Privacy Policy for Freedom Clock

Last Updated: April 5, 2026

Effective Date: April 5, 2026

1. Introduction

Newron Robotics, LLC (“we,” “our,” “us,” or “Company”), a Delaware limited liability company, operates the Freedom Clock mobile application (“App”). This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your information when you use our App. Freedom Clock is designed as a local-first application: your core retirement planning data stays on your device and is not uploaded to our servers. We minimize server-side access to personal financial data wherever practical.

By installing, accessing, or using Freedom Clock, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the App.

1.1 Scope

This Privacy Policy applies to the Freedom Clock iOS application and all associated services, including:

• The core retirement planning calculator and tools
• The optional AI assistant feature (powered by third-party AI providers)
• Premium subscription features
• Our Firebase Cloud Functions backend that processes AI requests

1.2 Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland, we process personal data under the following legal bases:

• Consent: For optional sharing of data with external AI providers, and for analytics or diagnostics where consent is required by applicable law
• Contract Performance: To provide the App's core functionality, backend service access, and premium subscription services
• Legitimate Interest: For security monitoring, fraud prevention, rate limiting, abuse prevention, device attestation, and service improvement, balanced against your rights and interests

2. Information We Collect

2.1 Information You Provide Directly

2.2 Information Collected Automatically

2.3 Information We Do NOT Collect

• Precise Location: We do not collect or store precise GPS coordinates. During onboarding, with your explicit permission, we may access your device's approximate location (city-level accuracy) once to auto-detect your city for cost-of-living calculations. This approximate location is used in-memory only, is not stored on our servers, and is not transmitted to third parties. Your user-entered location preferences (country, state/province, city) are stored as part of your retirement plan and may be shared with AI providers when external AI is enabled (see Section 4).
• Contacts, Calendar, or Photos: We do not access your device contacts, calendar, camera, or photo library
• Health Data: We do not access Apple Health or HealthKit data
• Advertising Device Identifiers: We do not collect the IDFA (Identifier for Advertisers), device advertising identifiers, or fingerprint your device for advertising or cross-app tracking purposes. The device-level identifier described in Section 2.2 is used solely for security, abuse prevention, and fair-use enforcement.
• Browsing History: We do not track websites you visit or apps you use outside Freedom Clock
• Financial Account Numbers: We do not collect bank account numbers, credit card numbers, Social Security numbers, or other sensitive financial identifiers
• AI Conversation Text: We do not log or store AI conversations on our servers. Your full AI conversation history, including per-thread conversation memory summaries used for contextual continuity, is stored locally on your device only. When you send a message, the conversation context is transmitted to our Cloud Functions solely for generating a response and is not persisted server-side.

3. How We Use Your Information

3.1 Core App Functionality

• Retirement Calculations: All retirement timeline calculations run locally on your device. Your financial inputs are not transmitted to our servers for this purpose.
• On-Device Data Storage: Your retirement plan inputs, calculation history, goals, budget data, and AI chat history are stored locally on your device only. This data is not uploaded to our servers or synced across devices.
• Service Improvement: We may use aggregated, anonymized operational data (such as AI service performance metrics) to monitor service health and improve the App.
• Backend Service Access: To authenticate your device anonymously, verify your subscription status, and enforce AI usage quotas.
• Feature Access: To enforce subscription entitlements and provide premium features to paying subscribers.

3.2 AI-Powered Features (Optional, Consent Required)

By default, no retirement planning data is shared with external AI services. If you choose to enable external AI in Settings, data is transmitted to generate responses. See Section 4 for full details.

3.3 AI Output Limitations

Freedom Clock includes optional AI-powered features that generate responses based on the information you provide and general knowledge models. These responses may contain inaccuracies, incomplete information, or outdated assumptions.

• AI-generated outputs are provided for informational and educational purposes only and should not be relied upon as the sole basis for financial decisions.
• You are solely responsible for evaluating any suggestions, projections, or insights generated by the App or its AI features before taking action.
• Use of the App does not create a financial advisor, fiduciary, or professional advisory relationship between you and Newron Robotics, LLC.
• Past projections or modeled outcomes are not guarantees of future financial results.

AI-generated content may not reflect the most current market conditions, tax laws, or jurisdiction-specific rules.

3.4 User-Provided Information

The accuracy of retirement projections, financial estimates, and other outputs generated by Freedom Clock depends on the accuracy and completeness of the information you provide.

• If the data entered into the App is inaccurate, incomplete, or outdated, the resulting outputs, insights, and projections may also be inaccurate.
• Newron Robotics, LLC does not independently verify the financial information entered by users and is not responsible for decisions made based on incorrect or incomplete data provided by the user.

