Privacy Policy

1. Data controller

The data controller is Hieratek AB (org.nr 559580-3429).

Contact:
Postal address: Sätervägen 1A, 562 41 Taberg
Email: integritet@bokalk.se
Website: bokalk.se

2. What data is collected?

2.1 Account information

You can use BoKalk by signing in with your Google or Apple account, or by using the app anonymously (without creating an account). Anonymous accounts are automatically deleted after 90 days of inactivity. We do not request personal identity numbers or bank details as account information.

2.2 User-generated content

The app stores the properties and calculations you create, including details about price, fees, size, and household finances that you enter yourself.

2.3 Anonymous usage statistics and crash reporting

We collect anonymous usage statistics as well as crash and error reports (stack traces, breadcrumbs) via TelemetryDeck. No personal data is included. You can turn off statistics collection under Settings in the app. The legal basis for crash reporting is legitimate interest (GDPR Art. 6.1 f) — see section 4.2.

3. Purpose

Your data is used to:

• Provide the service — calculate housing costs, save your properties, and synchronize between devices.
• Manage subscriptions — administer your account and any payments.
• Improve the service — through anonymous, aggregated usage statistics.

We do not use your data for marketing, profiling, or automated decision-making.

4. Legal basis

4.1 Balancing test — third-party data in uploaded documents

Documents uploaded by users to BoKalk's AI services may contain names of individuals. Personal names are not scrubbed before transmission and pass transiently through Google Vertex AI within the EU during processing. The selected Gemini 3 models run in Google's EU multi-region; during transition or rollback, Gemini 2.5 may run in europe-west1 (Belgium). BoKalk's intended data schema contains no fields for personal names, and the model is instructed not to extract them. Because images and PDF documents are not pre-scrubbed and AI models can make mistakes, BoKalk cannot guarantee that a name never appears in a model response. Any such structured response is subject to the cache limit in section 5.2. The data is not used for AI model training.

Informing each affected individual would require disproportionate effort (Article 14.5 b GDPR), since we lack contact details, personal names are not intended result fields, and the information is very likely already public.

4.2 Balancing test — anonymous usage statistics and crash reporting

We use TelemetryDeck (TelemetryDeck GmbH, Germany) to collect aggregated, anonymous usage statistics — for example which features are used most and where users abandon a flow — as well as crash and error reports (stack traces and breadcrumbs) to identify and fix technical issues.

Our legitimate interest: Understanding how the app is used in order to improve functionality, identify and fix crashes and errors, and prioritize development.

Why the intrusion on the data subject's privacy is limited:

• No cookies or local tracking are used.
• No IP addresses are logged.
• No device IDs, advertising IDs, or personal data are collected.
• Users are identified by a double hash that neither we nor TelemetryDeck can link to an individual.
• All data is stored within the EU (Germany).
• Data is not shared with third parties for other purposes.

Opt-out: You can turn off anonymous statistics at any time under Settings > Data & Analytics in the app. The change takes effect immediately.

5. Storage and sub-processors

Your data is processed by the following sub-processors:

5.1 Transfers to third countries

Personal data is transferred to third countries (outside the EU/EEA) in the following cases:

• RevenueCat (USA) — subscription receipts are transferred with support from the EU Standard Contractual Clauses (SCC, module 2) pursuant to GDPR Art. 46.2 c.
• Google Cloud (Firebase & Vertex AI) — data is stored and processed in the EU (europe-north1, Finland and Vertex AI's EU multi-region; europe-west1, Belgium, may be used during transition or rollback), but Google's parent company is American and is also subject to US law. Transfers are protected by Google's Cloud Data Processing Addendum with SCC (Art. 46.2 c) and the EU-US Data Privacy Framework.
• WorkOS (USA) — sign-in data when you connect an AI assistant with BoKalk Premium is transferred with support from the EU Standard Contractual Clauses (SCC, module 2) pursuant to GDPR Art. 46.2 c. See section 5.4.

5.2 AI services

BoKalk uses Google Vertex AI to automatically extract data from documents users upload. Normal processing with the selected Gemini 3 models takes place in Google's EU multi-region. During transition or rollback, Gemini 2.5 may run in europe-west1 (Belgium). Google acts as a data processor pursuant to Google's Cloud Data Processing Addendum. AI processing is configured within the EU. Data sent to the API is not used for training AI models.

