Privacy Policy
In preparation. The final legal information will be published before launch.
Effective date: 24.09.2026
This Privacy Policy provides information under Article 13 GDPR about the processing of personal data when using the iOS app “Shelf: Smart Photo Albums.”
In short
Shelf organises your photos into smart albums using metadata read locally on your device, such as keywords and ratings. Your photos and the photo metadata read from them never leave your device and are not transmitted to me or any third party.
Only your app settings and smart-album configurations are synchronised through your private iCloud database. RevenueCat is used to manage subscriptions.
1. Controller
Lennart Gastler
Am Seeacker 1, 74821 Mosbach
Germany
Email: privacy-shelf@lgastler.de
A data protection officer is not legally required and has not been appointed.
2. Photos and metadata
The app requires access to your photo library to display your images and locally read associated metadata, such as keywords and ratings. Based on the rules you define, the app uses this information to create smart albums.
This processing takes place exclusively on your device. Neither photos nor photo metadata read from them are uploaded, stored externally, or transmitted to me or any third party.
You can change or revoke photo-library access at any time in iOS Settings. Essential app functions may not be available without sufficient photo access.
3. Data processed
| Data category | Purpose | Legal basis | Retention |
|---|---|---|---|
| App settings and smart-album configurations, particularly the selection rules you define | Providing app functionality and synchronising settings between your devices through your private iCloud | Article 6(1)(b) GDPR | Until you delete the relevant data or in accordance with Apple's iCloud functionality |
| Pseudonymous app-user identifier, purchase receipts, product identifier, and subscription status | Purchasing, validating, and managing monthly and yearly auto-renewing subscriptions through RevenueCat | Article 6(1)(b) GDPR | According to RevenueCat's retention and deletion periods; statutory retention duties remain unaffected |
| Crash, diagnostic, and usage data where you have enabled sharing with Apple or use a TestFlight build | App stability, troubleshooting, and beta testing through Apple or TestFlight | Article 6(1)(f) GDPR; legitimate interest in providing a stable and secure app | Determined by Apple |
Payments and billing are handled by Apple through the App Store. I do not receive complete payment details such as credit-card or bank-account information.
The app does not use additional analytics or tracking services such as Firebase or Google Analytics.
4. iCloud and CloudKit
App settings and smart-album configurations are stored in your private iCloud database through Apple CloudKit. iCloud use is tied to your Apple ID. You do not need to register or create a separate account with me.
As a rule, I have no administrative access to the contents of your private CloudKit database. Apple's privacy terms additionally apply to processing through iCloud and CloudKit.
Configurations synchronised through CloudKit contain no photos and no metadata read from your photos. They contain only your app settings and the rules used to select images locally.
5. Subscriptions and RevenueCat
The app offers auto-renewing monthly and yearly subscriptions. The purchase contract and payment processing are handled by Apple. RevenueCat is used to check and manage subscription status technically.
For this purpose, RevenueCat processes information including a pseudonymous app-user identifier, product and subscription information, and purchase receipts supplied by Apple. This data is used to determine whether paid app functionality should be unlocked.
For further information, see RevenueCat's Privacy Policy: https://www.revenuecat.com/privacy/
6. Recipients and providers
Personal data may be transmitted, to the extent necessary, to the following recipients:
- Apple Inc. or Apple Distribution International Ltd.: app distribution, iCloud/CloudKit synchronisation, payment and subscription processing, and optional diagnostic and TestFlight data.
- RevenueCat, Inc.: technical subscription validation and management.
Where RevenueCat processes personal data on my behalf, this processing is governed by an agreement under Article 28 GDPR.
7. International transfers
RevenueCat, Inc. and some Apple group companies are based in the United States. Personal data may therefore be processed outside the European Union or European Economic Area.
Where required, such transfers are based on an adequacy decision—particularly the EU-US Data Privacy Framework where the recipient holds a valid certification—or appropriate safeguards under Article 46 GDPR, particularly the European Commission's Standard Contractual Clauses.
8. Your rights
Where the applicable legal requirements are met, you have the following rights in particular:
- Access to your personal data under Article 15 GDPR
- Rectification of inaccurate data under Article 16 GDPR
- Erasure under Article 17 GDPR
- Restriction of processing under Article 18 GDPR
- Data portability under Article 20 GDPR
- Objection to certain processing under Article 21 GDPR
Where processing is based on your consent, you may withdraw that consent at any time with effect for the future. Withdrawal does not affect the lawfulness of processing performed before the withdrawal.
To exercise your rights, contact privacy-shelf@lgastler.de. Where information is processed exclusively by Apple in your private iCloud or in connection with your Apple ID, a request may need to be directed to Apple.
9. Right to complain
Under Article 77 GDPR, you have the right to lodge a complaint with a data-protection supervisory authority. For a controller established in Baden-Württemberg, the competent authority is generally:
The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Heilbronner Straße 35
70191 Stuttgart, Germany
Email: poststelle@lfdi.bwl.de
Phone: +49 711 615541-0
Website: https://www.baden-wuerttemberg.datenschutz.de/
10. Automated decisions
No automated decision-making or profiling within the meaning of Article 22 GDPR takes place. Images are assigned to smart albums exclusively on your device using the metadata rules you define, and this has no legal or similarly significant effect.
11. Terms of use
Use of the app is governed by Apple's Standard End User License Agreement (Standard EULA):
https://www.apple.com/legal/internet-services/itunes/dev/stdeula/
12. Changes
This Privacy Policy will be updated if the app or the associated processing changes. The version published in the app or on this website applies.