LoopLeaf Privacy Policy

Updated October 9, 2026

Effective date: October 13, 2026

This Privacy Policy explains how personal data is processed on www.loopleaf.de, in version 1.4 of the LoopLeaf apps for iOS and Android, when you communicate with us, and on our Instagram profile, @loopleaf.app.

Sections 1 through 4 are based on the eRecht24 text included in our previous policy and have been adapted to reflect the contact options and features actually available on our website. The additional sections that follow explain data processing on the LoopLeaf website and in the apps in more detail. For information about the website’s actual features, please refer in particular to Section 6.

1 Privacy at a glance

Overview

The following information provides a brief overview of what happens to your personal data when you visit this website. Personal data is any information that can be used to identify you personally. For more detail, please read the full Privacy Policy below.

Data collection on this website

Who is responsible for collecting data on this website?

The website operator is responsible for processing data on this website. You can find the operator’s contact details under “Data controller” in this Privacy Policy.

How do we collect your data?

You provide personal data when you contact us, for example by email. We process your email address, the content of your inquiry, and any attachments you send.

Other data is collected by our IT systems automatically, or with your consent, when you visit the website. This is primarily technical information, such as your browser, operating system, or the time you access a page. This information is collected automatically when you visit the website.

How do we use your data?

Some data is collected to keep the website running properly. Other data may be used to analyze how visitors use the website. Our website does not offer a way to enter into contracts or provide forms for placing orders or commissioning services.

What rights do you have over your data?

You have the right, at any time and free of charge, to receive information about the source, recipients, and purposes of the personal data we store about you. You also have the right to request that this data be corrected or deleted. If you have consented to data processing, you may withdraw your consent at any time with effect for the future. In certain circumstances, you may also request that the processing of your personal data be restricted. You have the right to lodge a complaint with the competent supervisory authority.

You may contact us at any time about these rights or any other privacy questions.

2 Hosting

Our website content is hosted by the following provider:

External hosting

This website is hosted by an external provider. Personal data collected on the website is stored on the hosting provider’s servers. This may include IP addresses, contact inquiries, metadata and communications data, contract details, contact information, names, website access records, and other information generated through a website.

External hosting supports the performance of contracts with prospective and existing customers (Article 6(1)(b) of the General Data Protection Regulation, or GDPR) and our interest in having a professional provider deliver a secure, fast, and efficient online service (Article 6(1)(f) GDPR). Where we request the relevant consent, processing is based exclusively on Article 6(1)(a) GDPR and Section 25(1) of Germany’s Telecommunications Digital Services Data Protection Act (TDDDG), to the extent that consent covers storing cookies or accessing information on your device, such as through device fingerprinting, within the meaning of the TDDDG. You may withdraw your consent at any time.

Our hosting provider processes your data only as necessary to fulfill its service obligations and follows our instructions regarding that data.

We use the following hosting provider:

SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany.

3 General information and required disclosures

Data protection

We take the protection of your personal data seriously. We treat your personal data as confidential and process it in accordance with applicable data protection laws and this Privacy Policy.

Various types of personal data are collected when you use this website. Personal data is information that can be used to identify you personally. This Privacy Policy explains what data we collect, how we use it, and how and why it is processed.

Data transmitted over the internet, including by email, can be exposed to security risks. It is not possible to guarantee complete protection against access by third parties.

Data controller

The controller responsible for processing data on this website is:

Ryska Productions – Katharina Virginia Thielen

c/o Online-Impressum #7924

Europaring 90

53757 St. Augustin

Email: support@loopleaf.de

A controller is the individual or legal entity that determines, alone or jointly with others, the purposes and means of processing personal data, such as names or email addresses.

Retention periods

Unless this Privacy Policy sets out a specific retention period, we retain your personal data until it is no longer needed for the purpose for which it is processed. If you submit a valid request for deletion or withdraw your consent to processing, we delete your data unless we have another lawful reason to retain it, such as tax or commercial recordkeeping requirements. In that case, we delete the data once that reason no longer applies.

Legal bases for processing data on this website

If you have consented to processing, we process your personal data under Article 6(1)(a) GDPR or, where special categories of data under Article 9(1) GDPR are involved, Article 9(2)(a) GDPR. If you explicitly consent to the transfer of personal data to a third country, processing is also based on Article 49(1)(a) GDPR. If you consent to storing cookies or accessing information on your device, for example through device fingerprinting, Section 25(1) TDDDG also applies. You may withdraw your consent at any time. Where your data is needed to perform a contract or take steps before entering into a contract, we process it under Article 6(1)(b) GDPR. Where processing is necessary to comply with a legal obligation, Article 6(1)(c) GDPR applies. Processing may also be based on our legitimate interests under Article 6(1)(f) GDPR. The following sections identify the legal bases that apply to particular processing activities.

Recipients of personal data

We work with various external parties in the course of our activities. This sometimes requires sharing personal data with them. We share personal data only where necessary to perform a contract, where required by law, such as disclosure to tax authorities, where we have a legitimate interest in the disclosure under Article 6(1)(f) GDPR, or where another legal basis permits it. When we use processors, we share customers’ personal data only under a valid data processing agreement. Where data is processed under joint controllership, we enter into a joint controllership arrangement.

Withdrawing your consent

Many processing activities require your explicit consent. You may withdraw consent you have already given at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew it.

Right to object in specific circumstances and to direct marketing under Article 21 GDPR

IF YOUR DATA IS PROCESSED UNDER ARTICLE 6(1)(e) OR (f) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION. THIS ALSO APPLIES TO PROFILING BASED ON THOSE PROVISIONS. THE RELEVANT LEGAL BASIS IS SET OUT IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL STOP PROCESSING THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING IS NECESSARY TO ESTABLISH, EXERCISE, OR DEFEND LEGAL CLAIMS (ARTICLE 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO PROCESSING FOR THAT PURPOSE. THIS INCLUDES PROFILING TO THE EXTENT THAT IT IS RELATED TO DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING (ARTICLE 21(2) GDPR).

Right to lodge a complaint with a supervisory authority

If the GDPR is infringed, you have the right to lodge a complaint with a supervisory authority, particularly in the EU member state where you habitually reside or work, or where the alleged infringement occurred. This right is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to receive data that we process by automated means on the basis of your consent or a contract, or to have it provided to a third party, in a commonly used, machine-readable format. If you request direct transfer to another controller, we will do so where technically feasible.

Access correction and deletion

Subject to applicable law, you have the right, at any time and free of charge, to obtain information about the personal data we store about you, its source and recipients, and the purposes of processing. You may also have the right to have that data corrected or deleted. You may contact us at any time about these rights or other questions concerning personal data.

Right to restriction of processing

You have the right to request that the processing of your personal data be restricted. You may contact us at any time to make this request. This right applies in the following circumstances:

If you contest the accuracy of personal data we hold about you, we generally need time to check it. You have the right to request restricted processing while we verify its accuracy.

If processing is or was unlawful, you may request that processing be restricted instead of having the data deleted.

If we no longer need your personal data, but you need it to establish, exercise, or defend legal claims, you have the right to request restricted processing instead of deletion.

If you have objected under Article 21(1) GDPR, your interests must be weighed against ours. Until it has been established whose interests prevail, you have the right to request restricted processing.

Once processing has been restricted, your personal data may, apart from storage, be processed only with your consent, to establish, exercise, or defend legal claims, to protect the rights of another individual or legal entity, or for reasons of important public interest of the European Union or an EU member state.

SSL and TLS encryption

This website uses SSL or TLS encryption for security and to protect confidential content transmitted to us as the website operator, such as orders or inquiries. You can identify an encrypted connection by the change from “http://” to “https://” in your browser’s address bar and the padlock icon in the browser.

When SSL or TLS encryption is enabled, third parties cannot read the data you transmit to us.

Unsolicited marketing emails

We object to the use of contact details published to comply with legal notice requirements for sending advertising or informational materials that we have not expressly requested. We expressly reserve the right to take legal action against unsolicited advertising, including spam emails.

4 Data collection on this website

Server log files

The hosting provider automatically collects and stores information in server log files that your browser transmits automatically. This includes:

• Browser type and version
• Operating system
• Referrer URL
• Hostname of the computer accessing the website
• Time of the server request
• IP address

This data is not combined with other data sources.

This data is collected under Article 6(1)(f) GDPR. The website operator has a legitimate interest in ensuring that the website works properly and in optimizing it; collecting server log files is necessary for those purposes.

Inquiries by email phone or fax

If you contact us by email, phone, or fax, we store and process your inquiry, including any personal data it contains, such as your name and the details of your request, to handle your inquiry. We do not share this data without your consent. This is distinct from processing by our email service provider SpeedIT, which processes the data on our instructions as a processor, as described in Section 7. Statutory disclosure obligations remain unaffected.

Processing is based on Article 6(1)(b) GDPR if your inquiry relates to the performance of a contract or is necessary for steps before entering into a contract. In other cases, processing is based on our legitimate interest in handling inquiries effectively (Article 6(1)(f) GDPR) or on your consent (Article 6(1)(a) GDPR), where we have requested it. You may withdraw your consent at any time.

We retain the data you send in contact inquiries until you request its deletion, withdraw your consent to storage, or the purpose of storing it no longer applies, for example once your inquiry has been resolved. Mandatory legal requirements, particularly statutory retention periods, remain applicable.

Source for Sections 1 through 4: https://www.e-recht24.de

Additional information for LoopLeaf

5 Controller and contact information

The controller responsible for the processing activities we carry out as described in this policy is:

Katharina Virginia Thielen
Project name: Ryska Productions
c/o Online-Impressum #7924
Europaring 90
53757 Sankt Augustin
Germany

Email for privacy inquiries and support: support@loopleaf.de. You can also send privacy inquiries from other countries to this address, preferably by email. Other legally permitted contact methods remain available.

Ryska Productions is the project name used by the individual named above, not a separate company. In this policy, “we” and “us” refer to the individual responsible for LoopLeaf.

Privacy contact

As the provider of LoopLeaf, Katharina Virginia Thielen is also the contact person responsible for protecting personal information. She oversees compliance with the privacy obligations applicable to our processing and handles privacy inquiries and complaints.

Where Canadian privacy law applies, she also serves as the responsible privacy official (“Privacy Officer” or “person in charge of the protection of personal information” under Québec privacy law).

New Zealand: Privacy Officer

Where New Zealand’s Privacy Act 2020 applies, Katharina Virginia Thielen also fulfills the role of Privacy Officer. She works to ensure compliance with the applicable New Zealand privacy obligations, handles requests for access to and correction of personal information and privacy complaints, and serves as the point of contact for the Office of the Privacy Commissioner.

You can reach her at support@loopleaf.de, our preferred contact method, or through the other contact methods in this section. Your requests and complaints are handled in accordance with the procedures described in the section “New Zealand: access, correction, and complaints”.

You can reach her at support@loopleaf.de or at the postal address listed above. Email is also the preferred contact method for inquiries from other countries. Other legally permitted contact methods remain available.

6 Using the website

Hosting and technical access data

Our website is hosted by SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany. SpeedIT also provides the email service for support@loopleaf.de. According to the provider, hosting takes place in Germany. We have entered into a data processing agreement with SpeedIT.

Technical data is processed when you access the website to deliver pages and keep the service secure. This may include your IP address, the date and time, the requested URL, response status, data volume, browser and operating system information, and any referring URL sent by your browser. This data may be stored in the hosting service’s access and error logs.

The purposes are to deliver the website, detect and resolve technical problems, and prevent and investigate misuse. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is in operating our information service securely and reliably. We do not use this data for advertising or to create personal usage profiles.

According to our hosting provider, SpeedIT, IP addresses are initially stored in full in web server logs for technical analysis and to prevent attacks and misuse. Following automatic log rotation, IP addresses are generally anonymized after seven days. Depending on the rotation cycle, log files are retained for a total of four to eight weeks and then deleted.

Server side website statistics

SpeedIT regularly and automatically generates server-side website statistics for our site using AWStats and the server logs. The statistics are generated whether or not we access the reports. We do not currently view, analyze, or export these reports. We therefore do not conduct our own analysis of visitor behavior. If we wish to conduct such an analysis in the future, we will first review the applicable data protection requirements and update this Privacy Policy before beginning the analysis.

The analysis uses server logs only. It does not set cookies, add analytics scripts to our website, or use other browser-based methods.

The reports contain aggregate information about visits, page views and requests, data transferred, pages and files accessed, referring pages, any search terms transmitted, and HTTP status codes. Browsers, operating systems, and bots are also analyzed using the transmitted user-agent identifier. Figures are broken down by hour, day, and month. According to SpeedIT, AWStats does not record visitors’ IP addresses, and the reports do not contain IP addresses.

Aggregate monthly reports are retained for the duration of the hosting contract or for as long as the domain remains configured in the hosting account. According to SpeedIT, they are removed when the domain is deleted or the contract ends.

According to SpeedIT, the website statistics are generated and stored on the servers used for our hosting in Frankfurt am Main, Germany. According to SpeedIT, no additional external analytics service is used for this purpose. This is distinct from the subprocessors that SpeedIT uses for its hosting infrastructure.

Language and appearance

The website is available in German, English, Italian, Spanish for Spain, Brazilian Portuguese, and Polish. To select a language automatically, it reads the language settings provided by your browser locally. To select light or dark mode automatically, it checks the corresponding system setting. Our website scripts do not send this information to an analytics or personalization service. The URL of a language-specific page is visible to the web server as part of the page request.

If you explicitly choose a language, its language code is stored in your browser’s Local Storage under the key “loopleaf-lang”. If you explicitly choose light or dark mode, the corresponding setting is stored under the key “loopleaf-theme”. These entries do not contain an individual user identifier. They allow the website to remember your choices on subsequent visits.

The website does not set an expiration period for these values. They remain stored until replaced, removed by selecting “Automatic” or “System,” respectively, or deleted when you clear the website’s data in your browser. Closing the browser generally does not delete Local Storage entries. The website remains usable if browser storage is blocked, but your choices may not be saved for future visits.

These storage and access operations support the language or appearance feature you selected. Where they are strictly necessary to provide that feature, Section 25(2), point 2 TDDDG is the basis for access to your device. To the extent that personal data is processed, the legal basis is Article 6(1)(f) GDPR. Our interest is in providing a website that is understandable and reflects your selected settings.

Cookies and external resources

Our website does not use cookies for analytics, advertising, or tracking, or integrate services that track individual visitor behavior in the browser. We do not use Google Analytics. Our use of Google Search Console is described separately below. The website has no contact form, login, or user account. Images, font files, stylesheets, and website scripts are served from the website’s hosting service. No external fonts, maps, videos, or social media content are embedded.

“Do Not Track” and tracking across websites

Our website does not track your activities across different websites or online services. We do not integrate services that collect personal information for such cross-site tracking when you visit our website.

A “Do Not Track” signal sent by your browser does not trigger a separate change in how our website processes data. The technical server logs and server-side website statistics described in this policy are generated regardless of whether your browser sends this signal. The purposes of processing and retention periods described in this policy remain unchanged.

If you follow a link to Instagram or another external service, data processing there is governed by the privacy information provided by the respective provider.

Google Search Console

We use Google Search Console to manage our website’s visibility in Google Search and check its indexing and technical accessibility. The provider for the European region is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The service provides aggregate information such as impressions, clicks, search queries, and pages in Google Search, as well as technical information about the website. It does not use a tracking code embedded on our website to record how individual people use the site. Website ownership may be verified using a verification file or DNS record. We do not create individual visitor profiles from these reports or combine them with contact or app data. We view the reports only within Google Search Console. We do not download them or share them with other services.

Our purpose is to maintain the technical operation and discoverability of our information service. To the extent that our use involves personal data, the legal basis is Article 6(1)(f) GDPR. Our legitimate interest is in a functioning website that people can find. Google’s processing in connection with Google Search and Google accounts is governed by Google’s privacy information at https://policies.google.com/privacy?hl=en.

Processing in Germany for people in the United Kingdom

We are based in Germany. If you access our website from the United Kingdom or send us a contact or support request, we process the personal data involved in Germany and therefore outside the United Kingdom.

Our service provider, SpeedIT Solutions UG (haftungsbeschränkt), provides website hosting and email services and processes the data necessary for these services on our behalf. According to the provider, hosting takes place in Germany. We handle your requests ourselves in Germany. Details about the types of data, purposes, and retention periods are provided in Sections 6 and 7.

Germany is covered by the UK adequacy regulations. Where the UK GDPR rules on international transfers apply to the transfers to Germany described here, we rely on the recognition of an adequate level of data protection under Article 45 UK GDPR.

App content stored exclusively on your device is not automatically transmitted to us as part of our website or support operations. If you send us content or screenshots yourself, the support and deletion rules described in this policy apply. Apple, Google, and Meta process data separately, as described elsewhere in this policy.

Processing outside Canada

We are based in Germany. If you access our website from Canada or send us a contact or support inquiry, we process the personal information involved in Germany, outside Canada and Québec.

Our service provider, SpeedIT Solutions UG (haftungsbeschränkt), provides website hosting and email services. According to the provider, hosting takes place in Germany. SpeedIT processes the necessary information on our behalf to provide and secure the website and to transmit and store email correspondence. We handle your inquiries ourselves in Germany. Details of the types of information, purposes, and retention periods are provided in Sections 6 and 7.

When personal information is processed in Germany, it may be accessible to courts or competent authorities, particularly law enforcement and national security authorities, subject to the applicable legal requirements there. This does not mean that information is routinely disclosed to those bodies.

Content stored only on your device in the app is not automatically transferred to Germany as part of our website or support operations. If you send us such content yourself, the support and deletion procedures described in this policy apply. Apple, Google, and Meta process data separately, as described elsewhere in this policy.

Information about our use of service providers outside Canada is provided in this privacy policy. The responsible person named in Section 5 answers questions about this as our privacy contact, preferably via support@loopleaf.de. Other published contact methods remain available.

Processing outside Australia

We are based in Germany. If you access our website from Australia or send us a contact or support inquiry, we process the personal information involved in Germany, outside Australia.

Our service provider, SpeedIT Solutions UG (haftungsbeschränkt), provides website hosting and email services. According to the provider, hosting takes place in Germany. SpeedIT processes the necessary information on our behalf. We handle your inquiries ourselves in Germany. Details of the types of information, purposes, recipients, and retention periods are provided in Sections 6 and 7.

App content stored only on your device is not automatically transferred to Germany as part of our website or support operations. If you send us such content yourself, the support and deletion procedures described in this policy apply. Apple, Google, and Meta process data separately, as described elsewhere in this policy.

You can direct questions about this to the privacy contact named in Section 5, preferably by email at support@loopleaf.de.

7 Contact and correspondence

Email and other contact methods

When you contact us, we process the contact details you provide, the content of your inquiry, and any attached files to handle and respond to your request. Email also involves technical message data needed to send and receive messages. Our email service provider is SpeedIT. We handle messages ourselves and access the SpeedIT mailboxes through Apple Mail on our iPhone and MacBook. Messages are not automatically forwarded to other email addresses. The email applications may cache messages and attachments locally on these devices. The communications providers you use also process data needed to transmit your messages.

The legal basis is Article 6(1)(b) GDPR where processing is necessary to perform a contract with you or take steps before entering into a contract at your request. Other inquiries are handled under Article 6(1)(f) GDPR; our legitimate interest is in responding appropriately to your request. Retention required by law is based on Article 6(1)(c) GDPR.

We retain correspondence for as long as needed to handle your inquiry and any necessary follow-up questions. We then delete messages and attachments that are no longer needed from the mailbox and trash folder, including from the email applications used on our iPhone and MacBook. Statutory retention requirements or an ongoing need to preserve legal claims may prevent deletion. Deletion from our mailboxes does not mean that copies held by you or in the email provider’s technical backups are removed at the same time.

The applicable retention and deletion requirements also apply to technical backup copies. When the contract with our email service provider ends, the data processing agreement provides for the return of the processed data or, at our request, deletion of that data, including backup copies, unless statutory retention requirements prevent deletion.

Contacting us is voluntary. We may be unable to respond without a way to reply and the information needed to handle your request. Please send only what is necessary for your inquiry and avoid private notes or health information; a diagnosis is not needed to describe a technical problem. Before sending a support request, please redact or remove personal information that is not needed for your inquiry, particularly information about other people. If a screenshot you send contains personal information, after reviewing it we record only the information needed to address the technical issue in an anonymized problem description and then delete the screenshot from the storage locations we use. The problem description contains no names, contact details, or other information that could identify the person who reported the issue or any other person. We retain anonymized bug reports and records of their resolution to maintain and further develop the app. Personal support messages and attachments, however, are subject to the deletion procedures described above. We do not share personal support content or screenshots with AI services. Email is not automatically end-to-end encrypted.

Unsolicited information about other people may include names, contact details, or personal notes. The source of this information is the person who sends us the support request. We do not use this information to maintain contacts or assess the people shown. We review it only to the extent needed to identify and remove unnecessary content. For ordinary personal data, this is based on our legitimate interest in handling support requests while minimizing personal data under Article 6(1)(f) GDPR.

We inform the sender that the screenshot has been deleted and explain what anonymized technical information, if any, we have recorded. The corresponding provisions of this Privacy Policy apply to recipients, technical backup copies, and data subject rights. We separately assess any obligation to inform other affected individuals.

We review our support inbox at least once a week.

We do not request health information or diagnoses and do not need them to handle technical support requests. For accessibility inquiries, please describe the desired feature or the specific difficulty you experience when using the app without providing information about medical conditions or diagnoses.

If health information is nevertheless sent to us, we remove it from the messages and attachments we handle without undue delay after reviewing them. If the information cannot be removed separately, we delete the message or attachment after recording the necessary technical information without any health details. Where necessary, we ask for a new description without health information.

For further handling of the request, we retain only the necessary technical information and the contact and correspondence details needed. We do not include health information in bug reports or product planning. We do not repeat this information in our response.

The deletion procedures described above apply to deletion from the mailbox, trash folder, and local email copies. This does not mean that the information is removed from all technical backups at the same time.

United Kingdom: unsolicited health information

Where UK data protection law applies to our processing, we do not treat the unsolicited submission of health information as explicit consent to its further use. Legitimate interests or necessity for the performance of a contract alone do not permit the processing of health information; the requirements of Article 9 UK GDPR must also be met.

We do not need health information to handle technical support requests. We do not use unsolicited diagnoses or other health information to resolve the inquiry. The procedures described above apply to removal after review and to further handling based on the necessary information without any health details. For such information sent through Instagram, the deletion procedures and technical limitations in Section 10 apply.

Japan: unsolicited health information

Where Japan’s Act on the Protection of Personal Information (APPI) applies, diagnoses, medical history, and certain other health information may qualify as personal information requiring special care. In principle, collecting this information requires valid consent or a statutory exception.

Voluntarily providing your own health information directly to us may, subject to the statutory requirements, constitute consent to its collection. However, we do not treat this as blanket consent to further use or disclosure. Special requirements concerning minors remain unaffected.

We do not request health information and do not need it to handle technical support requests. For accessibility inquiries, describing the desired feature or the specific problem using the app without a diagnosis is sufficient. If health information is nevertheless sent to us, we do not use it to resolve the inquiry, for bug reports, or for product planning. After reviewing the information, we remove it without undue delay in accordance with the deletion procedures described above and handle the request using the necessary information without health-related content.

This also applies to health information about other people; its submission by a person making an inquiry does not automatically constitute those other people’s consent. For information submitted through Instagram, the deletion options and technical limitations described in Section 10 also apply.

South Korea: unsolicited health information

Where South Korea’s Personal Information Protection Act (PIPA) applies to our processing, health information is classified as particularly protected sensitive information. Its processing is subject to the additional requirements of Article 23 PIPA. The general legal bases for contact and support inquiries are not sufficient on their own. We do not treat the unsolicited submission of such information as separate consent to its further use.

We do not request health information or diagnoses and do not need them to handle technical support inquiries. For accessibility inquiries, a description of the desired feature or the specific usability problem without a diagnosis is sufficient.

If we nevertheless receive health information, we do not use it to resolve the inquiry, for bug reports, or for product planning. After reviewing it, we remove it without delay in accordance with the deletion procedures described above. If the information cannot be removed separately, we delete the message or attachment after recording the necessary technical information without any health details. Where necessary, we ask for a new description without health information. We do not repeat this information in our response.

This also applies to health information about other people; its submission does not replace any required consent from those people. For children under 14, the requirements described above concerning consent from their legal representative also apply where consent is required. For information submitted through Instagram, the deletion options and technical limitations described in Section 10 also apply.

Australia: unsolicited health information

Where the Australian Privacy Principles apply to our processing, we assess within a reasonable period after receiving unsolicited health information whether we could lawfully have collected it. We do not need such information to handle technical support requests; the deletion procedures described above apply. We do not treat voluntarily sending us health information as blanket consent to its further use.

If a statutory retention requirement or a binding order from a public authority or court prevents deletion, we limit retention and use to what is necessary for that purpose. Once the reason for retention no longer applies, we delete the information concerned.

Information about the processing of contact and support information outside Canada is provided in Section 6 under “Processing outside Canada.”

Consent where Canadian privacy law applies

Where Canadian privacy law applies to our processing, we comply with its requirements for valid consent and its statutory exceptions. Any required consent must be voluntary and informed and relate to specific purposes explained in understandable terms.

If you voluntarily provide your own nonsensitive contact details and the necessary information for an ordinary contact or support inquiry, this may, subject to the applicable legal requirements, constitute implied consent to the handling of and response to your inquiry as described in this policy. This does not constitute consent to advertising, other purposes, or the use of unsolicited health information. The deletion procedures described above apply to such information. Special requirements for consent by minors remain unaffected.

Where express consent is required, we obtain it separately before the relevant processing begins. Simply visiting our website or using the app does not constitute blanket consent to all processing activities.

You may withdraw consent for future processing by contacting support@loopleaf.de or using the other published contact methods. We explain the consequences for your inquiry; in particular, we may be unable to continue handling it without the necessary information. Processing based on that consent will cease in accordance with applicable law. Where legally permitted restrictions, reasonable time periods for implementing the withdrawal, or continued processing without consent apply, we explain these to you.

New Zealand: unsolicited personal information

Please send us only the information necessary for contact and support inquiries. Health information, diagnoses, and unnecessary personal information about other people are not needed to handle technical matters. For accessibility inquiries, a description of the desired feature or specific usability problem without a diagnosis is sufficient.

Where New Zealand’s Privacy Act 2020 applies, we distinguish between information that we request or deliberately collect and information that is genuinely unsolicited. We also comply with the applicable requirements concerning security, use, retention, access, and correction when handling unsolicited information.

We remove unsolicited health information and other personal information unnecessary for the inquiry after reviewing it, in accordance with the support and deletion procedures described above. If it cannot be removed separately, we delete the message or attachment after recording the necessary technical information without those details. Where necessary, we ask for a new description without the unnecessary information.

We do not use health information to resolve technical issues or include it in bug reports or product planning. We do not repeat this information in our reply. For messages sent through Instagram, the deletion options and technical limitations described in Section 10 also apply.

New Zealand: information about other people

Please do not send us personal information about other people that is unnecessary for your inquiry. In particular, remove or redact names, contact details, and personal content in screenshots before sending them to us. For technical support inquiries, a description of the problem without such details is normally sufficient.

Where New Zealand’s Privacy Act 2020 applies, when collecting personal information about other people, we assess whether the collection is necessary and whether the statutory requirements for collection from a source other than the individual concerned are met. We handle genuinely unsolicited information in accordance with the support and deletion procedures described above.

If we collect personal information indirectly and a notification obligation applies, we take reasonable steps to ensure that the individual concerned is informed of the collection as soon as reasonably practicable in the circumstances. This includes the information collected, the purpose, the intended recipients, the name and address of the agency collecting and holding the information, and the rights of access and correction. If the collection is authorized or required by law, we also identify the relevant statutory provision.

No further notification is required if the individual concerned has already been made aware of all the required matters. We assess any other statutory exceptions in light of the particular circumstances. These notices do not cause any additional app content stored only on your device to be sent to us.

Postal correspondence

We use an address service for the postal address published in our Legal Notice. Our use of this address service does not cause data to be sent to it when you simply visit our website or use our apps. If you contact us by mail, information on the envelope or package and in the correspondence itself may be processed to receive and forward it.

The legal basis is Article 6(1)(f) GDPR: our legitimate interest in having an accessible provider address that meets legal requirements. The purposes, legal bases, and retention criteria described above apply to our subsequent handling of correspondence. Processing for which the postal or address service is independently responsible is governed by that service’s privacy information.

8 Data processing in the apps

Children under 13

LoopLeaf is intended for teenagers aged 13 and older and adults and is not specifically directed to children under 13. App content stored on the device is not transmitted to us.

Please do not send us personal information about children under 13 through our contact and support channels unless it is necessary for your inquiry. Parents and legal guardians can contact support@loopleaf.de with questions about the processing of their child’s personal information.

If we learn that a child under 13 has personally submitted personal information to us, we review the processing in question and remove the information without undue delay unless there is a legally permitted basis for continuing to process it.

United Kingdom: privacy for minors

Where UK data protection law applies to our processing, we take minors’ particular need for protection into account when handling their personal data. When processing is based on legitimate interests, we specifically weigh their interests, rights, and freedoms and limit processing to the data necessary for the relevant purpose.

The age designation “13 and older” is not blanket consent to the processing of personal data. Where we offer an online service directly to children and rely on consent under Article 8 UK GDPR for a processing activity, persons aged 13 and older may give that consent themselves, subject to the statutory requirements. For children under 13, consent from a person with parental responsibility is required in this case; we take reasonable steps to verify that person’s parental responsibility.

For ordinary contact and support requests, we assess the appropriate lawful basis in each case. Parental consent is not required solely because the person making the request is a minor. The special requirements for health information and other special category data remain unaffected.

Please send only the technical information and contact details necessary for support requests. Personal app content or diagnoses are generally not needed to describe a problem using the app. Minors may also send privacy questions to support@loopleaf.de; we explain our response in clear, age-appropriate language.

Special rule for minors in Québec

Where Québec privacy law applies, we comply with its special consent rules for minors. Any required consent for a person under 14 must be given by a person having parental authority or a legal guardian. From the age of 14, the minor may also give consent themselves.

For contact or support inquiries from persons under 14 in Québec, we ask that a person having parental authority handle the inquiry. Please provide only the information necessary to process the inquiry and do not send personal app content or health information.

If we become aware that a person under 14 in Québec has personally submitted personal information to us, we assess whether continued processing is legally permitted. Where there is no legally permitted basis, we remove the information without undue delay.

Australia: consent by minors

Where Australian privacy law applies to our processing and consent is required for the processing in question, we consider whether a minor understands the nature, purpose, and significant consequences of the processing and can give valid consent themselves. What matters is the specific processing activity and the person’s ability to understand it; age alone does not determine whether they can give valid consent.

If a minor cannot give the required consent themselves, we obtain it from a person with parental responsibility or another legal representative authorized to give that consent before carrying out the processing that requires consent. Without valid consent, we do not carry out that processing unless another lawful basis permits it.

Simply sending an inquiry or reading this Privacy Policy is not treated as blanket consent to all processing of personal information.

Japan: privacy for minors

Where Japan’s Act on the Protection of Personal Information (APPI) applies to our processing, we take minors’ age, stage of development, and particular need for protection into account when handling their personal information. We limit processing to the information necessary for the specific purpose and explain privacy matters in clear, age-appropriate language.

The target audience designation “13 and older” does not constitute blanket consent to the processing of personal information. If consent is required for a specific processing activity and the minor cannot yet sufficiently understand its essential consequences, consent from a person with parental responsibility or another authorized legal representative is required.

Locally stored app content is not automatically transmitted to us. If minors voluntarily submit personal information in a contact or support request, for example in a screenshot, the described support and deletion procedures and any applicable special protection requirements apply to that information.

Once the special provisions for persons under 16 introduced by Japan’s 2026 privacy reform enter into force, we will also comply with the legally required involvement of legal representatives in consent and privacy information, as well as the expanded rights to request cessation of use, deletion, or cessation of disclosure. The statutory requirements and exceptions apply. When processing the information, we give priority to the minor’s best interests.

Minors and their legal representatives may send privacy questions and requests about the relevant information to support@loopleaf.de, our preferred contact address. We verify identity and any necessary authority to act as a representative only to the extent required.

South Korea: privacy of children under 14

Where South Korea’s Personal Information Protection Act (PIPA) applies to our processing, we take into account the particular vulnerability of children under 14 when processing their personal data. We provide privacy information and answers to their questions in clear, age-appropriate language.

Where consent under PIPA is required for a specific processing activity, we require consent from the legal representative of a child under 14 and verify that consent in accordance with the statutory requirements. A message sent by the child does not replace this consent. Other lawful grounds for processing remain available subject to their specific conditions.

For contact or support requests involving personal data from children under 14, we recommend that a legal representative make or assist with the request. Please provide only the necessary technical information and contact details. Private app content, diagnoses, or other health information are generally not required to describe a usability problem.

If we become aware that a child under 14 has sent us personal data directly, we assess whether further processing is lawful. Any further use that requires consent takes place only after the required consent of the legal representative has been obtained and verified. If there is no lawful basis for further retention or use, we delete the data concerned without undue delay in accordance with the statutory requirements. The safeguards and deletion procedures described for unsolicited health information also apply.

App content stored exclusively on your device is not automatically transmitted to us. If such content is voluntarily sent to us, for example as a support screenshot, this is distinct from exclusively local use. The consent rules described here do not in themselves establish a general restriction of app use to people aged 14 or older.

New Zealand: privacy for minors

Where New Zealand’s Privacy Act 2020 applies to our processing, we take children’s and young people’s age, understanding, and particular need for protection into account when handling their personal information. We limit the information we request to what is necessary for the relevant purpose and explain the processing and respond to privacy questions in clear, age-appropriate language.

Where consent or authorization is required for a particular processing activity, we assess whether the minor sufficiently understands its meaning and consequences and can make a valid decision themselves. If not, we involve a legal representative authorized to act in that capacity. Simply using the app or sending a message is not treated as blanket consent to further processing.

Children and young people may exercise their privacy rights themselves where they are able to do so. For requests from parents or other representatives, we verify their authority to act to the extent necessary and take the minor’s rights and interests into account. Parents do not automatically obtain access to their child’s personal information solely because they are the child’s parents.

These notices do not cause any additional app content stored only on your device to be sent to us. The support procedures described in this policy apply to information you choose to send us for support.

Local use and data security

LoopLeaf helps you keep in touch with people in everyday life. The app does not assess health conditions or provide therapeutic recommendations. Its adjustable interface is designed to make it easier for people with different needs to use the app. You enter contacts and content manually. The app does not read your device’s address book and does not need access to your location, camera, microphone, photo library, calendar entries, or system health data for these features. A contact method such as “WhatsApp” or “Call” is an organizational detail; it does not automatically connect to that service.

On iOS, LoopLeaf stores persistent app content and settings in its private app storage using UserDefaults. On Android, structured content is held in a local Room/SQLite database, and settings are stored using DataStore in the app’s internal storage. On Android 13 and later, the operating system manages the app language; on earlier Android versions and on iOS, the selection is stored in the app’s local settings.

LoopLeaf does not add its own encryption or app lock for this stored content. Protection depends on your operating system’s security features and your device settings. App content may be visible on screen, in screen captures, and potentially in the app switcher. Use a suitable device lock and limit access to your device.

The apps have no user accounts, connection to our own servers, cloud synchronization provided by us, or in-app purchases. They do not contain analytics, tracking, advertising, or crash-reporting SDKs integrated by LoopLeaf. We do not have remote access to the content you store locally. If you choose to send content to us, for example by email or as a screen capture, we process it to handle your inquiry.

Content and settings processed

Depending on how you use the app, it processes and stores the following in particular:

• Contact name, emoji, preferred and optional alternative contact method, relationship closeness, your assessment of the effort required to contact the person, notes, and an optional birthday with day, month, and, if provided, year;
• Contact interval, last and next contact dates, contact-specific pauses, selected postponement days, archive status and time of archiving, and check-ins with date and time;
• The daily energy level you select for each calendar day and technical information about pause days that have already been applied;
• Your own message ideas, categories, favorites and associated timestamps, language assignments, language labels you enter, and language filters, including filters for individual contacts;
• App language, design selection, light/dark/system appearance, view size, sorting, filters, emoji and form options, and reminder settings;
• Onboarding status, an identifier for “What’s New” content already displayed, and internal IDs, timestamps, and states used for storage, migration, and reminder rotation.

On Android, the database may also contain technical contact attributes such as priority and accent color, as well as retained suggestion information from earlier versions. These are not necessarily identical data fields on both platforms.

The first contact date you choose affects later contact scheduling; it does not have to be stored separately as a start date. On Android, the app reads its own app package’s installation and update times to distinguish a first installation from an update. These times are not stored as a separate history or transmitted to us.

Purposes and legal framework

Daily energy lets you assess your social energy for staying in touch that day, including your capacity for contacts you find challenging. Your selection affects how contacts due for a check-in are displayed and sorted. With “Low,” challenging contacts that are due are shown separately; with “None,” contacts are hidden on the Today screen. You can still mark contacts as contacted on the Contacts screen. You can turn off the daily energy display in Settings. Your selection is processed locally and is not transmitted to us.

Local processing provides the features you use: contact organization, contact history, due dates, daily energy and pause days, message ideas, local search, sorting, language and appearance choices, and reminders. It also supports technical continuity and helps prevent accidental data loss.

Where storage or access operations fall within Section 25 TDDDG and are strictly necessary to provide a feature you have expressly requested, Section 25(2), point 2 TDDDG applies. This does not mean that all additional features are exempt from consent requirements or that data may be stored indefinitely.

LoopLeaf provides software for organizing your personal contacts locally. You decide which people and information to enter and how to use them. Processing takes place on your device; we do not receive this content, access it remotely, or use it for our own purposes.

If you use the app solely for personal or household activities, your processing may fall under the GDPR household exemption. Professional or business use, however, may give rise to data protection obligations of your own.

This is separate from the processing described in this Privacy Policy in connection with our website and your communications with us.

An optional feature or operating system permission does not automatically constitute consent under data protection law. LoopLeaf does not collect medical diagnoses from system services. Depending on their content, free-text entries and daily energy information may nevertheless allow sensitive inferences. Please do not enter health data or other particularly sensitive information about other people that is unnecessary for keeping in touch with them. The legal bases under Article 6 GDPR described above do not replace any additional condition that may be required under Article 9 GDPR.

Information that may relate to health

The daily energy feature allows you to assess the social energy you have available for keeping in touch. LoopLeaf uses your selection to display, sort, and plan your contacts locally. The feature does not assess medical conditions or provide medical diagnoses or therapeutic recommendations.

Depending on their content, your entries, particularly free-text entries and daily energy selections, may nevertheless relate to health or allow inferences about your physical or mental condition. This app content is processed locally on your device and is not transmitted to us. The separate information in this policy applies to possible operating system backups and device transfers.

If you choose to send us content through a contact or support channel, the information in Section 7 applies, or Section 10 for Instagram. A diagnosis is not needed to handle technical problems or accessibility inquiries.

Search and temporary states

Contact searches process contact names stored in LoopLeaf locally. Search terms are not stored in a search history, the contact database, or persistent settings, and are not sent to us. On Android, search terms and open forms may remain available after a temporary interruption or when the interface is recreated as part of the interface state saved by the system. They are therefore not always held exclusively in RAM.

Birthdays and settings that change data

The birthday feature is initially turned off. If you use it, active contacts’ birthdays can be displayed locally. The year of birth is optional. In version 1.4, birthdays do not trigger separate reminder notifications.

Turning off the birthday feature hides stored birthdays but does not delete them. You can remove a birthday in the contact form. Archiving preserves the contact’s details and history while removing the contact from active scheduling and reminders.

Other settings have different effects. Turning off the alternative contact method deletes that information for all contacts after you confirm the change. Turning off the additional relationship closeness option changes affected entries from “close” to “regular” after confirmation.

Reminders and personal contact suggestions

Reminders are turned on by default after a new installation and after using “Delete All Data.” The default style is “General,” which does not include a contact name. You can change reminders and notification times in the app settings or turn reminders off. Whether notifications may be displayed also depends on system permissions and device settings.

On iOS, the app requests notification permission around the first launch if you have not yet made a choice. On Android 13 and later, it requests the system permission when permission has not been granted and reminders are turned on. Earlier Android versions do not have an equivalent runtime permission dialog. Android also uses a system permission to resume local scheduling after the device restarts.

Three styles are available: “General,” “Personal · Gentle,” and “Personal · Random.” The two personal styles are used only if you select them. They may include the name and emoji of a contact due for a check-in in the notification text. Notes, birthdays, contact methods, and check-in histories are not included in that text.

Selection takes place locally. Due dates determine which contacts are eligible. In the “Gentle” style, contact effort and relationship closeness also affect group selection. Both personal styles use randomness and a local rotation state to alternate suggestions. Contact intervals and the time of the last contact are not used as additional ranking criteria within this selection process.

The app stores internal contact IDs, group information, and rotation information for this purpose. On iOS, it also stores assignment and scheduling times, times when delivery is detected, and times when a notification is tapped. These records support local reminder rotation. They are not sent to us or used for advertising or server-based usage analysis. On Android, the current rotation state is stored without equivalent delivery and opening timestamps; older date values from earlier versions may remain.

Notifications are scheduled or triggered locally through the operating system, without a LoopLeaf push server. On iOS, content may be submitted to the notification system in advance for future dates. System and device settings determine whether and how notifications appear on the lock screen, in banners, in the notification center, or on connected devices. The personal reminder styles may therefore display contact names even when the app is not open.

Deleting or archiving the named contact, changing the style, or turning off reminders does not automatically remove a notification that has already been delivered from the notification center. You can remove it there yourself. “Delete All Data” also requests removal of LoopLeaf notifications; the operating system handles removal on connected devices.

Retention and internal data preservation

Local app content generally remains stored until you edit or delete it. The shorter retention rules below apply to daily energy values and their associated technical processing records. These are separate from other suggestion and rotation states.

Your daily energy value for the current day is stored locally on your device so that the daily view, sorting, and reminder logic work. Past “High,” “Okay,” and “Low” values are automatically deleted the next time the app runs a processing cycle in which cleanup can safely take place. LoopLeaf does not build a daily energy history for later display or analysis.

A day marked “None” as a pause day remains stored until the associated postponement of contact due dates has been successfully applied exactly once. Unprocessed pause days have no fixed expiration period. This preserves the intended postponement even if you do not open the app for several days. Once processing is complete, the associated daily energy value is deleted.

A purely technical record of completed processing prevents the same pause day from being applied again. This record is retained on the day of processing and for the next three full calendar days, based on the device’s local time. It is removed no earlier than the start of the fourth following day, during the next processing cycle in which cleanup can safely take place. If the app remains closed during this period, cleanup takes place when you next open it. Cleanup does not run independently in the background or through a server.

After the update, older daily energy values and associated technical records are automatically cleaned up under the same rules, without reapplying pause days that have already been processed. The app does not offer a way to delete individual values or records selectively. “Delete All Data” removes them completely from local app storage. Turning off the daily energy display does not itself delete data; the cleanup rules above still apply.

LoopLeaf processes daily energy values and processing records exclusively on your device. The app does not transmit them to us, external servers, or other recipients. Possible operating system backups and device transfers are covered separately under “Backups and device transfers.” Custom language labels cannot currently be deleted individually; they are removed by “Delete All Data.”

On iOS, cleanup limits the detailed suggestion log to a window starting 14 days before the current day, measured by the scheduled date, and a maximum of 120 entries; future scheduled entries may also be included. This cleanup does not run independently in the background when the app is not in use. The separate rotation state has no automatic time limit.

If stored contacts, custom message ideas, or language definitions become unreadable on iOS, LoopLeaf retains the affected records or an internal raw copy in the same local storage to prevent accidental data loss. This content may be invisible in the interface and unavailable for individual deletion. Older favorite information that can no longer be matched may also remain. “Delete All Data” removes these records. This is not a backup service or a recovery feature available to you.

Animations and local display state

The animated illustrations are rendered on your device. To display them, LoopLeaf uses local interactions and, where needed, existing app data such as daily energy, due dates, birthdays, and check-ins. The animations do not cause any additional transmission of this data to us or to external servers and are not used for usage analytics or advertising.

For birthday and completion displays, LoopLeaf locally stores the calendar day, internal contact IDs, and technical flags for check-ins already accounted for and displays already triggered. This prevents unintended repeats on the same day, including after an app restart. Readable day records for a different calendar day are removed during the next relevant app cleanup; there is no independent deletion timer while the app is closed. On iOS, unreadable records may remain until you use “Delete All Data.” “Delete All Data” removes the stored display records from the app’s local data. The separate information below applies to operating system backups and device transfers.

Copying and sharing

When you copy a message idea, its displayed text is written to the system clipboard. LoopLeaf does not read the system clipboard. If a support or feedback email link cannot be opened because no email application is available, the fixed address support@loopleaf.de may be copied to the clipboard automatically as a fallback.

The operating system controls what happens to copied text afterward. On iOS, this may include a clipboard shared across devices. Depending on the platform and permissions, other apps or system features may have access. Resetting LoopLeaf does not clear the clipboard.

When you share a message idea, LoopLeaf passes its text and a fixed subject, such as “Message Idea,” to the system share sheet. It does not add contact details, notes, or birthdays. Any personal information you entered in the text is, however, passed along as part of that text. Recommending LoopLeaf to others shares a prepared recommendation with a website link, without additional local user content.

You choose the destination app or system feature. LoopLeaf does not send this content through its own servers or analyze which app or recipient you select. Further processing is governed by the selected provider. Deleting content in LoopLeaf afterward does not remove copies you have already shared.

After you copy a message idea, LoopLeaf displays a confirmation screen with an animation. When you share, the iOS app uses only the operating system’s indication of whether the selected action was reported as completed; a reported cancellation does not trigger this display. It does not use the destination app, recipient, returned content, or error details from that response for this purpose. On Android, the display appears after the sharing window closes and you return to the app, even if you did not actually share. On either platform, the display is not proof that a message reached a recipient. The temporary state used for this display and the most recently selected animation background are held only in memory; LoopLeaf does not create a persistent copying or sharing history from them.

Links and support from within the app

The app can open the LoopLeaf website, “Why LoopLeaf?”, this Privacy Policy, the Legal Notice, information about Ryska Productions, Instagram, store review pages, and developer profiles. These destinations open in your browser or an appropriate external application; LoopLeaf does not use an embedded web view. Links do not include local contact or usage content or an individual user identifier. Language-specific website URLs may reveal the app language you selected.

Support and feedback open an email link to support@loopleaf.de with a prefilled subject. The app does not automatically add a contact list, device data, app version, or message. Anything you choose to add and send is covered by Section 7. Included license information, onboarding content, and “What’s New” content are displayed locally in the app.

Backups and device transfers

LoopLeaf 1.4 does not offer data export, import, or its own backup, restore, or synchronization feature.

On iOS, local app data is not expressly excluded from operating system backups. Depending on your use and settings, it may therefore be included in iCloud or computer backups and device transfers. This may cover all persistently stored content, including notes, birthdays, daily energy, and technical state information. Such a backup is not cloud synchronization operated by LoopLeaf.

On Android, the app configuration disables cloud backup of app files. Direct transfer to a new device is different: it is not separately excluded and may occur depending on the Android version and device manufacturer, even with cloud backup disabled. Information held by the system, such as the app language on Android 13 and later, follows the system’s own rules.

We do not have access to your personal operating system backups or copies already transferred. Management and processing of these copies depend on your device and account settings and the terms of the relevant platform or service providers. Deleting data in LoopLeaf does not automatically delete earlier backups or copies on other devices.

Deletion and full reset

You can delete contacts, individual check-ins, and your own message ideas using the app’s designated features. Archiving and hiding birthdays do not delete data. Deleting a contact removes its normally stored details and associated histories. On iOS, internal IDs without an attached name may remain in suggestion and rotation records, and content may remain in the internal copies described above for unreadable data. Notifications already delivered must be considered separately.

“Delete All Data” removes local contacts and histories, custom message ideas and favorites, daily energy values, pause days and their associated technical processing records, custom language definitions and filters, and personal suggestion records. On iOS, it also removes the internal copies and retained unreadable records described above. Settings, including app language and design, are reset; built-in default message ideas remain or are provided again. On Android, purely technical rotation counters and initialization markers without user content remain.

The feature requests removal of scheduled and already visible LoopLeaf reminders, or reschedules them using default settings. Reminders are then turned on again with the “General” style. If no contacts are due, this does not create a new personal notification. Onboarding may appear again; the status of update notices is reinitialized in a platform-specific way.

A reset does not revoke system permissions or Android notification channel settings. It also does not affect the clipboard, sent emails, shared content, system backups, or copies on other devices. You can manage these only through the relevant systems or services.

The deletion features remove data from active app storage; they do not guarantee forensic overwriting of every storage area. In particular, on Android, technical remnants may remain in database or related files until overwritten. Removing the app or clearing its storage through system settings is governed by the operating system. On iOS, offloading the app does not remove app data in the way that fully deleting the app does.

9 App stores and other external providers

When you download or update an app, leave a review, or visit a developer profile, Apple or Google processes data under its own responsibility. This may include account, device, connection, and interaction data. Depending on their services and your settings, these providers may also process usage statistics, technical diagnostics, and crash information, and provide related reports to developers. This is different from an analytics or crash-reporting SDK embedded in LoopLeaf.

We do not use usage, diagnostic, or crash statistics from App Store Connect or Google Play Console for our own analysis. Google Search Console for our website is a separate service.

For Apple, relevant information includes its privacy policy at https://www.apple.com/legal/privacy/ and its app analytics information at https://www.apple.com/legal/privacy/data/en/app-analytics/. For Google, see https://policies.google.com/privacy and your device’s usage and diagnostics settings.

Links to app stores and Instagram on the website and in the apps are standard links. Simply viewing a page does not load embedded content from those providers. After you open a link, your browser or the relevant application sends connection data to the destination. The providers’ privacy information governs their processing, including possible transfers outside the EEA. Our own processing on Instagram is described below.

10 Instagram profile loopleaf.app

Profile operation and communication

We operate @loopleaf.app as a personal Instagram account under the LoopLeaf project name, rather than a Business or Creator account. The profile provides information about LoopLeaf and a way to communicate with people interested in the project. We publish posts and respond to incoming comments and direct messages. We do not run paid advertising through Instagram or Meta. Instagram’s provider for the European region is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

When you visit or interact with our profile, Meta processes data such as account, device, connection, and interaction data, depending on how you use the service. We can see publicly visible profile information, usernames, comments and reactions, and messages sent to us. We use this information to handle your inquiries, communicate, and provide public information about LoopLeaf.

The legal basis for the communication for which we are responsible is Article 6(1)(f) GDPR. Our interest is in providing an accessible source of information and exchanging information about the project. Article 6(1)(b) GDPR applies to contract-related inquiries. Please do not send confidential information about yourself or other people through Instagram.

Statistics and processing by Meta

We have disabled the Insights feature for our Instagram profile and do not use it to analyze the reach or audience of our posts. We do not download Insights reports or share such reports with other services.

Disabling the Insights feature does not mean that Meta no longer processes personal data. When you use Instagram, Meta may continue to process account, device, connection, and interaction data in particular. Information about Meta’s purposes, legal bases, recipients, retention periods, and possible transfers outside the European Economic Area is available in Instagram’s privacy information: https://privacycenter.instagram.com/policy/.

Responsibility under data protection law depends on the processing activity involved. Our handling of comments and messages, as described here, is distinct from Meta’s other processing activities. Where we jointly determine the purposes and means of a specific processing activity with Meta, the joint controllership requirements of Article 26 GDPR apply. Our limited access to underlying data does not remove any obligations we may have.

Meta may also process data outside the EEA. Its privacy information explains the data categories, purposes, recipients, retention periods, legal bases, and transfer mechanisms: https://privacycenter.instagram.com/policy/. You can also find options for managing your privacy and contacting Meta there.

Retention and your rights

We handle Instagram messages addressed to us within Instagram. We do not save screenshots of these messages or copy usernames into our product planning. We may record improvement suggestions as factual tasks in our own words, without including personal information from the message. We review our Instagram inbox at least once a week. We delete completed routine inquiries from our inbox once no further questions are expected. Unresolved inquiries are retained until resolved; in legal disputes, we separately assess whether continued retention is necessary. Deleting a message from our inbox does not necessarily remove it from the other person’s account or all of Meta’s systems. Public posts and interactions may remain until deleted using the platform’s features; Meta’s retention follows its own rules.

Please do not send us health information, diagnoses, or screenshots containing personal app content via Instagram either. For accessibility inquiries, a description of the desired feature or the specific difficulty you experience when using the app is sufficient.

If we nevertheless receive such information, we do not use it in bug reports or product planning and do not repeat it in our response. After reviewing it, we remove the information using the available platform features. If it cannot be removed separately, we delete the message or conversation from our inbox after recording the necessary technical information without any health details. Where necessary, we ask for a new description without this information.

This deletion does not necessarily remove the content from the other person’s account or all of Meta’s systems. For technical support requests and privacy inquiries, you can also contact us without using Instagram at support@loopleaf.de.

You can direct privacy requests to us and, where the processing concerns Meta, to Meta. You do not have to refer a request to Meta before exercising your rights against us. Your statutory rights and complaint options remain unaffected.

11 Your rights and further information

Where the relevant legal conditions are met, you have the right to access your data and receive a copy under Article 15 GDPR, request rectification under Article 16, request erasure under Article 17, request restriction of processing under Article 18, and exercise your right to data portability under Article 20. You may withdraw consent you have actually given for data processing at any time with effect for the future; this does not affect the lawfulness of earlier processing.

For processing based on Article 6(1)(f) GDPR, you may object on grounds relating to your particular situation. We will then stop processing the data concerned unless there are overriding compelling legitimate grounds or a need to establish, exercise, or defend legal claims. You may object to direct marketing at any time.

You may lodge a complaint with a data protection supervisory authority, particularly where you live or work, or where the alleged infringement occurred. Please send requests to us at support@loopleaf.de or the postal address listed above.

Our lack of remote access to local app content does not generally restrict your statutory rights. However, we cannot provide or delete a contact list on our servers because no such list is stored there. Please describe your request without sending us all your app content just in case it might be needed. We will explain the local options available to you. The app’s current lack of an export feature does not amount to a general exclusion of statutory data portability rights.

Our own processing does not involve automated decision-making with legal or similarly significant effects within the meaning of Article 22 GDPR. Local due-date calculations, sorting, and contact suggestions are organizational tools, not decisions of that kind.

You do not have to give us your name or contact details simply to visit the website; necessary technical connection data is still processed. You determine the app content and optional contact details yourself. Some features cannot be used without the information they need.

Other applicable privacy rights

Your rights under the GDPR remain unaffected. Where other privacy laws apply to a particular processing activity, you also have the rights provided by those laws. These may include confirmation of processing, access and a copy of your data, correction, deletion, restriction or suspension of processing, objection, and data portability. The conditions, statutory exceptions, and deadlines depend on the applicable law.

Please send requests and complaints about our processing to support@loopleaf.de, our preferred contact address; the postal address listed above and other legally permitted contact methods remain available. Please describe your concern and the service involved. We request only the information necessary to handle the matter and, where required, verify your identity. We handle your request within the applicable statutory deadlines. If a legally permitted extension or restriction is necessary, we explain it as required by law. National complaint procedures and judicial remedies remain unaffected.

United Kingdom

Where the UK GDPR and the Data Protection Act 2018 apply to the processing in question, the UK data protection rights and complaint procedures described below also apply.

Privacy rights requests

Subject to the statutory requirements, you may request access, rectification, erasure, restriction of processing, and data portability, and object to certain processing activities. Please send requests to support@loopleaf.de, our preferred contact address; other legally permitted contact methods remain available.

We handle privacy rights requests without undue delay and generally within one calendar month of receipt. Where legally permitted and necessary because of the complexity or number of your requests, we may extend this period by up to two further months. We inform you of any extension and its reasons within the original one-month period. Special statutory rules on when the period begins or when it may lawfully be paused remain unaffected. We request additional information to verify your identity only where necessary.

If we do not comply with a request in whole or in part, we explain the reasons and the available complaint and judicial remedy options within the statutory time limit.

Data protection complaints

If you are dissatisfied with how we handle your personal data, you may send a data protection complaint to support@loopleaf.de, our preferred contact address. Other legally permitted contact methods remain available. You do not need to explicitly label your message as a complaint.

We acknowledge receipt of a complaint covered by UK data protection law within 30 days at the latest. We investigate the matter from receipt without undue delay, keep you informed of progress, and communicate the outcome without undue delay. The 30-day period applies only to the acknowledgment of receipt and does not replace the response deadline for privacy rights requests or the obligation to investigate promptly.

If your message contains both a privacy rights request and a complaint, we handle each matter in accordance with its applicable requirements and time limits.

You may also contact the Information Commissioner’s Office (ICO): https://ico.org.uk/. Judicial remedies remain unaffected.

Lawful bases in the United Kingdom

Where the UK GDPR applies to the processing in question, the following lawful bases also apply to the purposes listed below:

The processing of ordinary personal data to deliver and secure our website, detect and resolve technical problems, and prevent misuse is based on Article 6(1)(f) UK GDPR. Our legitimate interest is the secure and reliable operation of our informational website.

The handling of general contact and support requests, as well as our own communications on Instagram, is based on Article 6(1)(f) UK GDPR. Our legitimate interests are in responding appropriately to your inquiries and providing accessible information about LoopLeaf. We limit processing to the ordinary personal data necessary for these purposes and take your interests, rights, and freedoms into account, particularly those of minors.

Where handling a request is necessary to perform a contract with you or to take steps at your request before entering into a contract, it is based on Article 6(1)(b) UK GDPR.

Where processing is necessary to comply with an obligation under UK law that applies to us, it is based on Article 6(1)(c) UK GDPR. If we obtain consent for a particular processing activity and rely on that consent, Article 6(1)(a) UK GDPR applies. You may withdraw such consent at any time with effect for the future.

The app does not automatically transmit locally stored app content to us. If you send us content or screenshots as part of a support request, we handle them in accordance with the rules described in Section 7, “Contact and correspondence”. Before sending them, please remove or redact personal data that is not necessary to resolve the technical issue.

Additional conditions apply to health information and other special category data; the legitimate interests described above are not sufficient on their own.

Hong Kong: applicability and local app use

Where Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) applies to our processing of personal data, we comply with its requirements in addition to other applicable data protection laws. We distinguish between local use of the app and our processing of personal data in connection with our website, contact and support inquiries, and our own communication through Instagram.

App content stored in LoopLeaf is processed and stored locally on your device. The app does not automatically transmit this content to us or to a server operated by us. We do not have remote access to this content and cannot view, retrieve, correct, or delete it on your behalf. The available local deletion options and possible operating system backups and device transfers are described in Section 8.

This is distinct from information that you send us yourself, for example in a support message or screenshot. We process such content to handle your inquiry in accordance with the rules described in Section 7. Please send only the necessary information and remove or redact unnecessary personal details before sending it.

The information in Section 6 applies to website and hosting data, and the information in Section 10 applies to our own communication through Instagram. Independent processing by Apple, Google, and Meta is distinct from our processing and is explained in the relevant sections. Local storage of app content does not restrict your statutory rights regarding the personal data that we actually process.

Hong Kong: purposes and information at collection

Where the Personal Data (Privacy) Ordinance (PDPO) applies, the following information applies to the personal data we collect:

When you visit our website, we process the technical access data described in Section 6 to provide and secure the website, detect and resolve technical issues, and prevent and investigate misuse. This data is transmitted automatically when you access a page. Without the data necessary to establish the connection, we cannot deliver the website. The additional server-side statistical reports generated by our hosting provider and the fact that we currently do not use these reports are also explained in Section 6.

For contact and support inquiries, we use your contact details, messages, and necessary technical information to handle and respond to your inquiry. Contacting us is voluntary. If we have no way to reply or lack necessary information, we may be unable to answer your inquiry or resolve the technical issue. We do not need health information or unnecessary personal app content for this purpose.

For our own communication through Instagram, we use the messages, comments, and associated profile information made available to us to handle your inquiries and communicate about LoopLeaf, as described in Section 10. You decide whether to communicate with us through Instagram.

For website hosting and email processing, we use SpeedIT, the service provider identified in Section 6. Communication through Instagram is also processed through the Meta platform. The respective roles and independent processing by communication providers are explained in Sections 6, 7, and 10. Beyond this, we do not disclose your contact and support data to third parties without your consent unless a statutory obligation or another legally permitted exception applies.

Subject to the statutory requirements, you may request access to the personal data about you that we process and correction of inaccurate data. The person responsible for handling these requests is Katharina Virginia Thielen, who can be reached at support@loopleaf.de and at the postal address provided in Section 5.

Hong Kong: processing in Germany and service providers acting on our behalf

We are based in Germany. We process the website, contact, and support data described in this Privacy Policy in Germany and therefore outside Hong Kong.

For website hosting and email processing, we use SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany. According to the provider, hosting takes place in Germany. We have entered into a data processing agreement with SpeedIT. The additional processing of support messages on our work devices is described in Section 7.

The agreement requires SpeedIT to process data in accordance with our instructions, maintain confidentiality, and implement technical and organizational safeguards. Subject to the conditions agreed in the contract, SpeedIT may use approved subprocessors. These include, in particular, providers of data center infrastructure, domain registration, and SSL certification; the data processed depends on the service involved. The applicable contractual data protection obligations must also be imposed on the subprocessors.

The retention and deletion rules we describe also apply to processing carried out on our behalf. When the contract with SpeedIT ends, the agreement provides for the return of the processed data or, at our request, deletion of that data, including backup copies, unless statutory retention requirements prevent deletion. Deleting a message from our mailboxes does not mean that it is removed from technical backups at the same time.

Where Hong Kong’s Personal Data (Privacy) Ordinance applies to our processing, we remain responsible for complying with the obligations that apply to us.

This processing does not result in the automatic transmission of locally stored app content to us or SpeedIT. If you voluntarily send us such content, for example in a support screenshot, the rules in Section 7 apply. The separately described processing activities carried out by Apple, Google, and Meta are distinct from this processing.

Hong Kong: access, correction, and complaints

Where Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) applies to our processing, you may ask whether we hold personal data about you and obtain a readable copy of that data. You may also request the correction of inaccurate personal data.

Please direct these requests to the privacy contact identified in Section 5, preferably by email. Other legally permitted contact channels remain available. Please describe as specifically as possible which data or correction your request concerns. Where necessary, we ask for reasonable additional information to verify your identity or your authority to act on another person’s behalf.

We handle access and correction requests in accordance with the applicable statutory requirements, generally within 40 calendar days after receipt. If we do not hold the requested data or refuse a request on a legally permitted ground, we inform you in writing within the applicable time limit and, where relevant, explain the reason for refusal. If we cannot fully comply with an access request within the statutory time limit, we inform you in writing of the reasons within that period, comply partially where possible, and complete the response as soon as practicable. Shorter time limits under other data protection laws that also apply remain unaffected.

These rights concern the personal data that we actually hold or have processed by service providers acting on our behalf. We have no remote access to app content stored exclusively on your device. If you send us content yourself, for example in a support message or screenshot, the privacy rights described here and the rules in Section 7 apply.

You may contact us with questions or complaints. Where the PDPO applies, you may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD). Information about the complaint procedure is available at:

https://www.pcpd.org.hk/english/complaints/how_complaint/complaint/complaint.html

We do not require you to contact us first as a condition for lodging a complaint with the supervisory authority. Other statutory remedies remain unaffected.

Where required by the PDPO, we keep a log of refusals to comply with access or correction requests containing the information required by law, particularly the reasons for refusal. We retain these records for at least four years after entry and longer where required by law. This retention concerns the necessary record and does not mean that all support content is retained routinely.

Hong Kong: purpose limitation and consent

Where Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) applies to our processing, we use personal data only for the purposes stated when it was collected or for purposes directly related to those purposes. This also applies to the disclosure or transfer of that data.

If we intend to use personal data for another purpose that is not directly related to the original purpose, we explain the intended use to you beforehand and obtain your express and voluntary consent, unless an applicable statutory exemption applies. Merely reading this Privacy Policy, using our website or app, or sending a support inquiry does not constitute blanket consent to additional purposes of use. Updating this Privacy Policy or providing a notice of changes does not replace any consent that is required.

You may withdraw such consent for the future by giving us written notice, in particular by email to support@loopleaf.de. We then stop the use for the additional purpose that relies on that consent. Use carried out on the basis of that consent before we receive the withdrawal remains unaffected. Other statutory rights to withdraw consent remain available.

This information does not cause app content stored only on your device to be sent to us automatically. If you send us content yourself, for example in a support message or screenshot, the purposes and deletion procedures described in Section 7 also apply.

Hong Kong: minors and unsolicited health information

Where Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) applies to our processing, we take minors’ age and ability to understand into account when communicating with them. We limit the personal data used for contact and support inquiries to the information required for the particular inquiry and explain any consent that may be required in an age-appropriate way.

If consent is to be obtained for a new purpose of use that is not directly related to the original purpose, we consider whether the minor can understand that purpose and decide whether to consent. If this is not the case, a person with parental responsibility may give consent on the minor’s behalf under the statutory conditions. In particular, both the person with parental responsibility and we must have reasonable grounds for believing that the new use is clearly in the minor’s interest.

We do not request health information or diagnoses and do not need them for accessibility inquiries either. Please describe only the specific usability problem or the desired feature. If health information is nevertheless sent to us, we do not use it to assess the person, analyze errors, or plan the product. We remove it without delay after reviewing it, following the deletion procedures described in Section 7. For further support handling, we retain only the necessary technical information and the required contact and correspondence details. We do not treat simply sending us health information as consent to its further use.

Switzerland

Switzerland: applicability and local app use

Where the Swiss Federal Act on Data Protection (FADP) applies to our processing of personal data, we comply with its requirements in addition to other applicable data protection laws. We distinguish between local use of LoopLeaf and the processing of personal data in connection with our website, contact and support inquiries, and our own communication through Instagram.

The app content you enter in LoopLeaf is processed and stored locally on your device. The app does not automatically transmit this content to us or to an app server operated by us. We do not have remote access to content stored only on your device and cannot view, retrieve, correct, or delete it on your behalf. The available deletion options, possible operating system backups, and device transfers are described in Section 8.

This is distinct from content you send us yourself, for example in a support message or screenshot. We process this information when handling your inquiry in accordance with the purposes, safeguards, and deletion procedures described in Section 7. Please send only the information necessary for your inquiry and remove or redact unnecessary personal data before sending it.

The information in Section 6 applies to website and hosting data; the information in Section 10 applies to our own communication through Instagram. Independent processing by Apple, Google, and Meta is distinct from our processing and is explained in the relevant sections. Local storage of app content does not restrict your statutory rights concerning personal data that we actually process.

Switzerland: purposes, processing principles, and consent

Where the Swiss Federal Act on Data Protection applies, we process personal data lawfully, in good faith, and proportionately. We collect data for specific purposes that are identifiable to you and subsequently process it only in ways compatible with those purposes.

For our website, these purposes include, in particular, technical delivery, secure operation, and the detection and resolution of faults and abuse. We use contact and support data to handle and respond to your inquiry and for necessary follow-up questions. The purposes described in Section 10 apply to our own communication through Instagram. Details are provided in Sections 6, 7, and 10.

We limit processing to the personal data necessary for the specific purpose. We take appropriate measures to correct or remove inaccurate or incomplete data. We delete or anonymize personal data that is no longer needed in accordance with the retention and deletion rules described in this policy, taking into account statutory retention obligations and legally permissible retention to protect legal claims.

Not every instance of processing by private controllers requires consent under Swiss law. Where consent is required, we provide the necessary information and obtain voluntary consent for the specific processing activity. Where consent is required for sensitive personal data, it must be explicit. You may withdraw consent with effect for the future through the contact channels listed in Section 5.

We do not treat using our app or website or sending us a message as blanket consent to processing for additional purposes. Before further use that is incompatible with the original purpose, we assess whether it is permissible, inform you in accordance with the statutory requirements, and obtain consent where required. The separate information in Section 7 applies to unsolicited health information.

Switzerland: processing in Germany and SpeedIT

We are based in Germany and process the personal data arising from our website and contact and support inquiries in Germany, outside Switzerland. When handling your inquiries, messages and attachments may also be stored on the devices we use in Germany, as described in Section 7.

We use SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany, to host our website and provide our email mailboxes. According to the provider, hosting takes place in Germany. SpeedIT processes the necessary data on our behalf to provide and secure the website and to receive, send, and store email correspondence. We have a data processing agreement with SpeedIT. Information about the hosting infrastructure is provided in Section 6. The contractual requirements for subprocessors are explained in Section 11 under “Hong Kong: processing in Germany and service providers acting on our behalf”.

Where the Swiss Federal Act on Data Protection applies, its requirements apply to this processing on our behalf, particularly those concerning compliance with instructions, data security, and the involvement of further processors. We remain responsible for the processing we arrange. You may direct privacy inquiries to the responsible person identified in Section 5; where necessary, we involve SpeedIT in handling your inquiry.

Germany is recognized as a country with an adequate level of data protection under Annex 1 of the Swiss Data Protection Ordinance. To the extent that the processing described constitutes disclosure of personal data abroad within the meaning of the Swiss Federal Act on Data Protection, separate consent or safeguards through standard data protection clauses are therefore not required solely because Germany is the recipient country. Other requirements concerning the permissibility, transparency, and security of processing remain unaffected.

This information concerns the website, contact, and support data we process. App content stored only on your device is not automatically transmitted to us or SpeedIT as a result. If you send us content or screenshots yourself for a support inquiry, the processing and deletion rules described in Section 7 apply. Independent processing by Apple, Google, and Meta is distinct from this; the statement about hosting in Germany does not extend to their processing.

Switzerland: safeguards, retention, and responsibility

Where the Swiss Federal Act on Data Protection applies, we implement appropriate technical and organizational measures to ensure a level of data security appropriate to the risk. In doing so, we consider, in particular, the nature, scope, and purpose of processing and the potential risks to the individuals concerned. These measures are intended to protect personal data against unauthorized access, loss, and unlawful alteration or disclosure.

Only the responsible person identified in Section 5 has access to the support messages we handle and the associated accounts. Our iPhone and MacBook are protected by device locks; FileVault disk encryption is also enabled on the MacBook. We regularly install security updates and use antivirus software that also receives regular security updates. Our website uses HTTPS to encrypt transmission between your browser and the web server. This does not automatically make emails end-to-end encrypted. The contractual and statutory data protection requirements described in this policy apply to processing by SpeedIT on our behalf.

We retain personal data only for as long as necessary for the respective lawful purpose or as required by a statutory retention obligation. Any further retention to protect legal claims takes place only where legally permissible and necessary. The specific periods or criteria and deletion procedures for website and hosting data, support messages, attachments, and our Instagram communication are provided in Sections 6, 7, and 10. We delete or anonymize personal data that is no longer needed in accordance with these rules.

Anonymized descriptions of errors retained for maintenance and troubleshooting contain no information that allows them to be linked to the person who reported the issue or other individuals. Personal messages and screenshots, by contrast, are subject to the deletion procedures described in this policy. Applicable retention and deletion requirements also apply to technical backups; the technical limitations described in this policy do not replace any statutory deletion obligation.

This information about our work devices and procedures is distinct from exclusively local app use. It does not mean that LoopLeaf provides additional encryption or an app lock. The information in Section 8 applies to the protection of locally stored app content, possible operating system backups, and device transfers.

As the provider of LoopLeaf, Katharina Virginia Thielen is responsible for the processing described here and is your privacy contact. She handles privacy inquiries and complaints and oversees the necessary safeguards. You can contact her at support@loopleaf.de, preferably by email or through the other contact channels in Section 5. This role is distinct from that of a representative in Switzerland or a formal appointment as a data protection adviser under the Swiss Federal Act on Data Protection.

Switzerland: rights, privacy inquiries, and complaints

Where the Swiss Federal Act on Data Protection applies, you may request information about whether we process personal data about you and, if so, what data we process. This information includes, in particular, the data processed, the purposes of processing, the retention period or the criteria used to determine it, available information about the origin of the data, and recipients or categories of recipients. Where data is disclosed abroad, it also includes the information required by law about the recipient country and, where applicable, data protection safeguards.

You may request the correction of inaccurate personal data. Subject to the statutory requirements, you may also request the deletion or destruction of your data, the cessation or restriction of processing or disclosure, and object to processing. Where processing is based on your consent, you may withdraw that consent with effect for the future. Legally permissible grounds for further processing or retention remain unaffected.

Subject to the requirements of the Swiss Federal Act on Data Protection, you may request the personal data you have disclosed to us in a commonly used electronic format or have it transferred to another controller. This applies, in particular, to data that we process by automated means with your consent or in direct connection with a contract; statutory restrictions and the requirements for a transfer remain applicable.

You may send inquiries and complaints to Katharina Virginia Thielen, preferably by email at support@loopleaf.de or through the other contact channels in Section 5. Please describe your concern so that we can identify the relevant matter. You do not need to give reasons for an access request. To identify you securely and protect against unauthorized disclosure, we verify your identity in a proportionate manner. We request additional information only where necessary for this purpose; a copy of an identity document is not routinely required.

We generally provide access information free of charge and usually within 30 days. If we cannot meet this deadline, we inform you within that period and tell you when the information will be provided. We explain any refusal, restriction, or postponement permitted by law. We handle other privacy inquiries and complaints within the applicable statutory or reasonable time limits.

We have no access to app content stored exclusively on your device. The options for managing and deleting this content are described in Section 8. If you voluntarily send us content as part of a support inquiry, your rights also apply to the personal data we receive and process as a result.

