Privacy Policy

Fohl is a personal finance app published by Luewell (“Luewell,” “we,” “us”). Fohl is built to be private by design: your financial information stays on your device and in your own iCloud account. This policy explains what information Fohl handles, where it is stored, and the limited cases in which information leaves your device — always under your control.

1. Information you store in Fohl

Fohl lets you record the financial information you choose to enter, including accounts, balances, income and expense transactions, categories, currencies, recurring bills, and any files, photos, or receipts you attach to a transaction.

This information is stored locally on your device. If you are signed in to iCloud and have iCloud sync enabled, it is also stored in your own private iCloud database so it can sync across your Apple devices. This data is held under your Apple ID in Apple’s iCloud (CloudKit), and Luewell cannot read, access, or retrieve it.

Your use of iCloud is governed by Apple’s Privacy Policy.

2. The Fohl AI assistant

Fohl includes an optional AI assistant that can help you log transactions and answer questions about your money. You control how it works:

• On-device by default. Out of the box, the assistant uses Apple’s on-device model. Your requests and financial data are processed on your device and are not sent to Luewell or any third party.
• Optional cloud providers. You may instead choose a third-party AI provider — OpenAI, Anthropic, MiniMax, or any custom service you configure that is compatible with the OpenAI API. This is entirely optional and turned off until you enable it.

Before any data is sent to a cloud provider, Fohl requires you to give explicit consent and to provide your own API key for that provider. When you use a cloud provider, the content needed to answer your request is sent directly from your device to that provider over an encrypted (HTTPS) connection. Depending on your request, this may include the text of your message and relevant financial details (such as account names, balances, transactions, and categories), as well as any file, document, or image (for example a receipt or bank statement) you attach to the conversation.

Because you connect using your own account and API key, that data is handled by the provider you chose under their privacy policy and terms — not by Luewell. We do not receive a copy of these requests. Please review your chosen provider’s privacy policy:

• OpenAI Privacy Policy
• Anthropic Privacy Policy
• MiniMax Privacy Policy
• For a custom OpenAI-compatible endpoint, the applicable policy is that of the service you configure.

You can withdraw consent, switch back to the on-device assistant, or remove a stored API key at any time in Fohl’s Settings. API keys you enter are stored securely in the device Keychain and are never shared with Luewell.

3. Subscriptions and purchases

Fohl offers an optional paid subscription (Fohl Pro). Purchases are processed by Apple through the App Store; Luewell never receives your payment card or Apple ID. To manage subscription status and unlock Pro features across your devices, we use the subscription management service RevenueCat.

RevenueCat receives a randomly generated app user identifier and the purchase or receipt information needed to determine your entitlement. It does not receive your name or the financial data you store in Fohl, and this information is used only to operate and validate your subscription.

4. Notifications

If you enable reminders for recurring bills, Fohl schedules local notifications on your device. These are generated on-device and are not sent through any Luewell server.

5. What we don’t do

• We do not sell or rent your personal information.
• We do not show advertising.
• We do not use third-party analytics, tracking, or advertising SDKs.
• We do not track you across other apps or websites.

6. Data retention and deletion

You are in control of your data. You can edit or delete accounts, transactions, and other records directly in the app. Deleting the data in Fohl and/or removing it from iCloud removes it from your synced devices. Uninstalling the app removes the local copy from that device; data in your private iCloud can be managed from your device’s iCloud settings. You can also revoke any third-party AI provider access at any time by removing the API key in Settings and from that provider’s own dashboard.

7. Children’s privacy

Fohl is not directed to children and does not knowingly collect personal information from children. The app is intended for general audiences managing their own finances.

8. International transfers

If you choose to use a third-party AI provider, your requests are sent to that provider’s infrastructure, which may be located in countries other than your own. Those transfers are governed by the provider you selected. Apple iCloud storage is governed by Apple.

9. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Effective” date above. Significant changes will be reflected on this page.

10. Contact us

If you have any questions about this Privacy Policy or how Fohl handles your data, please contact us at support@luewell.com.