Privacy policy – Kursvik
This policy explains how personal data is processed when you use the Kursvik mobile app (iOS and Android) and this website. We have written it based on what the app actually does.
1. Controller
Martinez Lozano Internasjonal Handel (ENK (enkeltpersonforetak), a Norwegian sole proprietorship owned by Willy Edison Martínez Lozano), org. no. 935 407 095 (VAT NO935407095MVA), Norbygata 19, 0187 Oslo, Norway. Email: kontakt@mlinternasjonal.no. We have not appointed a data protection officer; contact us at the address above.
2. Summary
- No account, no sign-in, no advertising, no analytics, no crash reporting and no tracking across apps or websites.
- The app does not store your analyses or any personal data on your device.
- The only data that leaves your device is the text you type into an analysis, sent to our AI service to produce your result.
- The app contains no purchases and processes no payment data.
3. What we process and why
3.1 Text you enter for an analysis (the app)
When you tap the analysis button and live AI is available, the app sends an encrypted (HTTPS) request to our AI processing service containing: the text you typed, the Kursvik course you used (investing or travel) (yield, travel) and fixed technical fields (app type, event name). The request contains no name, email, account, advertising or device identifier, location, contacts or files. As with any internet connection, the receiving servers see your IP address and basic connection data (for example the user agent).
Purpose: to generate the analysis you asked for. Legal basis: GDPR Art. 6(1)(b) (providing the service you request) and Art. 6(1)(f) (our legitimate interest in operating a secure service). If the AI service is unavailable, the analysis is produced on your device and nothing is sent.
Please do not enter personal data about yourself or others, or confidential business data, that you do not want processed. We do not use your text for advertising, profiling or to train AI models, and we do not sell it.
3.2 Contacting us
If you email us, we process your email address and the content of your message to answer you (Art. 6(1)(b) and (f)).
3.3 Purchases made directly from us
The app contains no purchases. If you buy a subscription directly from us (outside the app), we process your name, email address, billing country/address, the plan and payment status to deliver the service, send receipts and meet bookkeeping obligations (Art. 6(1)(b) and (c)). Card payments are handled by our payment provider (Stripe); we never see your full card number.
3.4 This website
This website is static: it sets no cookies and uses no analytics or third-party scripts or fonts. Our hosting/CDN provider processes your IP address and request data in server logs to deliver the pages and protect against abuse (Art. 6(1)(f)).
3.5 App stores
Downloads are handled by Apple (App Store) and Google (Google Play) under their own privacy policies. We may receive aggregated, anonymous statistics (for example number of downloads) from them.
4. Processors and recipients
We use these service providers (data processors) under data processing terms; they may only process data on our instructions:
- Make (Celonis group, Czech Republic, EU region) – receives the analysis request and runs our automation.
- AI model provider – currently Google (Gemini API) – generates the analysis text from your request.
- Cloudflare – website hosting and CDN.
- Stripe (Stripe Payments Europe Ltd., Ireland) – payment processing for purchases made directly from us.
- Our email service provider – to receive and answer emails.
We do not sell or share personal data with third parties for their own purposes. We may disclose data if required by law.
5. Transfers outside the EEA
Some providers (for example Google, Cloudflare and Stripe) may process data in the United States or other countries outside the EEA. Such transfers are based on the EU–U.S. Data Privacy Framework (where the provider is certified) and/or the European Commission's Standard Contractual Clauses (GDPR Art. 45–46).
6. Retention
- Analysis text: not stored by us in any database. It may remain for a limited period in the execution history of our automation provider and, for abuse monitoring, at the AI provider, after which it is deleted. Nothing is kept on your device.
- Emails: as long as needed to handle your request, and no longer than 12 months after it is closed, unless required for a legal claim.
- Purchase and accounting records: as required by the Norwegian Bookkeeping Act (generally 5 years).
- Website server logs: short-term, according to the hosting provider's standard retention.
7. Your rights
You have the right to access, rectify and erase your personal data, to restrict or object to processing, and to data portability (GDPR Art. 15–21). Email kontakt@mlinternasjonal.no. Because the app sends no identifier, we can usually only locate an analysis request if you tell us the approximate time and the text used. You also have the right to lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet, www.datatilsynet.no) or the supervisory authority where you live.
8. Automated decisions
The app produces indicative decision-support results. No decision with legal or similarly significant effect on you is made automatically (GDPR Art. 22).
9. Children
Kursvik is a personal investment-research and travel-planning tool intended for adults. It is not directed at children and we do not knowingly process children's data.
10. Security
All communication with our services is encrypted in transit (HTTPS/TLS). We limit access to data to what is necessary to run the service.
11. Changes
We will update this policy if the app or our processing changes and show the new date at the top. Significant changes will be announced on this website.