⚠️ Draft for legal review. This policy describes the planned data processing of the Factucate app and website. Before publication, all [placeholders] must be filled in and the text must be finalised by a qualified person (privacy counsel), in particular the sections on advertising, analytics and processors.
The controller within the meaning of the GDPR is:
Simpdi Media LLC
1178 Broadway, 3rd Floor #3331
New York, NY 10001, USA
Email: legal@factucate.com
Factucate is built to need as little data as possible. The app works offline, your content lives on your device first, and we do not sell data. Accuracy and trust are the core of this brand, and that includes how we handle your data.
You can create an account with email and password, with “Sign in with Apple” or with “Sign in with Google”. In doing so we process:
The legal basis is the performance of the user agreement (Art. 6 (1) (b) GDPR). When you use “Sign in with Apple” or “Sign in with Google”, the respective provider learns that you are signing in to Factucate; their own privacy policies additionally apply.
Which facts you save, which categories you prefer and your review progress are stored so the app works and your collection stays with you across devices. This data lives on your device first and is synced with your account. Legal basis: Art. 6 (1) (b) GDPR.
Our backend services (database, authentication) run on Supabase. Data is hosted in a data centre within the European Union (region Frankfurt, Germany). A data processing agreement pursuant to Art. 28 GDPR is or will be in place with the provider. [Confirm provider details and DPA before publication.]
If you opt in, we send you one daily reminder as a push notification. Delivery runs through Apple’s push service (APNs). You can disable notifications at any time in your device’s system settings. Legal basis: your consent (Art. 6 (1) (a) GDPR).
Premium subscriptions and the one-time purchase are handled by Apple’s App Store. Apple processes the payment data; we never receive card or bank details, only the information that a valid purchase exists. Apple’s privacy policy applies.
Short version: we do not track you. Not in the app, not on this website.
Two things do reach us, and we would rather name them than hide them:
If we ever introduce usage analytics, we will ask for your consent beforehand (Art. 6 (1) (a) GDPR), name the specific service here and update this section before it goes live. Until then, the statements above apply exactly as written.
When you visit this website, the hosting provider processes technically necessary data (IP address, time, page requested, browser type). The legal basis is our legitimate interest in operating the site securely (Art. 6 (1) (f) GDPR). [Add the website hosting provider.]
If you join the waitlist, we process your email address solely to notify you once about the launch. The legal basis is your consent (Art. 6 (1) (a) GDPR), which you can withdraw at any time by writing to us. [If a newsletter service is used, name it here.]
We store your account data for as long as your account exists. If you delete your account, the associated data is permanently removed (see section 7). Statutory retention obligations remain unaffected.
Your data is only shared with the processors named above (e.g. hosting) under contracts pursuant to Art. 28 GDPR, with Apple/Google in the course of sign-in and purchases, or where we are legally required to do so. We do not sell your data.
Under the GDPR you have the right to:
Deleting your account: You can delete your account and all associated data at any time directly in the app (Settings → Account → Delete account) or contact us at legal@factucate.com.
You also have the right to lodge a complaint with a data protection supervisory authority.
Transfers between the app, the website and our servers are encrypted (TLS). Access to account data is protected by database-level access rules, so each person can only see their own data.
We will update this policy whenever the processing changes. The current version is always available here.