model cannot be confirmed cannot be used, and Gemini is not currently offered (see Section 5(4) of the Terms of Use).
  • How a provider stores, trains on and deletes what you send is governed by that provider’s terms, its privacy policy and your account settings, and processing may take place outside Taiwan. When you use free models, providers that offer free quota may keep what you send or use it for training; content on the Gemini free tier is used by Google to improve its products and may also be reviewed by people. Each provider’s policies: Google (https://ai.google.dev/gemini-api/terms, https://policies.google.com/privacy), OpenAI (https://openai.com/policies/privacy-policy), OpenRouter (https://openrouter.ai/privacy), Anthropic (https://www.anthropic.com/legal/privacy).

Do not send content that contains personal, confidential or sensitive information to a free service. Please also avoid including unnecessary personal data in text you send to AI.

AI Keys

AI keys (including keys obtained by signing in with an OpenRouter account) are stored in the Keychain on iOS; on Android, they are encrypted with a key managed by Android Keystore and stored in the App’s private storage. Keys are not synced, are not backed up to other devices, and are never written to logs, crash reports or export files. When an AI service is called or queried, the key is sent to that provider over an encrypted connection for authentication, and it is not sent to us. You can remove a key in Settings at any time.

iCloud Sync (iOS Pro, off by default; where your version offers it)

When turned on, your watchlist, theses, trade and dividend records, AI Q&A records, and the reports you leave are synced to your own private iCloud database. This database belongs to your Apple Account, and we cannot see it. AI keys, separately stored market data and the AI cache are not synced; the data excerpts, web-search summaries and source URLs included in Q&A records and thesis-check results, and your replies and the AI’s follow-up questions in thesis checks, are synced together with those records. You can turn off sync in the App’s settings, or manage and delete this data in the iCloud settings of iOS.

Export (Pro)

The data export in this section creates a file only when you ask for one, and you decide where it is stored or shared. Export files contain only your watchlist, theses, trade and dividend records; they do not contain AI keys, market data, AI Q&A records or thesis-check results. Reports and diagnostics have their own export functions (see Section 3).

Notifications

Notifications are scheduled locally by the device; there is no push server. A new-announcement notification contains only the company name and the original subject line of the announcement, with no AI text. When the subject contains price-level or rating wording, the original subject is not shown, and a fixed message is shown instead (please open the App to read the original).

Purchases

Purchases are processed by the Apple App Store (Google Play on Android), and we do not receive your payment information. The App checks your purchase status with Apple or Google on the device.

Crash and Performance Information

The App has no third-party crash-reporting SDK. If you choose in iOS settings to share analytics data with app developers, Apple provides crash and diagnostic information to developers under its policies. The same applies to the Android version: if you turn on “Usage & diagnostics” in your Android device settings, Google provides crash and ANR information to us through the Play Console under its policies. This information does not include your content in the App; we use it only to fix problems. This information is kept in Apple’s App Store Connect and Google’s Play Console, for the retention periods set by Apple and Google; copies we download to fix a problem are deleted after the problem is fixed.

When You Write to Us

To reply to inquiries, handle complaints and resolve problems, QuantumElm Holdings Inc. collects the email address, message content and attachments (such as the reports on AI content or diagnostic reports you exported) that you provide when you write to support@twstocklens.app. This data is handled by our authorized personnel, and by Cloudflare (entrusted with email forwarding) and Google (Gmail, providing the mailbox), in Taiwan and in the locations of these providers’ servers outside Taiwan, through email, electronic storage and issue tracking. It is not used for marketing and is not provided to other third parties (except where required by law). The data is kept until one year after the issue is closed and is deleted when that period expires; where the law requires longer retention, data is kept only to the extent and for the period necessary. If the law requires us to refund you directly, we will separately collect the necessary payment details at that time, use them only for that refund, and keep the related accounting records for at least five years as the Business Entity Accounting Act requires.

You may write to support@twstocklens.app to request to inquire about or review, obtain a copy of, supplement or correct, stop the collection, processing or use of, or delete your personal data. We will handle your request as the law requires, and where the law does not allow us to comply in full, we will explain why. Whether to provide this data is up to you. Without contact information we cannot reply; without problem details we may be unable to resolve the problem. The App’s other features are not affected.

Website

The website is static. The web pages themselves set no cookies, place no tracking code or third-party analytics, and load no fonts or scripts from outside. We entrust Cloudflare (Cloudflare Pages) to host the website: to provide website connections, maintain security and resolve problems, Cloudflare processes connection information such as your IP address, browser information and access time as electronic records, and may set security cookies in your browser to block automated traffic or verify connections. The processing region includes Cloudflare’s global network outside Taiwan, and the retention period follows Cloudflare’s privacy policy (https://www.cloudflare.com/privacypolicy/). We do not separately download or keep individual access logs; the traffic statistics and security event records in the Cloudflare dashboard are used only by our authorized personnel to maintain security and resolve problems. You may write to support@twstocklens.app to request to inquire about or review, obtain a copy of, supplement or correct, stop the collection, processing or use of, or delete it, and we will handle your request as the law requires. If you do not provide the necessary connection information, the website may not be able to provide its content normally.

Age

The App may be used only by people who are at least 18 years old, and it is not directed at children.

Your Choices

Because the data is on your device (or in your own iCloud), you can manage it directly: clear market data and the AI cache in Settings, clear AI Q&A records, remove keys, withdraw AI consent, turn off “Search the web”, turn off iCloud sync, or delete the App.

Changes to This Policy

When this Policy changes, we will update this page and the version and effective date above. For a change that is materially disadvantageous to you, we will notify you in the App and ask you to agree again.

Contact Us

If you have any questions about this Policy, please write to support@twstocklens.app to contact QuantumElm Holdings Inc..