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Legal & Privacy

Privacy Policy

As of: July 12, 2026 · Version: 1.2

Note: This is a translation of the German original for your convenience. In case of doubt or conflict, the German version prevails.

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Andreas Putzinger
Katharina Pieslinger Weg 37, 4030 Linz, Austria
Email: privacy@facette.life

A data protection officer is not legally required and has not been appointed.

2. Principle: Your Data Stays With You

Facette is deliberately built to be "local-first". By default, all usage and game data — your training progress, your streak, your training points, unlocked games, your optional first name and your settings — are stored locally on your device (via Apple's UserDefaults). Only if you switch on the optional iCloud Sync (see Section 2a) is an additional copy placed in your own personal iCloud, so it can sync between your own devices. In both cases, the provider receives nothing.

Because in practice no processing of personal data takes place at the provider, the classic data protection obligations (record of processing activities, data subject rights vis-à-vis the provider, etc.) largely have no bearing. We nevertheless set out your rights in full (see Section 7).

2a. Optional iCloud Sync

Facette offers an optional iCloud Sync so your progress can move between your own Apple devices. It is off by default. You are asked once at first launch whether you would like to enable it, and you can turn it on or off at any time under Settings → "iCloud & Data" → "iCloud Sync".

When it is switched on, a copy of your progress data — your streak, your training points, your levels, your unlocked games, your optional first name and your settings — is stored in your own personal iCloud and synchronized only between the devices signed in to your Apple ID. This data resides in your private iCloud and is governed by the Apple Privacy Policy (apple.com/legal/privacy).

The provider never has access to this data, operates no server and never sees it. You can turn sync off at any time. A "Delete all data" button in the settings deletes everything on the device and in your iCloud and then disables sync.

The legal basis for this optional sync is your consent (Art. 6(1)(a) GDPR), which you can revoke at any time with effect for the future (by switching iCloud Sync off).

3. Individual Processing Operations

4. Legal Bases (GDPR)

Insofar as any processing takes place within the app at all, it serves solely to provide the functions you have requested (Art. 6(1)(b) GDPR) as well as the legitimate interest in a functioning, especially data-minimizing app (Art. 6(1)(f) GDPR). By default all data remains local on your device, so no transfer to the provider or third parties takes place. If you enable the optional iCloud Sync, a copy of your data is stored in your own iCloud on the basis of your consent (Art. 6(1)(a) GDPR); even then, no data is transmitted to the provider. No transfer to third countries is carried out by the provider.

5. Disclosure to Third Parties

None. The provider does not disclose any personal data to third parties and does not sell any data. The only point of contact with a third party is Apple in the context of purchase processing (see Section 3), over which the provider has no influence and for which Apple is independently responsible.

6. Retention Period & Deletion

The locally stored data remains on your device until you delete it or uninstall the app. Deleting the app removes all locally stored Facette data. If you have used iCloud Sync, a copy also remains in your own iCloud until you delete it — most easily via the "Delete all data" button in the settings (which removes the data both locally and in your iCloud) or via your device's iCloud settings. Deletion by the provider is neither possible nor necessary, as no data is held by the provider.

7. Your Rights

Under the GDPR, you are in principle entitled to the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21).

Since the provider stores or receives no data about you, it cannot fulfill these rights with respect to the data held locally on your device, nor does it need to — there is simply no data held by the provider. You exercise control over your local data directly yourself: viewing directly in the app, rectification by changing your entries, deletion by uninstalling the app.

For purchases, please contact Apple (Apple is the responsible entity for this).

Irrespective of this, you have a right to lodge a complaint with a data protection supervisory authority, in Austria with the Data Protection Authority (dsb.gv.at). If you have any questions, you can reach us at the email address stated above.

8. Children and Young People

Facette is aimed at a general audience and is also safe for children and young people, since the app does not collect or transmit any personal data whatsoever. No data of children is knowingly processed; in the absence of any data collection, this does not happen technically anyway. Purchases are subject to Apple's youth protection and Family Sharing settings.

9. Changes to This Policy

This policy may be adjusted if the app or the legal situation changes. Material changes — such as the optional iCloud Sync introduced in version 1.2 — are documented here. The current version can be viewed in the app under Settings → Legal & Privacy.

10. Contact

For questions about data protection: privacy@facette.life