App Privacy Policy

Effective date: 2025-09-01
Controller: Frederik Ott, Zürich, Switzerland
Contact: hello@besserrechtschreiben.com
App: Besser:Rechtschreiben (iOS)

1. Scope
   This Notice describes our processing of personal data under Swiss revFADP and, where applicable, the EU/EEA GDPR and UK GDPR.
2. Processing Overview
   a) App Content (CloudKit): User content is processed on-device and stored in the user’s private iCloud (CloudKit) database linked to their Apple ID. We neither host nor access this content.
   b) Purchases/Entitlements: On-device verification of in-app purchases/subscriptions (product identifier, entitlement status, renewal dates). We receive no payment card data and keep no server logs for entitlements.
   c) Support Communications: Contact details and message content you send us (e.g., email).
   d) Diagnostics: Aggregated or de-identified analytics and crash reports provided by Apple if the user enables sharing with developers in iOS settings.
   e) No third-party SDKs: The App includes no third-party analytics, advertising, or tracking SDKs.
3. Purposes
   Provide and operate the App; iCloud/CloudKit sync; entitlement management; support and incident handling; security and fraud prevention; legal compliance; product improvement.
4. Tracking and Advertising
   No advertising identifiers, cross-app tracking, or targeted advertising. We do not sell or share personal data for cross-context behavioral advertising.
5. Legal Bases (where GDPR/UK GDPR applies)
   Art. 6(1)(b) contract (App provision and entitlements); Art. 6(1)(f) legitimate interests (security, diagnostics, improvement); Art. 6(1)(a) consent (only for optional diagnostics or similar, where requested).
6. Recipients / Roles
   Apple operates iCloud/CloudKit and App Store billing under its own terms; your CloudKit content remains in your iCloud account. If used, our email/helpdesk providers process support communications as our processors under written terms.
7. International Transfers
   Apple processes iCloud/CloudKit data via its global infrastructure. If we use support/email providers outside Switzerland/EEA, transfers are protected by appropriate safeguards (e.g., Standard Contractual Clauses).
8. Retention
   CloudKit content: controlled by you; retained in your iCloud account until you delete it.
   Support communications: retained for 12 months after closure unless longer is required by law, then deleted or anonymized.
   Diagnostics from Apple: managed by Apple; we do not maintain user-level logs.
9. Your Choices
   Delete CloudKit content in the App under HomeScreen → Settings → Delete All Data. Deleting in the App removes the corresponding CloudKit records, this is irreversible. Manage iCloud and analytics sharing in iOS Settings. Cancel subscriptions in iOS Settings → your AppleId → Manage Subscriptions.
10. Your Rights
    You may request access, rectification, erasure, restriction, and objection; portability where applicable. For data we hold (e.g., support emails), contact hello@besserrechtschreiben.com.
    Switzerland: you may contact the FDPIC.
    EU/EEA: you may contact your local supervisory authority.
    UK: you may contact the ICO.
11. Automated Decisions
    We do not perform automated decision-making, including profiling, that produces legal or similarly significant effects.
12. Security
    We implement appropriate technical and organizational measures for data we handle directly (e.g., restricted access to support mailboxes). Apple is responsible for iCloud/CloudKit security.
13. US State Privacy (if applicable)
    We do not sell or share personal information as defined by applicable US state privacy laws. If this changes, we will provide required notices and opt-out mechanisms.
14. Changes
    We may update this Notice. The effective date will be revised, and material changes will be communicated in-App and/or on our website.
15. Contact
    Frederik Ott
    Zurich, Switzerland
    hello@besserrechtschreiben.com