Privacy Policy

Eduard Bruch

Kleinfeld 28c, 21149 Hamburg, Germany

Email: support@eduardbruch.com

This website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. When you visit, technically necessary data is processed (IP address, date and time, requested URL, referrer, browser and operating system) to deliver the pages and keep the service secure. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is reliable and secure delivery of the website. Vercel acts as our processor under an agreement pursuant to Art. 28 GDPR. Server logs are kept only as long as needed for operation and security and are then deleted. Transfers to the USA rely on the European Commission's adequacy decision of 10 July 2023 (EU-US Data Privacy Framework, Art. 45 GDPR), under which Vercel is certified. More information: Vercel Privacy Policy.

This website sets no cookies, uses no analytics or audience measurement, and stores nothing on or reads nothing from your device. Apart from the hosting described in Section 2, we embed no advertising trackers, social media plugins or external fonts; fonts are served from our own server.

Links to the Apple App Store take you to Apple. Once you reach the App Store, Apple is the controller for any further processing.

If you e-mail us, we process your name, e-mail address and message to answer your request. Our mailbox is operated through an e-mail service provider. Legal basis is Art. 6(1)(b) GDPR where the request concerns a contract or an app, otherwise Art. 6(1)(f) GDPR (interest in answering). We delete the correspondence once the matter is closed, unless statutory retention duties apply.

No data protection officer has been appointed as there is no legal obligation to do so. You are not obliged to provide personal data. No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.

We do not operate any servers that receive, store, or process your data. All vault content — including photos, videos, documents, audio files, notes, and settings — is stored on your device; it leaves your device only as an encrypted backup that you start yourself (Section 6.9). We have no technical ability to access, view, retrieve, or recover any of your encrypted data. We cannot see what you store, how you use the App, or how often you open it.

The App does not use any analytics frameworks (no Firebase Analytics, no Crashlytics, no Mixpanel, no Amplitude, no Flurry, or similar). The App does not contain any advertising SDKs or ad networks. The App does not track your usage behavior, feature interactions, session duration, or any other telemetry. No usage data is collected, stored, or transmitted. We have zero visibility into how you use the App.

The App requests the following device permissions, each for a specific and limited purpose:

• Photo Library (Read): Import photos and videos from your gallery into the encrypted vault
• Photo Library (Write): Export decrypted items back to your gallery (user-initiated only)
• Camera: Capture intruder detection photos on failed unlock attempts (opt-in feature)
• Face ID / Touch ID: Optional biometric vault unlock. No biometric data is accessed by the App.
• File Access: Import files (PDFs, documents, audio, etc.) from the device file system via the system file picker

All permissions are requested at runtime and can be revoked at any time through your device's Settings app. The App functions with reduced capability if permissions are denied.

We do not sell, rent, lease, trade, or share your personal data with any third party. In the App, the only third-party services that receive any data are RevenueCat for subscription verification (Section 7.1) and, optionally, iCloud or Google Drive for encrypted backups you explicitly initiate (Section 7.2). No vault content is ever shared in unencrypted form. No biometric information is ever shared with anyone.

All data is stored on your device for as long as the App is installed. You can delete individual items, notes, albums, and intruder photos at any time from within the App. Uninstalling the App permanently deletes all locally stored data, including encrypted files and the encryption key. Once deleted, encrypted data cannot be recovered by anyone, unless you have created a backup in your own cloud account.

• Encryption algorithm: AES-256-CBC with PKCS7 padding
• Encryption key: 256-bit key generated using a cryptographically secure random number generator, stored in the iOS Keychain (KeychainAccessibility.first_unlock)
• Initialization vectors: Unique 16-byte IV randomly generated for each encryption operation and prepended to ciphertext
• PIN storage: Salted SHA-256 one-way hash with a unique random salt per PIN — not reversible
• Brute-force protection: Lockout after failed PIN attempts (30s at 5 attempts, 5min at 10, 30min at 15+)
• Recovery key: PBKDF2-HMAC-SHA256 with 100,000 iterations for master key wrapping
• Intruder photos: Encrypted with AES-256-CBC before being written to disk
• File naming: Encrypted files use randomized UUID filenames that reveal no information about the original file
• In-memory caching: Decrypted data is temporarily held in memory for display and cleared when the vault is locked

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation:

• Access (Art. 15) — request confirmation of what data we process. Because all App data is stored on your device only, we hold no personal data from the App about you on our systems.
• Rectification (Art. 16) — correct inaccurate data
• Erasure (Art. 17) — delete your data via the App's settings or by uninstalling the App
• Restriction of Processing (Art. 18) — restrict processing of your data
• Data Portability (Art. 20) — receive your data in a portable format
• Objection (Art. 21) — object to processing based on legitimate interest
• Withdraw Consent (Art. 7(3)) — withdraw consent at any time, for example by disabling intruder detection

To exercise any of these rights, contact us at support@eduardbruch.com.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• We do not sell your personal information.
• We do not share your personal information for cross-context behavioral advertising.
• We do not use sensitive personal information for purposes beyond what is necessary to provide the App.

California residents may contact support@eduardbruch.com to exercise their CCPA/CPRA rights.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. Our competent authority is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Str. 22, 7. OG, 20459 Hamburg
datenschutz-hamburg.de

The App is not directed at children under the age of 13 (as defined by COPPA) or under the age of 16 (as defined by GDPR). We do not knowingly collect personal information from children. If we become aware that a child has provided personal information, we will take steps to delete such information.

International data transfers occur through Vercel (USA) for hosting this website (Section 2), through RevenueCat (USA) for subscription verification and, if you opt in, through Apple (iCloud) or Google (Google Drive) for encrypted backups. These transfers are protected under the EU-U.S. Data Privacy Framework. All backup data transferred to cloud services remains AES-256 encrypted. All other App data remains on your device and is never transferred internationally.

We reserve the right to update this privacy policy. The current version can always be found on this page, with the date of the last update at the top.

For questions, concerns, or requests regarding this privacy policy or your data, contact:

Eduard Bruch

Kleinfeld 28c, 21149 Hamburg, Germany

Email: support@eduardbruch.com