3.5 Service Operations and Improvement

• Rate Limiting and Abuse Prevention: We track per-user request counts and device-level usage to enforce fair usage limits and prevent abuse of AI services, including circumvention of one-time free AI entitlements via app reinstall. Security-relevant events such as blocked quota claims and malformed device identifiers are logged for audit purposes; device identifiers in these logs are cryptographically hashed and cannot be reversed to the original value.
• AI Service Analytics: We collect per-call operational metrics (associated with your anonymous identifier) and anonymized, aggregated metrics about AI feature performance (latency, error rates, model usage, cost) to monitor service health and optimize costs. These analytics do not include the content of your messages or personal financial data.
• Error Monitoring: To identify and fix technical issues that affect your experience.

3.6 Communications

• Local Notifications: If you enable them, we deliver local device notifications for weekly check-ins, milestones, and market reports. These are processed entirely on your device — we do not use push notification servers or collect push tokens.

3.7 No Professional Advisory Relationship

The App and its features, including AI-powered features, are provided as informational tools only. The use of Freedom Clock does not create a financial advisor, investment advisor, fiduciary, tax advisor, legal advisor, or professional advisory relationship between you and Newron Robotics, LLC.

4. Data Sharing with External AI Services (Opt-In Only)

4.1 What Data Is Shared When AI Is Enabled

When you use the AI assistant, retire-faster suggestions, or other AI-powered features with external AI enabled, the following data may be transmitted to our Cloud Functions backend, which then forwards relevant portions to the AI provider:

• Your Question Text: The exact text of your question or request
• Demographics and Employment: Age and occupation; country, state/province, and city for current and planned retirement locations (never street address or GPS coordinates)
• Income and Savings: Annual income, estimated take-home pay, monthly spending, and savings rate; income growth rate and expected future income changes; monthly cashflow summary and deficit indicators
• Investment Accounts: Retirement account balances, Roth account balances, taxable investment account balances; monthly contribution amounts; employer match rate and cap percentage; stock/bond allocation and expected return percentages
• Housing: Housing status; monthly rent or mortgage payment, mortgage years remaining, home equity; whether home is sold at retirement
• Family and Dependents: Marriage status and dependent spouse monthly expenses; children count and ages (no names); pets count and types (no names)
• Debts: Types of debt, monthly payment amounts, outstanding balances, and remaining terms
• Rental Properties: Net monthly rental income (if applicable)
• Support Payments: Alimony or child support payment amounts and durations (if applicable)
• Life Events: Type, target age, estimated cost, and recurrence details of planned life events
• Stress Tests: Market crash, job loss, and medical shock scenario configurations
• Money Wins: Summary of financial wins including amounts and categories, active retire-faster goals, and estimated days saved
• Retirement Planning Parameters: Retirement spending percentage, target plan-until age, lifestyle category; Social Security claim age (US users only); bequest/legacy target amount
• Calculation Results: Estimated retirement age, confidence score, projected portfolio value, current net worth, estimated Social Security benefits, and life expectancy estimate
• Currency and Language: Your currency code and preferred language for AI responses
• Conversation Context: Recent messages in the current session and a locally stored conversation memory summary for conversational continuity. This context is sent per-request and not persisted server-side.
• Market Report Context (Premium Feature): Additional context including years to retirement and cost-of-living multipliers

4.2 What We Do NOT Share with AI Providers

• Email address, phone number, or physical address
• Device identifiers (IDFA, device ID, hardware identifiers)
• Precise location (street address or GPS coordinates)
• Apple ID, subscription details, or payment information
• Financial account numbers or Social Security numbers
• Browsing history or data from other apps

4.3 AI Service Providers

Important: These providers process your data under their own privacy policies and data retention practices. Once data is sent to an external provider at your direction, that provider processes it under its own policies, which are outside our direct control. We recommend reviewing their policies before enabling external AI: Groq Privacy Policy and Perplexity AI Privacy Policy.

4.4 Your Control Over AI Data Sharing

• Opt-In Required: You must explicitly consent via the in-app consent modal before any data is shared
• Easy Toggle: Enable or disable external AI at any time via Settings
• Immediate Effect: Disabling the toggle immediately stops all future data transmissions to AI providers
• Consent Date Recorded: The date you granted consent is recorded locally on your device so you can verify when you opted in

5. Data Storage and Security

5.1 Where Your Data Is Stored

5.2 Security Measures

• Authentication: All server-side data access requires Firebase Authentication.
• Authorization: Firestore security rules enforce that users can only read and modify their own data.
• API Security: All API communications use HTTPS/TLS encryption. API keys are stored in Firebase Cloud Secrets and never exposed to client devices.
• App Check & Device Attestation: All Cloud Functions are protected by Firebase App Check, which uses Apple's App Attest (iOS 14+) or DeviceCheck (older devices) to help verify that requests originate from a valid instance of the App and reduce automated abuse. No personal data is collected through this process — only cryptographic attestation tokens.
• Rate Limiting and Quota Enforcement: Per-user rate limits, monthly caps, and device-level quota checks prevent abuse and enforce fair usage.
• Device-Level Integrity: A Keychain-persisted device identifier is checked alongside user-based quotas to prevent circumvention of lifetime usage limits. This identifier is used only for security and abuse prevention.
• No Sale of Data: We do not sell, rent, or trade your personal information to third parties.