Personal identity numbers (personnummer) in text sent to the AI service are technically removed before transfer. Images and PDF documents are not pre-scrubbed and may therefore contain both personal identity numbers and personal names when sent to Google Vertex AI. The model is instructed not to extract personal identity numbers, personal names, or contact details. Defined patterns for personal identity numbers, email addresses, and phone numbers are automatically sanitised in the structured response. The fields shown to the user are validated separately.

Images and PDF documents are transmitted as part of the AI request and are not stored by BoKalk as original uploads. For up to 30 days, BoKalk may cache the structured model response after automatic identifier sanitisation together with the validated result fields. Vertex AI model caching and ordinary request-response logging are disabled for the project. Under Google's standard online terms, prompts flagged for suspected abuse may nevertheless be stored for up to 90 days in the selected EU region and reviewed by authorised Google personnel. Different retention rules may apply if the account is governed by a separate Google Cloud agreement or an approved abuse-monitoring exception.

5.3 Logging of AI calls

We log metadata about AI calls (timestamp, function name, success/failure) linked to your user ID for debugging and quota management. These logs are automatically deleted after 90 days. When an account is deleted, all logs are deleted immediately.

5.4 AI assistants you connect

You can connect an AI assistant of your own choice, for example Claude or ChatGPT, to BoKalk. There are two routes: a free one without an account, and one for BoKalk Premium where you sign in with your BoKalk account. How to connect is described on the page Connect your AI assistant.

Without an account. The assistant sends the data a calculation needs to BoKalk's server, for example price, fee, income, and savings. The server calculates and answers without saving the data. We log which tool was called, whether it succeeded, and how long it took — never the content of the call. To limit abuse, the server counts calls per sender address in memory for one minute. When you use an assistant, the sender is normally the assistant's provider.

With BoKalk Premium. Once you have signed in, the assistant can read data about your saved properties and your household, for example address, price, fee, size, loans, and monthly cost, calculate on it, and save new properties to your account. We process the data to let the assistant do this at your request. Legal basis: your consent (Art. 6.1 a GDPR), which you give when you connect the assistant. Data about other members of a shared household, for example their income, is not disclosed to the assistant.

Recipients. What the assistant reads is disclosed to the AI provider you have chosen. The provider is independently responsible for its processing under its own terms. We have no agreement with it and do not control how long the data is kept, where it is processed, or whether it is used to train AI models. Read the provider's terms.

Transfers outside the EU. The AI provider may process the data outside the EU, for example in the United States. The transfer relies on the European Commission's adequacy decision when the provider participates in the EU-US Data Privacy Framework, and otherwise on your explicit consent (Art. 49.1 a GDPR). Protection of personal data outside the EU may be weaker, and it may be harder to exercise your rights.

Sign-in. Sign-in goes through WorkOS, which is our data processor and processes the data in the United States. WorkOS receives your BoKalk user ID, your email address if it is verified, and your name if the account has one, and issues the keys the assistant uses. The transfer relies on the European Commission's Standard Contractual Clauses (SCC, module 2) pursuant to Art. 46.2 c GDPR. WorkOS receives no calculations, income, properties, or subscription data.

What we keep. We log which tool is called, when, and with what result, but not the content. To limit use, we count the number of calls per account and day. The log and the count are kept for 90 days. Properties the assistant saves are stored in your account like everything else you save, are marked in the app as saved by the AI assistant, and are deleted when you delete your account.

Your choices. The feature is optional. You remove the connection in the assistant's settings. If you want us to close all connections to your BoKalk account, or to delete the data held by WorkOS, write to kontakt@bokalk.se. This does not affect data already disclosed to the AI provider. If you end Premium, the assistant can no longer see or save your properties.

6. Retention periods

Upon account deletion, all personal data is deleted or anonymized within 30 days, except for data we are legally required to retain and for the three cases below.

• A shared household owned by someone else. Data that you have entered in such a household belongs to the household and remains with the owner. Your membership is removed. If you want the data removed, ask the owner to remove it, or contact us.
• Bug reports. The text of a bug report that you have sent remains, without a link to your account, until the issue is resolved.
• Anonymous statistics. Statistics already sent cannot be linked to your account and are not deleted when the account is deleted.

