GDPR · § 5 TMG · App Store Privacy
Privacy
1 · Who is responsible
Alessandro Emrich
Salzstrasse 58, 82110 Germering, Germany
Email: blau.ton@icloud.com
2 · Principle
We collect the minimum needed to operate the service and fix issues. Content, identity, and behavior inside the app stay with you.
3 · What we collect and why
3.1 · On your device and in your iCloud
Content and settings you create inside the app.
- Storage location: your device and your private CloudKit container (Apple iCloud).
- We have no access to this data. No one other than you has access. Apple provides the sync between your devices.
- In the app settings you can delete all local data at any time. CloudKit data you can manage yourself via iOS Settings → Apple ID → iCloud.
3.2 · Anonymous usage and diagnostic data (TelemetryDeck)
We use TelemetryDeck by TelemetryDeck GmbH (Hamburg, Germany) for aggregated, anonymous app analytics. Only the following is transmitted:
- App launch and usage sessions (time and frequency)
- Anonymized functional events (which areas of the app are used — categorized, no content)
- Whether purchases happen in the app (no price, no identity)
- On app crashes: anonymized crash report
What is NOT transmitted:
- Content you create inside the app
- Time spent on individual items
- Your identity, your IP address, your location, your Apple account
- No user ID — TelemetryDeck uses random, non-persistent device identifiers that cannot be linked back to you
Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in improving the service. Processing takes place in the EU.
You can disable this telemetry at any time: In the app settings you can switch the „Anonyme Nutzungsdaten" toggle off. From that moment on, no further data is transmitted.
3.3 · Subscription handling (Apple StoreKit)
When you start a Premium subscription, payment runs directly through your Apple account. We receive from the Apple system only a signal that you have Premium (a simple yes/no) — not who you are, not how much you paid, not your payment details.
Apple is responsible for subscription management. You can manage or cancel your subscription at any time via iOS Settings → Apple ID → Subscriptions.
4 · What we do not collect
- No content that you create inside the app is read, transmitted, or stored by us
- No IP address is persisted
- No IDFA, no advertising ID, no cross-app tracking
- No user ID, no Apple account identifier
- No location
- No contacts, no address book, no photo library
- No microphone recording
- No time-spent metrics per item
- No data for advertising
- No data sharing with third parties (other than the service providers listed in section 5, who process on our behalf)
5 · Third-party services used
- Apple iCloud — CloudKit sync of your content between your devices. Apple Privacy
- Apple App Store / StoreKit — subscription and purchase management. Apple Privacy
- TelemetryDeck GmbH — anonymous app analytics. TelemetryDeck Privacy
There are no additional third-party providers receiving data. No advertising services, no trackers, no CDN providers with user tracking.
6 · Data retention and deletion
- User data (content you create inside the app): on your device and in your iCloud. You can delete it at any time — app settings → Reset app data. Plus iCloud settings for the cloud copy.
- Telemetry data: automatically deleted by TelemetryDeck after 13 months (TelemetryDeck's standard retention period).
- Subscription data: with Apple, per Apple's retention policies.
7 · Your rights (GDPR)
- Access: What data do we have? — Due to the architecture above, no personal data resides with us. You may still send a request by email.
- Rectification: not applicable — no personal data with us.
- Erasure: app settings → Reset app data. Plus iCloud settings for the cloud copy.
- Objection to telemetry: app settings → „Anonyme Nutzungsdaten" toggle off.
- Data portability: not applicable — no personal data with us.
Contact for all requests: blau.ton@icloud.com
8 · Complaints to the supervisory authority
You may lodge a complaint with the competent supervisory authority at any time. For my location in Bavaria, this is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
Phone: +49 (0) 981 53-1300
Email: poststelle@lda.bayern.de
Web: lda.bayern.de
9 · Changes to this privacy policy
We update this policy occasionally. The current version is always available at this URL. Material changes are announced in the app via the „What's new" feature.