Privacy Policy for PhotoDelete

§ 1 Controller

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

Moritz Stieber / WebVital
Immenhofer Str. 30A
70180 Stuttgart
Germany
Email: webvitalsoftware@gmail.com

§ 2 Scope

This Privacy Policy applies to the iOS app PhotoDelete and to this privacy policy website. It explains which data is processed when you use the app and when you access this website.

§ 3 Scope of Data Processing in the App

PhotoDelete is an app for locally cleaning up your photo and video library. The app requires access to your photo library so that you can view, review, sort, keep, favorite, or select photos and videos for deletion.

The app processes in particular the following information locally on your device:

• previews and displays of your photos and videos
• creation dates and available media metadata
• file sizes, where available through Apple’s PhotoKit framework
• media types such as photo, video, screenshot, or Live Photo
• swipe decisions, such as keep or delete
• cleanup progress, for example by month or category
• app settings, such as sorting options or video sound status
• information related to free usage, such as swipe counters or cooldown times

This data is generally processed locally on your device. Your photos and videos are not transferred to servers operated by the developer.

§ 4 Legal Bases

The processing of your data is based on the following legal bases:

• Art. 6(1)(b) GDPR, where processing is necessary to provide the core functionality of the app.
• Art. 6(1)(a) GDPR, where you voluntarily grant an iOS permission, such as access to your photo library.
• Art. 6(1)(f) GDPR, where we have a legitimate interest in secure operation, support, and abuse prevention.

§ 5 Photo Access and iOS Permissions

Photo Access

PhotoDelete requests access to your photo library to display photos and videos, read metadata such as date and file size, and create local cleanup sessions.

Limited Photo Access

iOS allows you to grant PhotoDelete access only to selected photos and videos. In this case, PhotoDelete can only display and process the media you have shared with the app. You can change or revoke access at any time in the iOS system settings.

Deleting and Favoriting

If you choose to delete or favorite media, PhotoDelete uses Apple’s PhotoKit functions. Deletion actions are only triggered after your selection and confirmation. Deleted media is generally moved to the iOS “Recently Deleted” album and may be recoverable there for a limited time, depending on your iOS and iCloud settings.

§ 6 No Transfer of Your Photos and Videos to Us

PhotoDelete does not transfer your photos or videos to the developer and does not operate its own server for processing your media library. Media processing takes place on your device through Apple’s PhotoKit framework.

If you use iCloud Photos, Apple may process your photos and videos according to your iCloud settings. PhotoDelete has no independent access to this data beyond the photo permissions provided by iOS. Apple’s Privacy Policy applies in this respect: https://www.apple.com/legal/privacy/

§ 7 Local Storage

PhotoDelete may store app data locally on your device, such as cleanup sessions, swipe decisions, app settings, progress, cached data, and information related to free usage.

This data remains on your device until you change it through use of the app, delete app data, or uninstall the app. When the app is uninstalled, locally stored app data is generally removed.

§ 8 In-App Purchases and Subscriptions

PhotoDelete offers optional premium features through in-app purchases and auto-renewable subscriptions. Purchases and payments are processed through Apple’s App Store. The developer does not have access to complete payment data such as credit card numbers.

To manage purchase and subscription status, purchase restoration, and premium access, PhotoDelete uses RevenueCat, Inc., USA.

RevenueCat may process in particular the following technical and purchase-related information:

• pseudonymous app user ID or comparable identifier
• Apple receipt information and purchase history
• product identifiers and purchase status
• subscription status, renewal status, and expiration dates
• technical app and device information, where required for purchase management

This processing is used for purchase validation, fraud prevention, entitlement management, purchase restoration, customer support related to purchases, and purchase-related dashboard or analytics functions provided by RevenueCat.

Your photos and videos are not transferred to RevenueCat. Further information is available in RevenueCat’s Privacy Policy: https://www.revenuecat.com/privacy/

§ 9 Support and Contact

If you contact us by email, we process your email address, your message, and any additional information you voluntarily provide. Processing is carried out to handle your request. The legal basis is Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR.

