Legal & Privacy

Privacy Policy

As of: 1 July 2026 · Version: 1.1

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 on Your Device

• There are no servers operated by the provider. The app does not establish any network connection to the provider on its own initiative.
• There is no user account and no registration.
• There is no cloud sync; the data is not synchronized via iCloud or any other service (as of this version).
• No analytics, tracking, profiling or advertising technologies are used (no third-party SDKs). There is no automated decision-making. Accordingly, no App Tracking Transparency dialog appears either.
• The provider does not collect, store, receive or transmit any personal data about you — neither your name nor your IP address, device identifiers or usage data.

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).

3. Individual Processing Operations

• First name (optional): Used only to greet you personally within the app. Entering it is voluntary; the name remains exclusively local on the device and is not transmitted to the provider or third parties.
• Purchases (Facette Pro): In-app purchases and subscriptions are handled entirely by Apple (App Store / StoreKit). The provider receives no payment, billing or address data and no names of purchasers from Apple. The app merely checks the purchase status (entitlement) locally on the device. Apple is responsible for payment processing (Apple Distribution International Ltd. or the Apple entity responsible for you within the framework of the Apple Media Services). The Apple Privacy Policy (apple.com/legal/privacy) applies in this regard. The provider has no influence over this processing.
• Daily reminder (optional): If you enable it, the notification is scheduled purely locally on your device (Apple UserNotifications). There is no push server and no transmission to third parties.
• Operating system diagnostics: If you have enabled the sharing of crash and diagnostic data with Apple in your device's system settings, the operating system may send such data to Apple. This is a feature of Apple, not of the provider; the provider receives no personal data from it.

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). Since all data remains local on your device, no transfer to the provider or third parties takes place. 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. 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. Should a feature be introduced in the future that causes data to leave the device (e.g. optional iCloud sync), this policy will be updated accordingly in advance. The current version can be viewed in the app under Settings → Legal & Privacy.

10. Contact

For questions about data protection: privacy@facette.life