Classical statistical theory has been developed under the assumption that the data belongs to a linear space. However, in many applications the intrinsic geometry of the data is more intricate. Neglecting this frequently yields suboptimal or outright unuseable results, i.e., taking the pixel-wise average of images typically results in noise. Incorporating the intrinsic geometry of a dataset into statistical analysis is a highly non-trivial task. In fact different underlying geometries necessitate different approaches, and allow for results of varying strength. Perhaps the most common non-linear geometries appearing in statistical applications are metric spaces of non-positive curvature, such as the manifold of symmetric, positive (semi-)definite matrices. In this paper we introduce a (strong) law of large numbers for independent, but not necessarily identically distributed random variables taking values in complete spaces of non-positive curvature. Using this law of large numbers, we justify a stochastic approximation scheme for the limit of Fr\'echet means on such spaces. Apart from rendering the problem of computing Fr\'echet means computationally more tractable, the structure of this scheme suggests, that averaging operations on Hadamard spaces are more stable than previous results would suggest.
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