AVALONPLUS App — Privacy Policy
This policy covers the AVALONPLUS Android app. The website privacy notice at trading-garden.com/gdpr.html covers the website only. The same text is shown inside the app under Account → Privacy.
1. Data Controller
| Field | Details |
|---|---|
| Name | Frank Gärtner (Trading Garden) |
| Address | Stifterstr. 15/2, 4722 Peuerbach, Austria |
| Contact | support@trading-garden.com |
2. Data Processed on Your Device (Local Only)
- App settings, backtester/risk-visualizer inputs, consent flags, cached signal/market data and your notes are stored locally on your device.
- Backtests and the risk visualizer are computed locally on your device.
3. Data Processed Outside Your Device (Account & Backend)
- Account: when you sign in with Google, we process a Google account identifier and your email address via Firebase Authentication to create and secure your account.
- Push token: to deliver the daily end-of-day signal notification, we process a Firebase Cloud Messaging (FCM) registration token that identifies your specific app installation. You can disable notifications in your device settings.
- Subscription status: your trial/active/expired status is processed via Google Play Billing and our backend (account record) to unlock the service. Google Play handles the payment; we do not receive your full payment details.
- Account record & signals: a user record (keyed to your account identifier) and the daily signal/model data are stored and delivered via Google Firebase (Cloud Firestore, Cloud Functions).
- Device identifier & integrity (abuse prevention): to enforce our one-free-trial policy and prevent abuse, we process a hashed device identifier (a one-way hash of the Android device ID), your device manufacturer and model, and a Google Play Integrity verdict (Google's attestation of whether the app and device are genuine). This lets us detect a second account requesting another free trial on the same device and block trials from emulators or tampered devices. These signals are used only for security and abuse prevention — not for advertising or tracking.
4. Purposes
Provide and secure the service (account, daily signals, notifications, subscription/entitlement management), prevent misuse, and comply with legal obligations.
5. Legal Bases (GDPR)
- Performance of a contract (Art. 6(1)(b)) for account, signal delivery and subscription management.
- Consent (Art. 6(1)(a)) for push notifications (revocable any time via device settings).
- Legitimate interests (Art. 6(1)(f)) for security and abuse prevention.
6. Recipients / Processors
Firebase services: Google (Google Ireland Ltd. / Google LLC) generally processes the app's backend data as a processor under the applicable Firebase terms.
Google Play: purchases and payment-related data are processed by Google Play and the applicable Google-affiliated payment processor under their respective terms and privacy policies.
We do not sell your personal data.
7. International Transfers
Google may process data on servers outside the EEA (including the USA) under appropriate safeguards (Google's Data Processing Terms and EU Standard Contractual Clauses).
8. Retention
Account and subscription data are kept while your account exists and for as long as required by law; afterwards they are deleted. Your FCM token is cleared from your account record when you sign out or delete your account; on uninstall it becomes invalid. Local data is removed when you clear app data or uninstall the app.
When you delete your account you can choose whether we keep a minimal record of your trial status (a hashed identifier plus trial dates) so you can restore your remaining trial if you reinstall; otherwise it is erased.
9. Delete Your AVALONPLUS Account
You can delete your AVALONPLUS account directly in the app under Account → Delete Account. This deletes your account record and your authentication account and signs you out. It does not delete your Google account, and it does not cancel your Google Play subscription (cancel that separately in Google Play).
If you no longer have access to the app, email support@trading-garden.com from the email address associated with your AVALONPLUS account, and we will delete it for you.
By request: you can also request deletion of your account and associated data by emailing support@trading-garden.com with the email address used to sign in. We delete the associated account record and authentication account and confirm by email, typically within 30 days. Local data on your device is removed when you uninstall the app or clear its data. Records we are legally required to retain (e.g. for tax/accounting) are kept only for the statutory period.
10. Your Rights (GDPR)
Access, rectification, erasure, restriction, portability, and objection. To exercise them, contact support@trading-garden.com. You may lodge a complaint with a supervisory authority (in Austria: Österreichische Datenschutzbehörde, dsb.gv.at).
11. Google Play Data Safety
Information about the app's declared data practices is also available in the Google Play Data Safety section.
12. Changes
We may update this policy to reflect changes in the app or applicable law. The date at the top indicates the last revision.