Last updated: [DD MONTH 2026] Effective: [DD MONTH 2026]
Lodestone ("the App") is provided by SIA Kellosolutions ("Kellosolutions", "we", "us", "our"), a limited liability company registered in the Republic of Latvia.
Company
SIA Kellosolutions
Registration number
[REG. NO.]
Registered address
[STREET, CITY, POSTAL CODE], Latvia
Contact
info@kellosolutions.com
We are the data controller for personal data processed through the App within the meaning of Regulation (EU) 2016/679 (the GDPR).
We are established in the European Union, so we are not required to appoint an Article 27 representative. We have not appointed a Data Protection Officer, as our processing does not meet the Article 37 thresholds. Contact info@kellosolutions.com for any privacy matter.
The short version, in plain language:
Your sensor readings stay on your device. Magnetometer data is processed locally and never transmitted to us.
Your saved finds stay on your device. Notes, photos and locations are stored in local app storage. We cannot see them.
AI Identify is the one feature that sends data off your device, and only when you tap it. It sends the numeric signal profile and, if you attach one, your photo.
We do not sell your personal data. We do not share it for cross-context behavioural advertising. We do not run third-party ad networks or trackers.
We do not require an account. The App is fully usable without giving us your name, email address or any identifier you control.
Magnetometer readings, calibration baselines, signal history and derived values are processed entirely on your device. This data is not transmitted to us and we have no access to it.
Sensor readings are not personal data in themselves. We describe the processing here for transparency.
Notes, tags, timestamps, attached photos and (if you enable it) coordinates are stored in your device's app storage. We do not receive, store or back up this data.
If you use the export or share function, you decide where that data goes. Anything you send through the iOS or Android share sheet is governed by the privacy policy of the app or service you send it to.
Deleting the App deletes this data permanently. We cannot recover it for you.
When you tap Identify or send a message to the AI Field Assistant, we transmit the following to our processing server and from there to Google:
Data
Always or optional
Scan mode, peak deviation, baseline, signal shape and duration
Always
A pseudonymous app instance identifier
Always
Your subscription entitlement status
Always
A photo, if you attach one
Optional — only if you attach it
A free-text note, if you write one
Optional
Your message text in the AI Field Assistant
Only in Assistant conversations
Legal basis: Article 6(1)(b) GDPR — performance of the contract, because AI interpretation is a feature you have asked us to provide. Where you attach a photo, we additionally rely on your consent under Article 6(1)(a), given by the act of attaching it after being informed.
Retention: Requests are processed in transit and are not stored in an identifiable form on our servers. We retain aggregated request counts (per pseudonymous identifier, per day) for up to 90 days, solely to enforce free-tier quotas and to detect abuse. The content of your requests, including photos, is not retained by us after the response is returned.
A specific warning about photos. A photo you attach may contain personal data — a face, a licence plate, a document, an identifiable interior. If it contains an image of a person, it may constitute biometric-adjacent data. Please do not photograph people. The App has no need for it and you should not include anyone in frame.
If, and only if, you enable location tagging for saved finds, we request permission for your device's approximate or precise location. Coordinates are attached to the find record and stored locally. They are not transmitted to us and are not sent with AI Identify requests.
Legal basis: Article 6(1)(a) GDPR — consent. You can withdraw it at any time in your device settings or in the App's Settings screen, without affecting any other feature.
Under the California Consumer Privacy Act, precise geolocation is sensitive personal information. We use it for the single disclosed purpose of tagging your own finds on your own device, and for nothing else.
Subscriptions are managed by RevenueCat, Inc. on our behalf. Payment is taken by Apple or Google — we never see or receive your card details, billing address or full name.
We receive from RevenueCat: a pseudonymous app user ID, your entitlement status, product identifier, purchase and expiry dates, platform, country, and renewal or cancellation events.
Legal basis: Article 6(1)(b) GDPR — performance of the contract. Retention: for the life of the subscription plus 7 years, to meet Latvian accounting and tax record-keeping obligations (Article 6(1)(c) GDPR).
If you grant notification permission, we store a push token to deliver calibration reminders, trial-expiry notices and, if you opt in separately, occasional product messages.
Legal basis: consent, Article 6(1)(a). Revocable in device settings at any time.
We collect crash logs and basic technical diagnostics — device model, OS version, App version, locale, crash stack trace, and a pseudonymous installation identifier.
