Privacy Policy

1. Who is responsible

The controller for the processing described here, within the meaning of Art. 4 (7) GDPR, is:

Finn Eming
Am Huchtert 26
58456 Witten
Germany
cuespot@proton.me

CueSpot is a one-person project and is not required to appoint a data protection officer under Art. 37 GDPR or § 38 BDSG. Write to the address above about anything in this policy.

2. What never leaves your device

CueSpot is built so that the material you care about has nowhere to go. There is no server operated by us, and the app has no login.

• Camera and microphone. The live video and audio are processed on the device to compose the preview and to write the recording. They are never transmitted.
• Recordings. A take is written to a temporary file on the device. When you confirm it, it is saved to your Photos library. When you discard it, the file is deleted. We never receive it, and we have no technical means to.
• Scripts, titles, presets and settings. Stored in the app's own container on the device. They are included in an encrypted iPhone or iCloud backup only if you have backups switched on — that is a setting in iOS, between you and Apple, and not something CueSpot controls.
• Text you share into CueSpot. The share extension writes the shared text into a container shared between the app and the extension on the same device. It is not sent anywhere.

CueSpot does not use iCloud sync, CloudKit or any other cloud storage for your content.

3. Device permissions

iOS asks for each of these separately, and you can withdraw any of them at any time in Settings → Privacy & Security or in Settings → CueSpot on your iPhone.

• Camera — to show the preview and record the picture.
• Microphone — to record the audio of your take.
• Photos (add) — to save a take you have confirmed.
• Photos (read) — to find the takes CueSpot saved so you can play them back inside the app. CueSpot does not browse or index the rest of your library.

Denying a permission limits the matching feature and nothing else. None of this data is transmitted.

4. Purchases

CueSpot Pro is sold through the App Store. Apple handles the payment and is an independent controller for it; Apple's terms and privacy policy apply to that part. We never see your name, address, card details or Apple Account credentials.

To know whether your purchase is active — and to restore it after a reinstall or on another device — the app uses RevenueCat, Inc. (San Francisco, USA) as a processor under Art. 28 GDPR. RevenueCat receives:

• a pseudonymous app user identifier generated on your device;
• the App Store transaction and receipt data for your purchase;
• the product identifier, the storefront country, and the purchase, renewal and expiry dates;
• the app version, the iOS version and the device model.

Legal basis: Art. 6 (1) (b) GDPR — this processing is necessary to provide the paid features you bought.
Transfer: processing takes place in the USA on the basis of the EU standard contractual clauses in RevenueCat's data processing addendum.
Retention: for as long as the entitlement can still be restored, and after that only where a statutory retention period applies.

5. Diagnostics — only if you say yes

CueSpot can report anonymous usage and crash information so that bugs get found and the app gets better. This is off by default. At the end of the introduction the app asks you once, plainly, with the same weight given to both answers; declining and skipping the question have the identical result, and no answer is preselected. You can change your mind at any time under Settings → Diagnostics in the app. Nothing in this section happens unless you have said yes.

Neither of the two services below ever receives the text of your scripts, your script titles, your recordings, a frame of your video, or any audio.

5.1 Product analytics — PostHog

PostHog, Inc., processing on PostHog Cloud EU with servers in Frankfurt, Germany, as a processor under Art. 28 GDPR. What is sent:

• which screens are opened and which features are used, as events without content (for example a preset was saved, never what the preset contains);
• the app version, the iOS version, the device model and the coarse language setting;
• a random identifier generated at installation, which is not linked to your name, your email address or your Apple Account.

IP addresses are not stored. IP capture is disabled by default on PostHog Cloud EU and is not enabled for this project.

5.2 Crash and error diagnostics — Sentry

Not active in the current version. Crash reporting is built into the app but is not switched on for any release yet, so no crash data is being sent to anyone and the corresponding switch does not appear in Settings. It is described here so the description is ready before it is used; it will be dated and announced under section 13 below before the first version that sends anything.

Functional Software, Inc., trading as Sentry, processing in Sentry's EU region with servers in Frankfurt, Germany, as a processor under Art. 28 GDPR. What would be sent when the app crashes or hits an error:

• the stack trace and the error message;
• the screen you were on and the recent in-app actions that led there, as event names without content;
• the app version, the iOS version, the device model, and the available memory and storage;
• the same random installation identifier.