How to delete the account, or request deletion without the app, is described on the Delete account page.

A minimal tombstone record (deleted_users/{uid}, containing only user ID and deletion timestamp — no personal data) is retained indefinitely to ensure that data remains deleted even after a potential backup restore. Legal basis: legitimate interest (GDPR Art. 6.1 f) — protects the data subject's right to erasure.

Upon account deletion, your subscriber record at RevenueCat is also actively deleted via their API. Note that an active subscription is not canceled automatically when the account is deleted — the subscription is managed by Google Play or the App Store and must be canceled there to stop future charges.

6.1 Backups

Deleted data may remain in encrypted backups until the next backup cycle has completed. Backups are not used to restore deleted personal data. Backups are stored encrypted within the EU (Google multi-region storage) and are automatically deleted after 30 days. In the event of a restore from backup, data belonging to deleted accounts is automatically deleted again.

7. Sharing with third parties

We never sell your data. Data is only shared with the sub-processors in section 5 to the extent required to provide the service. We disclose data to authorities if we are legally required to do so.

If you invite a partner, you share a household profile and joint properties — your partner sees the same data as you.

If you connect an AI assistant with BoKalk Premium, the data the assistant reads is disclosed to the AI provider you have chosen, see section 5.4.

8. Security

We implement technical and organizational measures to protect your personal data against unauthorized access, loss, and misuse. Data is stored encrypted in Firebase/Google Cloud. Communication is encrypted via TLS. We continuously update our security measures as new technologies and risks emerge.

9. Push notifications

BoKalk can send push notifications about interest rate changes and updated reference values. Notifications are only sent if you have explicitly consented via the operating system's permission dialog (consent pursuant to GDPR Art. 6.1 a). You can turn off push notifications at any time in the app's settings or in your device's system settings.

10. Local storage on your device

The app stores certain data locally on your device (outside Firebase):

• Settings — your preferences (e.g. theme, statistics consent) are saved in the device's local storage (SharedPreferences/NSUserDefaults).
• Cache — global reference values are cached locally so the app works offline.

Locally stored data is automatically deleted if you uninstall the app. It is not synchronized with our servers.

11. App permissions

BoKalk requests a small number of permissions from the operating system. Each permission is used solely for the purpose described below and is requested only when the feature requiring it is used for the first time.

The app also receives shared images from other apps (e.g. screenshots of property listings) for AI import. This feature does not require a separate permission.

12. Automated decisions

BoKalk does not make automated decisions that have legal effects or similarly significant impact on you (GDPR Art. 22). KALP calculations (affordability assessment), pre-approval indicators, and interest rate suggestions are informational tools and do not replace the assessment of a bank or financial advisor.

13. Minors

BoKalk is intended for persons aged 18 or older. No active age gate is applied, but by using BoKalk you confirm that you are at least 18 years old.

14. Your rights

Under the GDPR, you have the following rights:

• Access (Art. 15) — know what data we process about you.
• Rectification (Art. 16) — correct inaccurate or incomplete data.
• Erasure (Art. 17) — request that we delete your account and associated data; the exceptions are listed in section 6.
• Restriction (Art. 18) — request that we restrict the processing of your data.
• Data portability (Art. 20) — export your calculations in a machine-readable format (JSON). An export function is available under Settings in the app.
• Objection (Art. 21) — object to processing based on legitimate interest. You can turn off anonymous statistics at any time under Settings > Data & Analytics.
• Withdraw consent (Art. 7.3) — for consent-based processing (e.g. push notifications), at any time without affecting the lawfulness of prior processing.

The app includes a function to export all your data. Contact us at integritet@bokalk.se to exercise these rights. We will respond to your request within 30 days.

You also have the right to lodge a complaint with the supervisory authority: Integritetsskyddsmyndigheten (IMY), Box 8114, 104 20 Stockholm, www.imy.se.

15. Cookies and tracking

The app does not use cookies.

16. Changes to this policy

We may update this privacy policy. For material changes, we will notify you in the app. The current version is always available on this page.

Questions? Contact us at integritet@bokalk.se.