Privacy Policy

1. Who We Are

The person responsible for the services covered by this Privacy Policy is:

Benji Mandel
Netherlands
Website: mandellabs.me
Email: contact@mandellabs.me

2. Data Stored by Our Apps

Our apps generally store their data locally on your device.

Some apps may use Apple iCloud to store or synchronise app data between your Apple devices. Apps using iCloud may also state this within the app.

We do not operate our own user-account system for this data.

Information stored or synchronised using iCloud is also processed by Apple in accordance with your Apple Account and iCloud settings and Apple's privacy practices.

Apple's Privacy Policy is available at: https://www.apple.com/legal/privacy/

3. Anonymous Analytics

We use TelemetryDeck for privacy-friendly analytics in our apps and on our website.

TelemetryDeck processes anonymised analytics data. According to TelemetryDeck, this data does not allow conclusions to be drawn about an identifiable individual.

Information may include:

• an anonymised, untraceable identifier for an app installation;
• actions or events defined by us, such as an app being launched or a feature being used;
• timestamps rounded to the nearest hour;
• device metadata, such as device type, operating-system version, app version and build number;
• whether an app build came from the App Store or TestFlight;
• browser information for website analytics; and
• other anonymous metadata that we choose to send about how an app or feature is being used.

TelemetryDeck does not store IP addresses.

For website analytics, part of an incoming IP address may be used to determine a possible country of origin, but the IP address itself is not stored.

TelemetryDeck does not use cookies or other tracking technologies for this analytics.

We do not use TelemetryDeck analytics to identify individual users or for advertising or cross-service tracking.

More information is available in TelemetryDeck's Privacy Policy: https://telemetrydeck.com/privacy/

4. Diagnostics

Some of our apps allow you to voluntarily send diagnostic information when requesting support or reporting a problem.

Diagnostics are only sent when you choose to send them.

Diagnostic information may include:

• device type;
• operating-system version;
• app version and build information;
• app settings or technical information;
• information relating to an error or problem; and
• other technical information useful for diagnosing the issue.

Where the app uses RevenueCat, a RevenueCat App User ID is always included in diagnostics that you choose to send.

The RevenueCat App User ID is a randomly generated anonymous identifier and does not by itself tell us who you are.

If diagnostics are sent together with an email or another form of communication that identifies you, we may be able to associate the diagnostic information and RevenueCat purchase information with that communication.

5. Purchases and Subscriptions

Some of our apps contain:

• one-time in-app purchases;
• subscriptions;
• both; or
• no paid features.

All in-app purchases and subscriptions are purchased and billed through Apple and the App Store.

We do not receive or store your payment-card details.

For apps containing purchases, we use RevenueCat to manage purchase status, subscriptions and access to purchased features.

Where we do not provide RevenueCat with our own user identifier, RevenueCat generates a random anonymous App User ID. We do not intentionally provide RevenueCat with your name or email address, and our apps do not use their own user-account system.

RevenueCat processes purchase history and related information needed to determine purchase and subscription status and provide purchased features.

Ordinarily, we cannot identify who a RevenueCat App User ID belongs to.

If you send us diagnostics, the RevenueCat App User ID is included automatically.

If you contact us about a purchase or support question without sending diagnostics, you may choose to provide your RevenueCat App User ID separately. This can help us locate the relevant purchase record.

If you provide your RevenueCat App User ID in an identifiable support request, such as an email, we may then be able to associate the relevant purchase information with you.

More information is available in RevenueCat's Privacy Policy: https://www.revenuecat.com/privacy

6. Contacting Us

If you contact us, we receive the information that you choose to provide.

This may include:

• your email address;
• your name, if provided;
• the contents of your message;
• attachments;
• diagnostic information; and
• purchase information or a RevenueCat App User ID where relevant.

Email sent to contact@mandellabs.me is routed through Cloudflare Email Routing and forwarded to a Gmail mailbox operated by Google.

Cloudflare and Google therefore process email information as part of delivering and storing these communications.

Cloudflare's Privacy Policy: https://www.cloudflare.com/privacypolicy/

Google's Privacy Policy: https://policies.google.com/privacy

We use support communications to respond to you, investigate problems, provide support and maintain records where reasonably necessary.

7. Cookies and Tracking

We do not use advertising cookies or cross-site advertising trackers on mandellabs.me.

TelemetryDeck is used for anonymous website analytics and does not use cookies for its analytics.

We do not use analytics information for targeted advertising.

8. How We Use Information

Where applicable, information described in this Privacy Policy may be used to:

• operate and maintain our apps and website;
• provide purchased features;
• determine purchase and subscription status;
• understand anonymous usage patterns;
• improve our apps and website;
• identify and fix bugs;
• investigate technical problems;
• provide customer support;
• prevent fraud or misuse; and
• comply with legal obligations.

We do not sell personal information.

We do not provide personal information to advertising networks or data brokers.

9. Third-Party Services

Depending on the app and features being used, information may be processed through:

• Apple, for the App Store, in-app purchases and iCloud;
• RevenueCat, for purchase and subscription management;
• TelemetryDeck, for anonymous analytics;
• Cloudflare, for email routing and website infrastructure; and
• Google, for receiving and storing support email through Gmail.

These providers process information in accordance with their respective terms and privacy practices.

10. Legal Basis for Processing

Where the GDPR applies and information constitutes personal data, we process it only where there is a lawful basis to do so.

Depending on the situation, this may include:

• providing a service or feature you requested;
• responding to a support request;
• our legitimate interests in operating, securing, supporting and improving our services;
• complying with legal obligations; or
• your consent, where applicable.

Where processing is based on consent, you may withdraw that consent.

11. International Processing

Some of the service providers we use may process information outside the Netherlands or the European Economic Area.

Where applicable, international transfers of personal data are handled using safeguards recognised under applicable data-protection law.

12. Data Retention

Data stored locally remains on your device until it is removed by you, by the app, or when the app and its data are deleted.

Information stored using iCloud is subject to Apple's and your own iCloud storage and deletion settings.

Anonymous TelemetryDeck analytics may be retained for analytics and product improvement. Because the information is anonymised, we cannot normally identify analytics records as belonging to a particular individual.

Purchase information is retained and processed by Apple and RevenueCat according to their applicable policies and as required to provide purchase and subscription functionality.

Support emails and voluntarily submitted diagnostics may be kept for as long as reasonably necessary to respond to the request, investigate problems, maintain useful support records, resolve disputes or comply with legal requirements.

13. Your Privacy Rights

Depending on the law that applies to you, you may have rights to access, correct, delete, restrict or object to certain processing of your personal data, and in some cases to receive a copy of your data.

Privacy requests can be sent to: contact@mandellabs.me

Because our apps do not use user accounts and much of the information we process is anonymous, we may have no way to identify particular information as belonging to you.

We will not attempt to identify an anonymous user solely in order to respond to a request concerning anonymous information.

You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority, or another competent data-protection authority.

14. Security

We take reasonable measures to protect the information we handle.

However, no device, software, internet connection or electronic storage system can be guaranteed to be completely secure.

15. Children

Our apps are not designed to knowingly collect directly identifying personal information from children.

If an individual app is specifically intended for children and requires different privacy practices, additional information will be provided for that app.

16. Changes to This Privacy Policy

We may update this Privacy Policy when our apps, website, third-party services or legal requirements change.

The current version will be published on mandellabs.me.

The date at the top shows when this Privacy Policy was last updated.

17. Contact

For questions about this Privacy Policy or our apps:

Benji Mandel
Netherlands
contact@mandellabs.me
mandellabs.me