Legal & Privacy
Privacy Policy
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.
- 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.
- By default there is no cross-device sync. Optionally, you can enable iCloud Sync — a copy is then stored solely in your own iCloud (Apple), never with the provider (see Section 2a).
- 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).
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
- First name (optional): Used only to greet you personally within the app. Entering it is voluntary; the name remains local on the device and is not transmitted to the provider or third parties.
- iCloud Sync (optional, off by default): See Section 2a. If you enable it, a copy of your progress data is stored in your own personal iCloud and synced between your own Apple devices; the provider has no access to it.
- 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). 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