IP address storage is switched off in the project settings and the data scrubber is enabled.

5.3 Legal basis, withdrawal and retention

Legal basis: your consent, Art. 6 (1) (a) GDPR. Storing and reading the installation identifier on your device is covered by that same consent under § 25 (1) TDDDG.
Withdrawal: turn diagnostics off in the app at any time. Withdrawal takes effect immediately and for the future; it does not make the processing that already took place unlawful.
Retention: analytics events are kept for up to 12 months and crash events for up to 90 days, then deleted automatically.
Transfer: both services process this data inside the EU. Both providers are US companies, so access from the USA for support or maintenance cannot be ruled out entirely; that is covered by the EU standard contractual clauses in their data processing agreements.

6. When you email us

Mail sent to cuespot@proton.me is hosted by Proton AG in Switzerland, a country the European Commission has recognised as providing an adequate level of data protection. We process your address and whatever you write in order to answer you: on the basis of Art. 6 (1) (b) GDPR where it concerns the app you bought, and otherwise Art. 6 (1) (f) GDPR — our legitimate interest in replying to people who write to us. Correspondence is deleted once the matter is closed and no retention obligation applies.

7. This website

cuespot.app is a set of static files. It sets no cookies, loads no fonts or scripts from third parties, embeds no videos or maps, and runs no analytics of any kind. There is nothing to consent to, which is why you are not being asked.

The hosting provider writes standard server logs when a page is requested: the IP address, the time, the file requested, the referrer and the browser user agent. This is necessary to deliver the site and to defend it against attacks, on the basis of Art. 6 (1) (f) GDPR. The logs are kept briefly and then deleted.

BEFORE LAUNCH: name the hosting provider here, with its company name and country, state the exact log retention period, and confirm that a data processing agreement under Art. 28 GDPR is in place with it.

8. Who receives data

This is the complete list. There are no others. No data is sold, rented or used for advertising.

Recipient	Purpose	Where
Apple	App Store distribution and payment; independent controller	EU / USA
RevenueCat, Inc.	Checking and restoring your purchase	USA
PostHog, Inc.	Anonymous product analytics, only with consent	Frankfurt, Germany
Functional Software, Inc. (Sentry)	Crash and error diagnostics, only with consent — not active in the current version	Frankfurt, Germany
Proton AG	Email, if you write to us	Switzerland

9. No tracking, no profiling, no automated decisions

CueSpot does not track you across other companies' apps or websites and does not ask permission to, because it has no use for it. It contains no advertising SDK. It builds no profile of you, and it makes no automated decisions producing legal effects within the meaning of Art. 22 GDPR.

10. Your rights

You have the right to:

• access your data (Art. 15 GDPR);
• have it corrected (Art. 16) or erased (Art. 17);
• have processing restricted (Art. 18);
• receive it in a portable format (Art. 20);
• object to processing based on legitimate interest (Art. 21);
• withdraw a consent you have given, at any time (Art. 7 (3)).

One honest caveat about Art. 15 and Art. 17: because there is no account and the diagnostic data is pseudonymous, we normally cannot tell which records belong to you. Art. 11 (2) GDPR covers exactly this case — we are not obliged to obtain additional information purely in order to identify you, and we will not. If you want to be certain your diagnostic data is gone, turn diagnostics off and delete the app; a new identifier is created on the next install. If you can supply the identifier yourself, write to us and we will delete the matching records.

Deleting the app removes everything stored on the device, including your scripts and presets. Recordings you have already saved stay in your Photos library, because they are yours and Photos is not ours to touch.

11. Complaints

You can complain to a supervisory authority, in particular the one where you live, where you work, or where the alleged infringement took place. The authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2–4
40213 Düsseldorf
Germany
ldi.nrw.de

12. Children

CueSpot is not directed at children and is not designed for them. We do not knowingly process the data of anyone under 16.

13. Changes to this policy

If what the app does changes, this page changes with it, and the version and date at the top are updated. Where a change requires your consent, you will be asked in the app before it takes effect. Earlier versions are available on request.