If you suspect a violation of the Swiss Federal Act on Data Protection, you may report it to the Federal Data Protection and Information Commissioner (FDPIC). Information and access to the reporting form are available at https://www.edoeb.admin.ch/de/anzeige-einreichen. The FDPIC performs its statutory supervisory duties; a report does not replace the enforcement of individual claims before a court. This option remains available to you subject to the statutory requirements.

Switzerland: minors, unsolicited health information, and information about other people

Where the Swiss Federal Act on Data Protection applies, we take into account minors’ age, understanding, and particular need for protection when processing their personal data. We limit processing to the information necessary for the specific purpose and explain privacy matters in clear, age-appropriate language. The target audience designation “ages 13 and up” does not constitute blanket consent to the processing of personal data.

Where consent is required for a particular processing activity, the relevant consideration is whether the minor can understand its meaning and main consequences and make a legally valid decision independently. If they cannot, we involve a duly authorized legal representative. Minors may exercise their privacy rights independently to the extent that they have the capacity of judgment to do so. When parents or other representatives make requests, we verify the necessary authority to represent the minor and take the minor’s personality rights into account.

Under Swiss law, health information is sensitive personal data. We do not request health information or diagnoses and do not need them for accessibility inquiries either. Please describe only the feature you would like or the specific usability problem. We do not treat the unsolicited submission of such information as blanket consent to its further use. Where consent is required to process sensitive personal data, that consent must be explicit.

If we nevertheless receive health information, we do not use it to resolve technical issues, for error reports, or for product planning. After reviewing it, we remove it without delay in accordance with the deletion procedures described in Section 7. If the information cannot be removed separately, we delete the message or attachment concerned after recording the necessary technical information without any health details. Where necessary, we ask for a new description without such information. We do not repeat health information in our reply. For Instagram, the deletion options and technical limitations in Section 10 also apply.

Before sending information, please remove or redact unnecessary personal details about other people, particularly names, contact details, personal notes, and health information in screenshots. Your submission does not replace any consent that may be required from those people. After reviewing unnecessary information, we remove it in accordance with the support and deletion procedures described in this policy.

If we receive personal information about other people, we separately assess whether we have a duty to inform them. In particular, we consider whether the information is captured merely incidentally or by chance, or is the subject of deliberate collection or further processing. Where a duty to inform applies, we notify the person concerned as required by law no later than one month after receiving the data or, if disclosure occurs earlier, no later than that time. We assess and explain any legally permitted exception or restriction in the individual case. Informing the sender about deletion does not replace any required notification to the other person concerned.

Japan

Japan: applicability and purposes of use

Where we process personal information about individuals in Japan in connection with our services and Japan’s Act on the Protection of Personal Information (APPI) applies, we comply with its requirements in addition to other applicable data protection laws.

The purposes of use are described in the relevant sections of this Privacy Policy. They include, in particular:

• Website (Section 6): Providing the website, ensuring its secure and reliable operation, detecting and resolving technical issues, and preventing and investigating misuse.

• Contact and support (Section 7): Receiving, handling, and responding to your inquiries, including necessary follow-up questions and the resolution of technical problems.

• Our Instagram profile (Section 10): Handling your messages and comments and communicating about LoopLeaf. Meta’s processing is explained separately in that section.

Content stored locally in the app is not automatically transmitted to us. If you voluntarily send us content or screenshots as part of a support inquiry, the purposes and procedures described in Section 7 apply.

Where the APPI applies, we change purposes of use only to the extent legally permitted in relation to the original purpose. We notify you of such changes or publish the revised purposes as required by law. Any use beyond that scope takes place only with your prior consent or under a statutory exception.

Japan: processing in Germany

We handle website and support data in Germany. We use SpeedIT to host our website and email mailboxes. According to the provider, hosting takes place in Germany. When handling your support inquiries, messages and attachments may also be stored on the devices we use in Germany, as described in Section 7.

Germany is among the countries whose data protection systems Japan’s Personal Information Protection Commission recognizes as equivalent for the purposes of Article 28 APPI. Separate consent under that provision is therefore not required solely because processing is carried out by a service provider in Germany. Other requirements of the applicable data protection laws remain unaffected.

This information concerns the website and support data we process. Locally stored app content is not automatically transmitted to us or to SpeedIT. If you voluntarily send us content or screenshots for a support inquiry, we handle them in accordance with the rules described in Section 7.

For independent processing by Apple, Google, and Meta, please refer to the relevant sections of this Privacy Policy and those providers’ privacy information. The statement about hosting in Germany does not extend to their processing.

Japan: protection of personal information

We limit the processing of personal information to the details necessary for the specific purpose. Wherever possible, we handle technical support inquiries without private app content or health information. We remove unnecessary personal information from submitted screenshots after review, following the procedures described in Section 7. For further troubleshooting, we retain only anonymized technical descriptions of errors. Support messages and attachments containing personal information are subject to the deletion rules described there.

Only the person responsible for processing identified in Section 5 has access to the support messages we handle and the associated accounts. Our iPhone and MacBook are protected by device locks. FileVault disk encryption is also enabled on the MacBook. We regularly install security updates and use antivirus software that also receives regular security updates.

Our website uses HTTPS to encrypt transmission between your browser and the web server. This does not mean that emails are automatically end-to-end encrypted. We use SpeedIT for hosting and email processing and have a data processing agreement with the provider. Processing by the provider and storage on our devices are described in Sections 6 and 7.

Locally stored app content is not automatically transmitted to us. LoopLeaf does not add its own encryption or app lock; the protection of this content depends on the operating system’s security mechanisms and your device settings. The safeguards for our work devices described above are separate from this.

You may request further information about the safeguards used for our processing through the privacy contact in Section 5. We respond to such inquiries without undue delay. We do not disclose technical details if doing so would compromise the security of personal information.

Japan: rights, requests, and complaints

Where Japan’s Act on the Protection of Personal Information (APPI) applies, you may, subject to its requirements, request information about purposes of use, disclosure of retained personal data about you that is covered by the law, and disclosure of existing records of disclosures to third parties that are covered by the law. If information is inaccurate, you may request correction, addition, or deletion. Subject to the statutory requirements, you may also request cessation of use, deletion, or cessation of disclosure.

Please send your request by email, preferably to support@loopleaf.de. Other legally permitted contact methods remain available. Please describe your request and the data concerned as specifically as possible. We help you clarify the scope and verify your identity and, where applicable, a representative’s authority only to the extent necessary.

We handle requests without undue delay. Upon request, we provide disclosures electronically. If the requested form is not possible under the statutory conditions, we notify you and provide the disclosure in the alternative form required by law. We do not charge fees for handling these requests.

If no corresponding data exists or we do not comply with a request in whole or in part, we notify you without undue delay and explain the relevant reasons.

You may also direct privacy complaints to the contact listed above. We review your concern and inform you of the outcome. Japan’s Personal Information Protection Commission (PPC) also offers advice on privacy questions and complaints: https://www.ppc.go.jp/personalinfo/pipldial/. Statutory judicial remedies remain unaffected.

South Korea

South Korea: applicability and local app use

Where South Korea’s Personal Information Protection Act (PIPA) applies to our processing of personal data, we comply with its requirements in addition to other applicable data protection laws. We distinguish between local use of the app and the processing of personal data in connection with our website, support inquiries, and our own communication through Instagram.

Content you enter in LoopLeaf is processed and stored locally on your device. The app does not automatically transmit this content to us or to an app server operated by us. We cannot view, retrieve, correct, or delete this content stored exclusively on your device on your behalf. The available deletion options and the particular features of operating system backups and device transfers are explained separately in this Privacy Policy.

This is distinct from content you send to us yourself, for example in a support message or screenshot. Such submitted content is processed when handling your inquiry as described in Section 7. Please send only the information necessary for this purpose and remove any unnecessary personal data beforehand.

The information in Section 6 applies to website and hosting data; the information in Section 10 applies to our own communication through Instagram. Independent data processing by Apple, Google, and Meta is distinct from our processing and is also governed by those providers’ privacy information.

South Korea: purposes and legal bases

Where South Korea’s Personal Information Protection Act (PIPA) applies, we process personal data for the purposes and on the legal bases listed below. Details of the types of data and their retention are described in the relevant sections.

Website and technical security: We process the technical access data described in Section 6, in particular the IP address, time, requested address, and technical browser and connection information, to deliver the website, detect and resolve technical issues, and prevent and investigate misuse. The legal basis is Article 15(1)(6) PIPA, to the extent that processing is necessary for these purposes, is proportionate to them, and our legitimate interests clearly outweigh the rights of the data subjects. In doing so, we take into account, in particular, limited retention and the absence of advertising and personal usage profiles. The server-side statistical reports automatically generated as part of hosting and the fact that we do not currently use these reports are described separately in Section 6.

Contract-related contact and support inquiries: We process the necessary contact details, technical message data, and inquiry content needed to handle the request on the basis of Article 15(1)(4) PIPA, to the extent necessary to perform a contract with you or take steps you request in connection with entering into a contract. This also applies to corresponding inquiries through Instagram.

Other inquiries and our own Instagram communication: We process necessary contact or profile details, messages, comments, and associated communication data to respond to your concerns and communicate appropriately about LoopLeaf. Article 15(1)(6) PIPA may provide the basis for this processing subject to the conditions stated above. We limit processing to the information necessary for these purposes; publicly visible profile information or a message does not constitute blanket consent to other purposes of use. Details are provided in Sections 7 and 10.

Legal obligations: Where a legal obligation applicable to us requires the processing of certain personal data, we process that data on the basis of Article 15(1)(2) PIPA to the extent necessary.

Processing with consent: Where consent is required for processing beyond these purposes, we obtain it separately before that processing begins. We provide information about the purpose, the types of data concerned, the retention period, the right to refuse consent, and any consequences of refusal. Merely visiting our website or sending an inquiry does not replace any required consent. Special requirements concerning minors and health information remain unaffected.

South Korea: processing in Germany and SpeedIT

Where South Korea’s Personal Information Protection Act (PIPA) applies, we also comply with its requirements when processing personal data outside South Korea. We are based in Germany and process the personal data arising from our website and contact and support inquiries in Germany.

We use SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany, to host our website and provide our email mailboxes. SpeedIT processes the necessary data on our behalf to provide and secure the website and to receive, send, and store email correspondence. According to the provider, hosting takes place in Germany. We have a data processing agreement with SpeedIT. When we handle your inquiries, messages and attachments may also be stored on the devices we use, as described in Section 7.

Our direct collection of personal data as a provider based in Germany is distinct from subsequent processing by another provider. To the extent that processing by SpeedIT constitutes a cross-border transfer under Article 28-8 PIPA, we rely on the equivalence recognition for the European Union and the European Economic Area pursuant to Article 28-8(1)(5) PIPA. Germany is covered by this recognition. Separate consent to the cross-border transfer is therefore not required solely because Germany is the processing location. Other requirements, particularly those concerning the legal basis for processing, entrusted processing, data security, and your rights, remain unaffected.

Details of the types of data processed, the purposes, and the retention and deletion rules are provided in Sections 6 and 7. You may direct privacy inquiries to the contact named in Section 5, preferably by email to support@loopleaf.de.

This information does not result in any automatic transmission to us or SpeedIT of app content stored exclusively on your device. If you send us content or screenshots yourself for a support inquiry, the described support and deletion rules apply. Independent processing by Apple, Google, and Meta is distinct from this processing; the statement about hosting in Germany does not extend to their processing.

South Korea: safeguards, retention, and privacy contact

Where South Korea’s Personal Information Protection Act (PIPA) applies, we implement the technical and organizational safeguards required for our processing. These safeguards concern the website, contact, and support data we process, as well as our own communication through Instagram.

Only the responsible person named in Section 5 has access to the support messages we handle and the associated accounts. Our iPhone and MacBook are protected by device locks; FileVault is also enabled on the MacBook. We regularly install security updates and use antivirus software that also receives regular security updates. Our website uses HTTPS to encrypt transmission between your browser and the web server. This does not automatically provide end-to-end encryption for emails. Information about processing by SpeedIT is provided in Sections 6 and 7 and in the preceding supplement on processing in Germany.

We retain personal data only for as long as necessary for the respective lawful processing purpose or as required by an applicable statutory retention obligation. The specific retention periods or criteria and the deletion procedures for website logs, support messages, attachments, and Instagram communication are described in Sections 6, 7, and 10. When personal data is no longer needed, we delete it without undue delay in accordance with the applicable legal requirements. If another applicable law requires continued retention, we store the data concerned separately from other data and limit its use to the purpose provided for by law.

