Privacy Policy

1. Data Controller

The data controller responsible for processing your personal data is:

Malupp GmbH
Eystrasse 52
3427 Utzenstorf
Switzerland
[email protected]

For all privacy-related enquiries, including exercising your data subject rights, please contact us at the above address or email.

2. Data We Collect

We collect the minimum data necessary to provide and improve our Services. Depending on the Service you use, this may include:

Category	Examples	Source
Contact data	Email address, name	Provided by you (e.g. contact form, in-app support)
Account data	Username, password (hashed), profile information	Provided by you at registration
Usage data	Feature interactions, session duration, screen views	Automatically collected via analytics tools
Technical data	App version, operating system, device type, language	Automatically collected
Purchase data	Subscription status, purchase history	Received from Apple / Google (no payment card data)
User-generated content	Data you create or import within the app	Provided by you

We do not knowingly collect sensitive personal data (e.g. health, racial or ethnic origin, political opinions) unless explicitly required by a specific Service and disclosed separately at that point.

3. How We Use Your Data

We process your personal data for the following purposes and on the following legal bases:

Purpose	Legal Basis (revFADP / GDPR)
Providing and operating our Services	Performance of a contract (Art. 31 revFADP / Art. 6(1)(b) GDPR)
Responding to enquiries and support requests	Legitimate interest / performance of a contract
Improving and developing our Services through analytics	Legitimate interest (Art. 31 revFADP / Art. 6(1)(f) GDPR)
Processing in-app purchases and subscriptions	Performance of a contract
Sending important service-related communications	Legitimate interest / performance of a contract
Compliance with legal obligations	Legal obligation (Art. 31 revFADP / Art. 6(1)(c) GDPR)
Sending marketing communications (if opted in)	Consent (Art. 31 revFADP / Art. 6(1)(a) GDPR)

4. Analytics

Our website uses Simple Analytics, a privacy-first analytics service that does not use cookies and does not collect personally identifiable information. Simple Analytics is compliant with the revFADP and GDPR. No IP addresses are stored; only aggregate, anonymised statistics are generated. For more information, see simpleanalytics.com/privacy.

Individual apps may use additional analytics tools (such as Apple's App Store Connect analytics or Firebase Analytics). Where such tools are used, this will be disclosed in the app-specific privacy notice presented in the respective app store listing.

5. Data Sharing and Processors

We do not sell your personal data. We may share data with trusted third parties who act as data processors on our behalf, strictly to support the delivery of our Services:

• Apple Inc. — App Store distribution, in-app purchase processing, and optional analytics (Apple App Store Connect). Privacy policy: apple.com/legal/privacy
• Google LLC — Play Store distribution, in-app purchase processing, and optional Firebase services. Privacy policy: policies.google.com/privacy
• Simple Analytics — Privacy-first website analytics. Privacy policy: simpleanalytics.com/privacy
• Cloud hosting providers — Server infrastructure for our web services, located within Switzerland or the EEA.

We may also disclose your data if required by law, court order, or to protect the rights, property, or safety of Malupp GmbH, our users, or the public.

6. International Data Transfers

Some of our third-party service providers are based outside Switzerland and the European Economic Area. Where this occurs, we ensure that adequate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission or equivalents recognised under Swiss law. You may request details of such safeguards by contacting us.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law:

• Account data — retained for the duration of your account plus up to 30 days after deletion, then purged.
• Contact/support correspondence — retained for up to 3 years for legitimate interest and legal purposes.
• Financial/purchase records — retained for 10 years as required by Swiss commercial law (OR Art. 958f).
• Analytics data — aggregated and anonymised; no individually identifiable retention period applies.

8. Cookies and Tracking Technologies

Our main website (malupp.com) does not use cookies or tracking technologies that process personal data. Simple Analytics operates without cookies.

Individual apps may use local storage or similar device-storage mechanisms to save your preferences or session state. No cross-app or cross-site tracking is performed by Malupp GmbH.

9. Your Rights

Under the revFADP and, where applicable, the GDPR, you have the following rights regarding your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to erasure — request deletion of your data, subject to legal retention obligations.
• Right to restrict processing — request that we limit how we use your data in certain circumstances.
• Right to data portability — receive your data in a structured, machine-readable format (where processing is based on consent or contract).
• Right to object — object to processing based on legitimate interest, including for direct marketing.
• Right to withdraw consent — withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before fulfilling your request.

If you believe your data is being processed unlawfully, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch, or with the supervisory authority in your EU member state of residence (if applicable).

10. Children's Privacy

Our Services are not directed at children under 13. We do not knowingly collect personal data from children under 13. If you become aware that a child under 13 has provided us with personal data without parental consent, please contact us at [email protected] and we will delete it promptly.

11. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include encrypted data transmission (TLS), access controls, and regular security reviews. However, no system is completely secure, and we cannot guarantee absolute security of data transmitted over the internet.

12. Links to Third-Party Sites

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies before providing any personal data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where appropriate, by in-app notification or email. We encourage you to review this Policy periodically.

14. Contact

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

Malupp GmbH
Eystrasse 52
3427 Utzenstorf
Switzerland
[email protected]