Legal basis: Article 6(1)(f) GDPR — our legitimate interest in keeping the App stable and secure. We have assessed that this processing has minimal privacy impact, uses no directly identifying data, and is what a user would reasonably expect. You may object under Article 21 by writing to info@kellosolutions.com.
Retention: 12 months.
If you email us, we process your email address and whatever you choose to put in the message. Legal basis: Article 6(1)(f) — legitimate interest in responding to you. Retention: 24 months after the matter is closed.
We do not use third-party advertising SDKs. We do not use analytics SDKs that build cross-app profiles. We do not use the Advertising Identifier (IDFA/AAID) and we do not present the App Tracking Transparency prompt, because we do not track you across apps or websites owned by other companies.
Recipient
Role
Data
Location
Google Ireland Ltd / Google LLC (Gemini API)
Processor
AI request content, incl. attached photos
EU and USA
RevenueCat, Inc.
Processor
Subscription status, pseudonymous ID
USA
Apple Inc. / Google LLC
Independent controllers
Payment and account data
USA and elsewhere
[HOSTING PROVIDER]
Processor
API request routing
[REGION]
[CRASH REPORTING PROVIDER]
Processor
Crash diagnostics
[REGION]
Some of these transfers involve countries outside the European Economic Area. Where that happens, we rely on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) together with a transfer impact assessment, or, where the recipient is certified, the EU–US Data Privacy Framework.
You may request a copy of the relevant safeguards by writing to info@kellosolutions.com.
We may also disclose data where legally compelled — to a competent court, regulator or law enforcement authority acting under a valid legal instrument — or where necessary to establish, exercise or defend legal claims. In a merger or acquisition, data may transfer to the successor entity, and we will notify you before it takes effect.
Under the GDPR you have the right to access your data, to rectify it, to erase it, to restrict processing, to data portability, to object to processing based on legitimate interests, and to withdraw consent at any time without affecting the lawfulness of prior processing.
Because we hold very little identifiable data about you, most of these rights are exercised most quickly on your own device: delete finds in the App, revoke permissions in device settings, or uninstall the App.
To exercise a right against us, write to info@kellosolutions.com. We respond within one month, extendable by two further months for complex requests, and we will tell you if we need the extension. Exercising your rights is free; we may charge a reasonable fee only for manifestly unfounded or excessive repeat requests.
To identify your data, we will normally need the pseudonymous app user ID shown in Settings → About → Diagnostics. Without it we may be unable to locate any record, and we will not ask you for additional identity documents merely to create one.
You may lodge a complaint with the Latvian supervisory authority:
Datu valsts inspekcija (Data State Inspectorate) Elijas iela 17, Riga, LV-1050, Latvia pasts@dvi.gov.lv · www.dvi.gov.lv
You may also complain to the supervisory authority in your own EU country of residence or workplace.
Depending on your state, you may have the right to know, delete, correct and obtain a portable copy of your personal information, to opt out of sale or sharing, and to limit the use of sensitive personal information. You have the right not to be discriminated against for exercising these rights.
We do not sell personal information and we do not share it for cross-context behavioural advertising, including that of anyone we know to be under 16. Requests go to info@kellosolutions.com. You may use an authorised agent, in which case we will require written proof of authorisation.
The App is not directed at children and is rated for users aged 13 and over. We do not knowingly collect personal data from children under 13 (or under 16 in EU Member States that have set a higher age of digital consent).
If you believe a child has provided us with personal data, contact info@kellosolutions.com and we will delete it.
The AI Identify and AI Field Assistant features use a large language model provided by Google.
You are interacting with an AI system, not a human. We state this here and in the App itself, in accordance with Article 50 of Regulation (EU) 2024/1689 (the EU AI Act), which has applied since 2 August 2026.
Points you should understand:
AI output is an estimate, not a measurement. It can be wrong, and it can be confidently wrong.
We do not use your inputs to train our own models. Google's use of data submitted through its paid API is governed by its terms; we have configured our integration to exclude submitted content from model training.
No automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR takes place in the App.
Never rely on AI output for a safety decision. See the Terms of Service, section 5.
We use TLS for all data in transit, hold no API credentials in the App binary, apply access controls and least privilege to our servers, and keep no identifiable copies of AI request content.
No system is perfectly secure. If a breach occurs that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and notify Datu valsts inspekcija within 72 hours, as required by Articles 33 and 34 GDPR.
We may update this policy. Material changes will be notified in the App and by updating the date at the top. Where a change requires your consent, we will ask for it before it takes effect. Continued use after a non-material change means you accept the updated policy.