Privacy Policy
DevelopFilm
Last updated: February 2025
This Privacy Policy explains how the DevelopFilm iOS app and this website handle your information.
Summary
- No account, no analytics, no ads.
- Journal data and photos stay on your device. They are not uploaded to our servers.
- Payments are processed by Apple. We don’t receive your card details.
- Contact-only data. If you email us, we use your email solely to reply and support you.
Data We Process
- App data (on-device only): journal entries, development settings, and photos are stored locally on your iPhone/iPad. We do not collect or receive this content.
- Purchase data: Apple (App Store / StoreKit) provides us with non-sensitive transaction status (e.g., active subscription). We do not receive full payment details.
- Support emails: if you contact us, we process your email and contents to respond.
Do You Share or Sell Data?
No. We don’t sell personal data. We don’t share it with advertisers or data brokers.
Legal Bases (GDPR/EEA/UK)
- Contract / Legitimate Interests: responding to support requests; validating purchases and providing subscription features.
- Legal Obligation: retaining purchase records we must keep for tax/accounting (from Apple’s settlement info).
Retention
- On-device journal data: remains until you delete the app or remove entries/photos within the app.
- Support emails: kept as long as reasonably necessary to resolve and document support matters.
- Purchase records: retained per statutory accounting/tax requirements.
Security
Because data is stored locally, your device’s own protections (passcode/Face ID/Touch ID, iOS sandboxing, backups) are key. We do not run any backend server for your content.
Children’s Privacy
DevelopFilm is not directed to children under 13 (or the minimum age in your country where parental consent is required). We do not knowingly collect data from children.
International Transfers
We are based in Germany. If you email us or purchase via Apple, your data may be processed in the EU and by Apple entities globally. Apple’s processing is covered by Apple’s own terms and policies.
Your Rights
EEA/UK/CH (GDPR): You can request access, correction, deletion (where applicable), portability, and object/restrict processing. To exercise rights about App Store data, you may also use your Apple privacy portal.
California (CPRA): We do not “sell” or “share” your data as defined by CPRA. You can request access/deletion for any support correspondence we hold.
To exercise rights related to information we hold (e.g., your support emails), contact us (see “Contact”). We will respond as required by law.
Payments & Subscriptions
- In-app purchases and subscriptions are handled by Apple. We do not receive your full payment card information.
- Apple may share limited transaction metadata (e.g., if a subscription is active) so the app can unlock features.
- Billing issues and refunds are administered by Apple per App Store terms.
Cookies/Tracking
We don’t use cookies or analytics on this site, and the app has no third-party trackers.
Links to Other Sites
Links we provide (e.g., Apple sites) are governed by their respective policies.
DSA (EU) Trader Information
Trader: Aleksandrs Bertulis
Address: Dehnhaide 153, 22081 Hamburg, Germany
Email: aleksandrs [dot] bertulis [at] gmail [dot] com
This contact is displayed for EU Digital Services Act compliance.
Controller
Data Controller: Aleksandrs Bertulis, Dehnhaide 153, 22081 Hamburg, Germany.
Changes to This Policy
We may update this Privacy Policy. We’ll revise the “Last updated” date and, if material, may notify users in-app or via the App Store listing.
Contact
Questions or rights requests:
- Email: aleksandrs [dot] bertulis [at] gmail [dot] com
- Postal: Aleksandrs Bertulis, Dehnhaide 153, 22081 Hamburg, Germany