Privacy Policy

1. Data Controller

The Data Controller is the individual who determines the purposes and means of processing your personal data within this application.

2. What We Do NOT Collect

All PDF processing happens exclusively on your device (on-device). Your files remain under your control at all times.

The Data Controller does not collect, transmit, or store on any server:

• The content of the PDF files you process
• The passwords you enter
• The signatures you draw, and the text or images you add to a PDF
• Any data relating to the documents you open or export

Data kept only on your device. Some features store data locally, inside the app, and never send it anywhere:

• Library (Premium) — copies of the PDFs you process, in the app's private folder
• Saved passwords (Premium, optional) — in the iOS Keychain, protected by Face ID or your device passcode
• Signatures — up to 3 drawn signatures, in the app's private folder
• Daily usage counters of the free version — in the iOS Keychain
• Temporary working files of the tools — deleted automatically after 24 hours

Device permissions (each is requested only when you use the related feature):

• Camera — to scan paper documents into a PDF; the images are processed on the device
• Photos — the app only receives the photos you pick in the system picker; permission to add to your library is requested only if you save images there
• Face ID — handled by iOS to unlock saved passwords; the app never receives biometric data
• Notifications (optional) — a reminder before the end of the free trial, scheduled locally on the device

3. Data Collected by Third Parties

A. Google AdMob (advertising — free version only)

The free version displays ads provided by Google LLC (2 Google Way, Mountain View, CA 94043, USA) via the Google Mobile Ads SDK. The SDK may collect:

Legal basis: consent (Art. 6(1)(a) GDPR) for IDFA; legitimate interest (Art. 6(1)(f) GDPR) for minimal technical data.
Transfer: Google LLC (USA) — covered by Standard Contractual Clauses.
More info: policies.google.com/privacy

You can withdraw ATT consent at any time: Settings → Privacy & Security → Tracking → Unlock my PDF.

B. Apple StoreKit (in-app purchases)

Purchases and subscriptions are managed by Apple Inc. The Developer only receives minimal transaction status data. Full payment details are handled by Apple: apple.com/legal/privacy

C. Google User Messaging Platform (ad consent — free version only)

Where required (for example in the EEA, the UK and Switzerland), the app uses Google's User Messaging Platform to ask for and store your advertising consent choices. You can change them at any time in Settings → Ad privacy options inside the app. More info: policies.google.com/privacy

D. Date check (free version only)

To apply the daily free limits, the free version reads the current date from the response header of a simple request to apple.com (or google.com as a fallback). The request contains no file content, no password and no identifier of yours; like any internet connection, it reveals your IP address to the server contacted.

E. TelemetryDeck (anonymous usage statistics)

To understand which features are used most and where to focus development, the app sends anonymous usage statistics to TelemetryDeck GmbH (Augsburg, Germany). For example: that a PDF was unlocked or protected, which tool was opened or completed, or that the subscription screen was shown. Each event carries technical data such as app version, iOS version, device model and language, and a device identifier that is hashed on the device before it is sent, so it cannot be traced back to you.

The statistics never include file names, file content, passwords, signatures or anything you add to a PDF, and they are not used for tracking or advertising.
Legal basis: legitimate interest in improving the app (Art. 6(1)(f) GDPR).
More info: telemetrydeck.com/privacy

4. Purposes and Legal Bases

• Providing the app service — performance of a contract (Art. 6(1)(b) GDPR)
• Advertising via AdMob — consent for personalization; legitimate interest for contextual ads
• In-app purchases — performance of a contract (Art. 6(1)(b) GDPR)
• Applying the daily free limits (date check) — legitimate interest (Art. 6(1)(f) GDPR)
• Anonymous usage statistics (TelemetryDeck) — legitimate interest in improving the app (Art. 6(1)(f) GDPR)

5. Data Retention

The Data Controller does not store personal data on its own servers. Data collected by Google AdMob is retained by Google according to its own policies. Data relating to Apple purchases is retained by Apple under its own terms. Anonymous usage statistics are kept by TelemetryDeck on behalf of the Data Controller and deleted when no longer needed to improve the app.

6. Recipients

• Google LLC — ad delivery (AdMob), ad consent (User Messaging Platform), date check fallback
• Apple Inc. — in-app purchase management, date check
• TelemetryDeck GmbH — anonymous usage statistics, as data processor
• Public authorities — where required by applicable law

The Data Controller does not sell or share your data for marketing purposes beyond the recipients listed above.

7. International Transfers

Both Google LLC and Apple Inc. are based in the United States. Transfers are carried out in compliance with Arts. 44–49 GDPR, through Standard Contractual Clauses approved by the European Commission. TelemetryDeck GmbH is based in the European Union.

8. Minors

This service is not directed to users under 16 years of age (the threshold applicable in Italy under Art. 2-quinquies of Legislative Decree 196/2003). The Data Controller does not knowingly collect data from minors under 16. If you believe a minor has provided us with personal data, please contact us at giulio.palumboschiavone@gmail.com.

9. Your Rights (GDPR)

Pursuant to Arts. 15–22 GDPR, you have the right to:

To exercise your rights: giulio.palumboschiavone@gmail.com

You also have the right to lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or the supervisory authority of your EU Member State.

10. Changes to This Policy

The Data Controller reserves the right to update this policy at any time. The revision date at the top of this page indicates the latest update. Continued use of the App after changes are published constitutes acceptance of the updated policy.

11. Contact

For any questions about this privacy policy or the exercise of your rights: