Privacy Policy — Aemble

In short

Aemble collects nothing. It has no account, no server, no analytics, no advertising, no third-party code, and it makes no network connections. Nothing you do in the app reaches us, because nothing you do in the app leaves your device. The only personal data we ever handle is what you choose to put in an e-mail to us.

1 — Who is responsible

TWELVE DEGREES BELOW UG (haftungsbeschränkt)

c/o IP-Management #11692
Ludwig-Erhard-Straße 18
20459 Hamburg
Germany

Managing Director: Caroline Victoria Steinigk
Commercial register: HRB 200746, Amtsgericht Hamburg, Dept. 66
E-mail: hello@twelvebelow.app
Phone: +49 156 79828617

We have not appointed a Data Protection Officer; we are not required to.

Full legal notice: twelvebelow.app/impressum (German, legally prevailing) · English translation

2 — What the app collects: nothing

Aemble contains no networking code. There is no account system, no login, no server of ours that it talks to, no analytics or crash-reporting service, no advertising identifier, and no third-party SDK of any kind — the app is built entirely from Apple's own frameworks.

As a result there is no profile of you, no session history, no record of which techniques you use or when, and nothing for us to sell, share, disclose or lose. Our App Store privacy label is Data Not Collected across every category.

3 — What is stored on your device

The app remembers a small set of preferences so it behaves the way you left it. They live in the app's own storage on your iPhone or iPad. They are never transmitted, never synced — no iCloud, no CloudKit, no sync between your devices — and never seen by us.

There is no timestamp, no counter and no history among them. The app cannot tell you how often you have breathed, because it does not know.

Deleting the app removes all of it. There is nothing on our side to delete, because nothing ever arrived.

4 — Permissions and sensors: none

Aemble asks for no permissions and reads no sensors. It does not use HealthKit and does not measure your heart rate or anything else about your body. It has no access to your microphone, camera, location, contacts, photos or notifications, and it shows no App Tracking Transparency prompt, because it does not track.

5 — The one connection out

The app's Impressum screen has a Full legal notice button that opens twelvebelow.app in Safari. Safari makes that request, under Apple's terms and ours for the website; the app itself still makes no connections. Our website's own privacy policy applies once you are there.

6 — Siri, Shortcuts and Control Center

Aemble offers App Intents and an aemble:// link so you can start a session from Siri, the Shortcuts app, the Action Button or a Control Center control. Apple's system software handles all of that on your device. We receive nothing from it, and it changes nothing about what the app stores.

7 — Required-reason API declarations

Apple requires apps to declare certain system APIs and the reason they are used. Both targets in this release ship a privacy manifest declaring:

• ·User defaults (reasons CA92.1 and 1C8F.1) — to read and write the app's own preferences listed in section 3 (CA92.1), and the copy in the shared container that the widgets read (1C8F.1).

Tracking is declared as false, and the collected-data-types and tracking-domains lists are empty.

8 — Buying the app, and what Apple tells us

Aemble is a paid app with no subscription. The purchase happens entirely between you and Apple; we never see your name, e-mail address, payment details or Apple Account. Apple's handling of that transaction is governed by Apple's Privacy Policy.

As the store operator, Apple gives every developer aggregated, anonymised reports about their app — downloads, sales, active devices, retention, crash reports, performance metrics, App Store search terms, and the reviews and TestFlight feedback people choose to send. We read those. They are compiled by Apple from data Apple collects, they contain no information that identifies you to us, and we have no way to connect any of it to a person or to anything you do inside the app.

We deliberately run no analytics of our own — not even anonymous, aggregated usage counts. Because we collect nothing, there is no analytics opt-out, no consent banner and no cookie in the app; there is nothing to opt out of.

9 — If you write to us

E-mail is the only way to reach us, and the only situation in which we process personal data about you.

• ·What we process: your e-mail address, your name if you give it, and whatever you put in the message.
• ·Why: to read your message and answer it.
• ·Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in responding to enquiries; and where your message concerns a purchase or a contract with us, Art. 6(1)(b) GDPR.
• ·Who else is involved: our business e-mail is operated using Google Workspace, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which processes the message on our behalf as a processor under Art. 28 GDPR. A data processing agreement is in place. Data may be transferred to servers outside the European Union; for such transfers Google relies on the EU Standard Contractual Clauses and its certification under the EU–US Data Privacy Framework.
• ·How long: we keep correspondence for as long as it takes to deal with the matter, and afterwards only where statutory retention periods require it.

We do not use your address for anything else, and there is no newsletter.

10 — Your rights

Under the GDPR you have the right to access the personal data we hold about you (Art. 15), to have it corrected (Art. 16) or erased (Art. 17), to restrict its processing (Art. 18), to receive it in a portable form (Art. 20), and to object to processing based on legitimate interest (Art. 21). In practice this can only ever concern e-mail correspondence, since the app itself gives us nothing.

Write to hello@twelvebelow.app and we will deal with it.

You also have the right to complain to a supervisory authority. Ours is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22, 20459 Hamburg, Germany

11 — Changes to this policy

If the app ever changes what it does with data, this page, the app's privacy screen and the App Store privacy label change with it, and the date at the top of this page is updated. We have no way to notify you, because we have no way to reach you.