The technical error descriptions we retain for maintenance and troubleshooting contain no information that could identify the person who reported the issue or any other individual. Personal messages and screenshots, by contrast, are subject to the described deletion rules. The technical limitations concerning backups and platforms explained in the relevant sections do not replace any statutory deletion obligation.

App content stored exclusively on your device is distinct from these processing activities. The safeguards on our work devices do not provide additional encryption or an app lock in LoopLeaf. The separate information in this Privacy Policy applies to local app content and possible operating system backups.

Katharina Virginia Thielen is the person responsible for privacy at LoopLeaf and, where PIPA applies, performs the duties of the privacy officer under Article 31 PIPA. These duties include handling privacy inquiries and complaints and reviewing our data protection measures. You can contact her by email, preferably at support@loopleaf.de or through the other contact methods listed in Section 5. This role is distinct from that of a local representative in South Korea.

South Korea: rights, privacy requests, and complaints

Where South Korea’s Personal Information Protection Act (PIPA) applies to our processing of your personal data, you may, subject to its conditions, request information about and access to that data, its correction or deletion, or the suspension of its processing. You may withdraw consent you have given. The information provided may include, in particular, the data processed, purposes of use, retention period, disclosures to third parties, and consent you have given. Statutory restrictions, particularly where retention is mandatory, remain applicable.

You can send your request by email, preferably to support@loopleaf.de. The other contact methods listed in Section 5 remain available. Requests can generally also be made through the channel through which you provided the data concerned, for example through an Instagram direct message. Please describe your request and the data concerned as specifically as possible. To verify your identity or a representative’s authority, we require only the information necessary for that purpose. You may also exercise your rights through an authorized representative; legal representatives may act on behalf of children under 14.

We generally handle access requests within ten days of receipt. Where postponement, restriction, or refusal is permitted by law, we inform you within the prescribed period of the reasons and how you can object. Once a lawful reason for postponement no longer applies, we provide access without delay. For requests for correction, deletion, or suspension of processing, we inform you within the statutory ten-day period of the measures taken or a legally permitted refusal and its reasons. We handle withdrawal of consent in accordance with the legal requirements applicable to it.

If you disagree with our handling of your request or our decision, you can ask for a further review through the same contact methods. Independently of this, you can contact the competent South Korean bodies:

Personal Information Protection Commission (PIPC): https://www.pipc.go.kr/

Korea Internet & Security Agency (KISA) Personal Information Infringement Report Center: https://privacy.kisa.or.kr/

Personal Information Dispute Mediation Committee, for dispute mediation: https://www.kopico.go.kr/

You do not have to complain to us first in order to use these external complaint or dispute mediation channels.

This information concerns personal data that we actually process. We do not have access to app content stored exclusively on your device. If you voluntarily send us such content as part of a support request, for example as a screenshot, the rules described in Section 7 apply.

New Zealand

New Zealand: applicability and local app use

Where New Zealand’s Privacy Act 2020 applies to our processing of personal information, we comply with its requirements in addition to other applicable data protection laws. We distinguish between local use of LoopLeaf and the processing of personal information in connection with our website, contact and support inquiries, and our own communication through Instagram.

Content entered in LoopLeaf is processed and stored locally on your device. The app does not automatically transmit this content to us or to an app server operated by us. We do not have remote access to content stored exclusively on your device; we cannot view, retrieve, correct, or delete it on your behalf. The available deletion options and possible operating system backups and device transfers are described in Section 8.

This is distinct from content you send to us yourself, for example in a support message or screenshot. The purposes, safeguards, and deletion procedures described in Section 7 apply to that information. Please send only the information necessary for your inquiry and remove or redact unnecessary personal information before sending it.

The information in Section 6 applies to website and hosting data, and the information in Section 10 applies to our own communication through Instagram. Independent processing by Apple, Google, and Meta is distinct from this and is explained in the relevant sections. Local storage of app content does not restrict your statutory rights concerning personal information that we actually process.

New Zealand: purposes and information at collection

Where New Zealand’s Privacy Act 2020 applies, we collect personal information only to the extent necessary for a lawful purpose connected with our services. If identification is not necessary for the particular purpose, we do not require identifying information.

When you visit our website, the technical access data described in Section 6 is processed to provide the website, detect faults, and prevent misuse. This is distinct from the automatic generation of server-side web statistics by our hosting provider, which is also described there; we currently do not access or evaluate these reports.

For contact and support inquiries, we process the necessary contact details, message content, and technical information to handle and respond to your inquiry, as explained in Section 7. Contacting us is voluntary. If a way to reply or necessary information is missing, we may be unable to answer your inquiry or resolve the technical problem. We do not need health information or unnecessary personal app content for this purpose.

The purposes and types of information in Section 10 apply to our own communication through Instagram. You do not need to use Instagram to contact us.

The agency that collects and holds information for our operations is the provider identified by name, address, and contact details in Section 5. SpeedIT processes website and email data on our behalf; the provider’s name, address, and tasks are given in Sections 6 and 7. For Instagram, Meta’s role and the processing on that platform are described in Section 10. Your New Zealand rights of access and correction are explained in the following rights paragraph.

New Zealand: processing in Germany and service providers acting on our behalf

We handle website, contact, and support data in Germany. For people in New Zealand, this processing therefore takes place outside New Zealand. When handling inquiries, messages and attachments may also be stored on the devices we use in Germany, as described in Section 7.

For website hosting and the provision of our email mailboxes, we use SpeedIT Solutions UG (haftungsbeschränkt), Asphalweg 26, 30916 Isernhagen, Germany. According to the provider, hosting takes place in Germany. SpeedIT processes the necessary data on our behalf to provide and secure the website and to receive, send, and store emails. We have a data processing agreement with the provider.

Where SpeedIT stores or processes this data solely on our behalf and does not use or disclose it for its own purposes, this is not a disclosure to a foreign recipient within the meaning of Information Privacy Principle 12 under New Zealand’s Privacy Act 2020. We remain responsible for the personal information we process. Separate consent under this principle is not required for such processing on our behalf solely because the processing takes place in Germany.

If we disclose personal information to a foreign recipient for use for its own purposes, we first assess the applicable requirements, including Information Privacy Principle 12 where it applies.

This information does not cause locally stored app content to be sent to us or SpeedIT automatically. If you send us content or screenshots yourself for a support inquiry, the described support and deletion procedures apply. Independent processing by Apple, Google, and Meta is distinct from this; the information about hosting in Germany does not extend to their processing.

New Zealand: access, correction, and complaints

Where New Zealand’s Privacy Act 2020 applies, you may, subject to its requirements, request confirmation of whether we hold personal information about you and obtain access to that information. You may also request its correction.

Please direct your request to our privacy contact, preferably by email at support@loopleaf.de or through the other contact methods in Section 5. You do not need to use a particular form or expressly refer to the Privacy Act. We help you clarify your request and verify your identity or authority to act on someone’s behalf only to the extent necessary.

We decide on access and correction requests as soon as reasonably practicable, generally no later than 20 working days after receipt. The statutory New Zealand definition of working days applies. An acknowledgment of receipt does not replace this decision. If we grant access, we make the information available without undue delay.

If a legally permitted extension is necessary, we inform you within the original time limit of the reason, the length of the extension, and your right to complain about it to the Office of the Privacy Commissioner. If we refuse a request in whole or in part, we explain the relevant statutory grounds where required and advise you of the option to have the decision reviewed by that Office.

If we do not make a correction you request, you may provide us with a statement of the correction sought and request that it be attached to the relevant information. We take the reasonable steps required by law to ensure that the statement is read together with the information. If we correct information or attach such a statement, we inform previous recipients to the extent reasonably practicable.

You may also direct privacy complaints to us. We promptly acknowledge receipt, review your concern, and inform you of the outcome and any further steps. Please first give us an opportunity to resolve the matter. If your concern cannot be resolved, you may contact the Office of the Privacy Commissioner, subject to the applicable requirements. Information about the complaints process is available at:

https://www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/

These rights concern personal information that we actually hold, including information stored on our behalf. We do not have remote access to app content stored exclusively on your device. If you send us content or screenshots yourself, the described support procedures and the applicable rights apply.

Australia: access, correction, and complaints

Where the Australian Privacy Act and the Australian Privacy Principles apply to our processing, you may, subject to their conditions, request access to the personal information we hold or control about you. You may also request correction if that information is inaccurate, out of date, incomplete, irrelevant, or misleading in light of the purpose for which it is processed.

You can send requests and privacy complaints to the privacy contact named in Section 5, preferably by email at support@loopleaf.de. Other legally permitted contact methods remain available. Where necessary to handle your request securely, we may ask for additional information to verify your identity; we limit this to what is necessary.

We respond to access and correction requests within a reasonable period, generally within 30 calendar days. If handling a request takes longer in an individual case, we explain the reason and the expected response time. We do not charge for making an access request or for corrections.

If we refuse access or a correction in whole or in part, we notify you in writing of the reasons, where required by law, and of the available complaint options. If a correction is refused, you may, subject to the legal conditions, request that a statement of your disagreement be associated with the information concerned.

When you make a privacy complaint, we investigate the matter and inform you of the outcome and any measures taken. Please first give us an opportunity to resolve the matter. If you are dissatisfied with our response or have not received a response within 30 days, you may, subject to the legal conditions, contact the Office of the Australian Information Commissioner (OAIC): https://www.oaic.gov.au/privacy/privacy-complaints.

Canada

Where Canadian federal or provincial privacy law applies to our processing, you may, subject to its requirements, find out whether we process personal information about you, obtain access to that information, and request information about its use and disclosure. You may challenge the accuracy and completeness of your information and request correction. Withdrawal of consent is explained in Section 7.

Where Québec privacy law applies, you may also, subject to the statutory requirements, request that computerized personal information collected from you be provided in a structured, commonly used technological format or transmitted to a person or organization legally authorized to receive it. This right does not cover information we have created or inferred; the statutory exception for serious practical difficulties remains unaffected. Subject to the statutory requirements, you may also request that dissemination of personal information cease or that certain search links be de-indexed or re-indexed.

Please direct your request or privacy complaint to the responsible person named in Section 5, preferably by email to support@loopleaf.de. For formal access and correction requests, please submit a written request, for example by email. We help you clarify your request and verify your identity only to the extent necessary.

We handle requests within the applicable statutory time limit. For access requests under the Canadian federal law PIPEDA, this is generally 30 calendar days from receipt. Where a legally permitted extension is necessary, we inform you within the original time limit of the reason, the new deadline, and your right to complain. Requests under provincial law are subject to that law’s time limits. If a request is refused in whole or in part, we explain the reasons and the available review or complaint procedures in accordance with applicable law.

Depending on which authority has jurisdiction, you may contact the following privacy authorities:

• Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/
• Commission d’accès à l’information du Québec: https://www.cai.gouv.qc.ca/
• Office of the Information and Privacy Commissioner of Alberta: https://oipc.ab.ca/
• Office of the Information and Privacy Commissioner for British Columbia: https://www.oipc.bc.ca/

We recommend that you first direct privacy complaints to us so that we can review your concern. The applicable statutory complaint and review procedures and judicial remedies remain unaffected.

United States

For people in the United States, additional rights and complaint options depend on the applicable federal and state law. The general contact method described above is also available for these matters.

No sale of personal information or sharing for targeted advertising

We do not sell your personal information or make it available to third parties in exchange for money or other valuable consideration. We also do not share your personal information for targeted advertising based on your activities across different websites, apps, or services ("sharing" for "cross-context behavioral advertising" under California privacy law).

The processing by service providers described in this policy, particularly for website hosting and email, remains unaffected. Information about processing by external providers such as Apple, Google, and Meta is provided in the relevant sections of this policy.

Updates

This policy describes the functionality identified above. If features, data flows, or services change, we will update the privacy information accordingly. The effective date of each version appears at the beginning of this policy.

We will also inform you of material changes to data processing on our website through a prominent notice on the website before the changed processing begins. The notice will explain the material changes, state when they will take effect, and link to the updated Privacy Policy.

We will also inform you of material changes to data processing in the app through a prominent notice within the app, for example when you first open it after a relevant app update. The notice will explain the material changes and link to the updated Privacy Policy. It will appear before the changed processing begins.

Purely editorial changes will not trigger an additional notice on the website or in the app. Where a change requires consent, we will obtain that consent separately before the relevant processing begins.