Email service providers used for email delivery and mailbox hosting, in particular Google/Gmail when contacting our Gmail address, may process technical communication data and message contents according to their own privacy practices.

§ 10 App Ratings

PhotoDelete may display Apple’s native app rating prompt. If you submit a rating, it is processed directly by Apple. We do not receive access to non-public rating data.

§ 11 No Advertising, No Tracking, No General Usage Analytics

PhotoDelete currently contains no advertising SDKs, no tracking for advertising purposes, and no general third-party usage analytics for analyzing how you use photos, videos, or app features. No usage profiles are created for advertising. Based on the current implementation, an App Tracking Transparency prompt is therefore not required.

Purchase-related data may be processed through RevenueCat as described in § 8, including for purchase validation, entitlement management, fraud prevention, purchase restoration, and purchase-related dashboard or analytics functions.

If general analytics, crash reporting, advertising, or tracking services are added in the future, this Privacy Policy will be updated accordingly in advance.

§ 12 Third-Party Providers and Recipients

Personal data may be processed by the following providers where necessary:

• Apple Inc. and affiliated Apple companies for the App Store, in-app purchases, subscriptions, iOS system functions, and, where applicable, iCloud Photos
• RevenueCat, Inc. for purchase and subscription management
• GitHub, Inc. for hosting this privacy policy website
• email service providers, including Google/Gmail, where you contact us by email

Your photos and videos are not shared with or sold to third parties.

§ 13 International Data Transfers

In connection with the use of Apple, RevenueCat, GitHub, and email service providers, personal data may be processed in countries outside the European Union or the European Economic Area, in particular in the United States.

Where required, such transfers take place on the basis of appropriate safeguards within the meaning of Art. 44 et seq. GDPR, in particular adequacy decisions of the European Commission, the EU-US Data Privacy Framework, or standard contractual clauses.

§ 14 Hosting of This Website via GitHub Pages

This Privacy Policy is provided via GitHub Pages. When this website is accessed, GitHub as hosting provider processes technical access data, such as IP address, time of access, browser information, and requested file, in order to deliver and secure the website and enable its operation.

Further information is available in GitHub’s Privacy Statement: https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement

§ 15 Retention Period

Locally stored app data remains on your device until you change it, delete it, or uninstall the app.

Support requests are stored only for as long as necessary to process your request and comply with legal retention obligations.

Information about purchases and subscriptions is stored by Apple and RevenueCat according to their respective policies, where necessary for purchase processing, restoration, verification, fraud prevention, entitlement management, and legal documentation.

§ 16 Your Rights

Subject to the statutory requirements, you have the following rights:

• right of access under Art. 15 GDPR
• right to rectification under Art. 16 GDPR
• right to erasure under Art. 17 GDPR
• right to restriction of processing under Art. 18 GDPR
• right to data portability under Art. 20 GDPR
• right to object to certain processing under Art. 21 GDPR
• right to withdraw consent with effect for the future under Art. 7(3) GDPR

Because most app data is processed locally on your device, you can control or delete much of this data directly in the app, by changing iOS permissions, or by uninstalling the app.

To exercise your rights, you may contact us at any time at webvitalsoftware@gmail.com.

§ 17 Withdrawal of Permissions

You can change or revoke iOS permissions, in particular access to your photo library, at any time in the iOS system settings. The lawfulness of processing carried out before withdrawal remains unaffected.

§ 18 Automated Decision-Making

Automated decision-making, including profiling within the meaning of Art. 22 GDPR, does not take place.

§ 19 Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority may in particular be the authority of your place of residence or the authority responsible for the controller.

Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart
Germany
https://www.baden-wuerttemberg.datenschutz.de

§ 20 Changes to This Privacy Policy

We reserve the right to update this Privacy Policy if the app, integrated services, or legal requirements change. The current version is available at this URL.

Last updated: June 9, 2026

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