6. Server-Side Operational Data

Your retirement plan inputs, financial data, and AI chat history are not stored on our servers except as transiently needed to process optional AI requests and the limited operational records described below. For full transparency, the following describes every category of data we store on Firebase servers:

6.1 User Profile (users/{uid})

• Anonymous session creation date and last seen timestamp
• Premium subscription status and verification timestamp
• AI usage counter: messages used this billing period, period start date, last request time

6.2 Rate Limits, Usage Caps, and Device Quotas (Server-Only)

• Rate Limits: Per-user request counts within sliding time windows
• Monthly Feature Limits: Per-user monthly call counts by feature type
• Lifetime Feature Limits: Per-user lifetime usage counts for free-tier features (e.g., decision tests, retire-faster ideas)
• Device-Level Quotas: Per-device usage flags for one-time free AI entitlements, checked alongside user-based quotas to prevent circumvention via app reinstall. Stores only the device identifier, a feature flag, a timestamp, and associated anonymous user identifiers.
• Security Audit Logs: Structured security event entries (e.g., blocked quota claims, malformed device identifiers, quota refunds after provider failures) stored in Cloud Logging. These entries contain your user ID, a cryptographically hashed (non-reversible) device identifier, a feature name, and a timestamp. No financial data, message content, or raw device identifiers are included in these logs.

These collections store only your user ID or device identifier, a feature identifier, a count or flag, and a timestamp. No financial data, message content, or personal information is included.

6.3 AI Analytics (Server-Only)

• Per-Call Events: For each AI function call, we record: your anonymous user ID, feature name, AI provider and model used, response latency, success/failure status, error type (if any), token counts, estimated cost, whether a fallback model was needed, and non-identifying context (country, currency, language). These records are associated with your anonymous identifier for operational purposes such as quota enforcement and cost management. We do not intentionally store the content of your messages or the AI's responses in our databases.
• Aggregated Summaries: Rolled-up totals by feature and time period. These aggregates may contain pseudonymous user identifiers for deduplication purposes and are not individually purged upon data reset.
• Per-User Monthly Summaries: Your anonymous user ID, month, tier, total calls by feature, total estimated cost, and success/error counts.

7. Data Retention

8. Third-Party Services

We integrate with the following third-party services. Each operates under its own privacy policy:

8.1 Future Partner Integrations

As of the date of this Privacy Policy, Freedom Clock does not integrate with financial service providers, affiliate partners, advertising networks, or other commercial partners, and does not share personal financial data with any such parties.

If we introduce such integrations in the future, we will update this Privacy Policy before enabling them and provide any disclosures or consent mechanisms required by applicable law. We will never share sensitive financial details such as account balances, debts, or income with partners without your explicit consent.

8.2 Future Advertising and Analytics Providers

As of the date of this Privacy Policy, Freedom Clock does not integrate with any advertising networks, attribution services, or marketing platforms.

If we introduce such integrations in the future, we will update this Privacy Policy and provide any disclosures or consent mechanisms required by applicable law before enabling them.

9. Your Rights and Choices

9.1 All Users

• AI Data Sharing Control: Enable or disable external AI at any time in Settings. Default is OFF.
• Export Your Data: The “Export My Data” option in Settings (available in supported regions) allows you to download a copy of your local data in JSON format. All users may also request a data export by contacting us at support@newronrobotics.com.
• Delete AI Chat History: Tap the trash icon in the AI Assistant screen to clear your local conversation history and conversation memory. All AI data is stored on your device only.
• Reset Your Data: In Settings, tap “Reset Plan” to permanently erase all retirement plan data, goals, budget data, AI chat history, and AI conversation memory from your device. Your anonymous Firebase identifier, server-side usage counters, per-call AI analytics records, device-level quota records, and aggregated analytics summaries are retained for service integrity and abuse prevention (see Section 7). To request deletion of server-side data associated with your anonymous identifier, contact support@newronrobotics.com. Certain aggregated, de-identified, or otherwise non-user-attributable analytics records may not be individually purged (see Section 7). This action is irreversible.
• Manage Notifications: Control notification preferences in Settings.
• Manage Subscription: Cancel or modify your premium subscription through Apple ID Account Settings.
• Analytics: App usage analytics are currently used for local diagnostics only and are not transmitted off-device. AI service operational metrics are collected server-side as described in Section 6.3. If we enable broader analytics collection in the future, we will update this Policy and obtain your consent where required by law.

