Privacy Policy
Last updated: January 2025
1. Information about Collection of Personal Data
This privacy policy informs users about how personal data is handled within the evernook application. Personal data refers to any information that enables personal identification.
The data controller is Swiftmill UG (haftungsbeschrankt), Holzhofallee 21, 64295 Darmstadt, Germany, represented by Johannes Seidel (Email: johannes@swiftmill.io).
2. Data We Collect
evernook is designed with privacy in mind. We collect minimal data necessary to provide our services:
- Account information (if you create an account)
- App usage data for improving the service
- Purchase information for subscription management
- Device information for app compatibility
3. Data Processing
3.1 General Information
Service providers assist in contract implementation, receiving personal data as described below.
3.2 RevenueCat
In-app payments are processed through RevenueCat Inc. (300 Euclid Avenue, San Francisco, CA 94118, USA). Order information is shared solely for payment processing under GDPR Article 6(1)(b). Details are available at their privacy policy.
3.3 Microsoft Azure OpenAI
Image processing uses Azure services on European servers ensuring GDPR compliance. Data transmission occurs under Article 6(1)(b) GDPR. A data processing agreement with standard contractual clauses protects user data.
3.4 Superwall
Paywall management and conversion analysis uses Superwall, collecting aggregated user interaction data (views, clicks, conversions). Legal basis: Article 6(1)(f) GDPR for legitimate optimization interests.
4. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. All data transmissions are encrypted using industry-standard protocols.
5. Your Rights
Under GDPR, you have comprehensive rights regarding your personal data:
- Access information about your processed data and its purposes
- Request correction of inaccurate information
- Request deletion of your data (subject to legal exceptions)
- Request restrictions on processing
- Receive your data in a portable, structured format
- Withdraw consent at any time
- File a complaint with supervisory authorities
Right to Object
You may object to processing based on interest balancing or for direct advertising purposes.
6. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at: support@swiftmill.io