9.2 European Economic Area, UK, and Swiss Users (GDPR)

Under the General Data Protection Regulation, you have the following rights:

• Right of Access (Art. 15)
• Right to Rectification (Art. 16)
• Right to Erasure (Art. 17) — “right to be forgotten”
• Right to Restrict Processing (Art. 18)
• Right to Data Portability (Art. 20)
• Right to Object (Art. 21)
• Right to Withdraw Consent (Art. 7)
• Right to Lodge a Complaint with your local data protection supervisory authority

To exercise any of these rights, contact us at support@newronrobotics.com. We will respond within 30 days.

9.3 California Residents (CCPA/CPRA)

• Right to Know
• Right to Delete
• Right to Correct
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising.
• Right to Non-Discrimination
• Right to Limit Use of Sensitive Personal Information

To exercise your rights, email support@newronrobotics.com with the subject line “CCPA Request.” We will verify your identity and respond within 45 days.

9.4 Other U.S. State Privacy Rights

Residents of states with comprehensive consumer privacy laws — including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Tennessee (TIPA), Indiana (ICDPA), Iowa (ICDPA), Delaware (DPDPA), New Hampshire (NHPA), New Jersey (NJDPA), Kentucky (KCDPA), Maryland (MODPA), Minnesota (MCDPA), Nebraska (NDPA), and Rhode Island (RIDTPPA) — may have similar rights including access, deletion, correction, opt-out of sale/targeted advertising, and data portability. Contact us at the email below to exercise your rights.

10. International Data Transfers

Our servers and third-party service providers are located in the United States. If you are accessing Freedom Clock from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your jurisdiction.

For EEA/UK/Swiss users, we rely on Standard Contractual Clauses (SCCs) incorporated into Google's Firebase Data Processing and Security Terms to provide appropriate safeguards for international transfers. Where applicable, our third-party service providers may also rely on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and/or the Swiss-U.S. Data Privacy Framework as additional transfer mechanisms. You can learn more about the Data Privacy Framework at dataprivacyframework.gov.

11. Children's Privacy

Freedom Clock is not intended for children under 13 years of age (or under 16 in the EEA). We do not knowingly collect personal information from children under these ages. If you believe a child has provided us with personal information, please contact us at support@newronrobotics.com and we will promptly delete it.

12. Cookies and Tracking Technologies

Freedom Clock is a native iOS application and does not use cookies, web beacons, or pixel tags. We do not engage in cross-app tracking.

13. Data Breach Notification and Security Incident Response

13.1 Incident Assessment

We assess security incidents based on their severity and potential impact on user data, taking into account factors such as the type of data involved, the number of users potentially affected, and whether actual unauthorized access to personal data has been confirmed or remains a theoretical risk. This assessment informs the scope and urgency of our response.

13.2 Notification Obligations

In the event of a confirmed data breach that affects your personal information, we will:

• Notify affected users without undue delay, and within 72 hours of becoming aware of the breach for GDPR-covered users where the breach is likely to result in a risk to rights and freedoms
• Notify the relevant supervisory authority where required by applicable law (including state attorneys general as required by U.S. state breach notification laws)
• Provide information about the nature of the breach, the categories and approximate number of data records affected, the likely consequences, and the measures taken or proposed to address the breach
• Deliver notifications via in-app notice, email (if available), or other reasonable means based on the contact information we have on file
• Document all breaches internally, including facts, effects, and remedial actions taken, regardless of whether notification to users is required

13.3 Incident Response and Remediation

Upon discovery of a significant security incident, we will take steps we determine are reasonable and appropriate under the circumstances, which may include containment, investigation, remediation, revocation of compromised credentials, coordination with service providers, engagement of outside advisors, cooperation with law enforcement, and updates to safeguards, policies, or procedures.

13.4 Limitations of Security

While we implement reasonable and appropriate safeguards (as described in Section 5.2), no method of electronic transmission or storage is 100% secure. We cannot guarantee that our security measures will prevent every unauthorized access, use, or disclosure. Our security obligations are limited to implementing and maintaining reasonable and appropriate administrative, technical, and organizational safeguards appropriate to the nature of the data we process. We are not responsible for unauthorized access resulting from factors beyond our reasonable control, including but not limited to: compromised user device security, user credential sharing, vulnerabilities in third-party infrastructure, or sophisticated attacks that overcome reasonable security defenses.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we make material changes, we will:

• Update the “Last Updated” and “Effective Date” at the top of this page
• Notify you through the App or via email (if you have provided one)
• For material changes affecting data previously collected, we will seek your renewed consent where required by law

15. Data Controller

By using Freedom Clock, you acknowledge that you have read and understood this Privacy Policy.