App Privacy Policy

Last updated: May 2026

1. Controller

Levin Köhler (sole proprietor) Talstr. 13/1, 74579 Fichtenau, Germany. Email: contact@prog-app.com / support@prog-app.com

2. Purpose of this policy

This policy describes the processing of personal data when using the mobile app PROG. Information about visiting our website can be found separately in the website privacy policy.

3. What data does PROG process?

3.1 Local content data (on your device only)

Journal entries, goals, tasks, routines, learning progress, and app settings are stored exclusively locally on your device. There is no server upload, no cloud sync, and no developer access.

3.2 Notifications

PROG can schedule local reminders on your device. No push tokens are transmitted and no data is sent to any server.

3.3 Purchase and subscription management (RevenueCat)

PROG uses RevenueCat (RevenueCat, Inc., USA) to handle purchases and subscriptions. RevenueCat processes the following data: an anonymous user ID (automatically generated, not linked to your identity), the type of subscription chosen (e.g. monthly, yearly, lifetime), and a creator code if voluntarily entered. No names, email addresses, or usage habits are collected.

Purpose: subscription management and fair creator compensation. Legal basis: performance of the usage agreement (Art. 6(1)(b) GDPR) and legitimate interest (Art. 6(1)(f) GDPR). Privacy policy: https://www.revenuecat.com/privacy

3.4 Operating system diagnostic data (optional)

If you have enabled sharing of diagnostic data with Apple in your iOS settings, Apple may collect anonymous stability metrics. We do not receive any personal raw data. Apple alone is responsible for this processing.

No cookies, no advertising IDs, no app tracking. The only external SDK is RevenueCat – used exclusively for purchase and subscription management.

4. Purposes and legal bases

  • App functionality (local storage): performance of the usage agreement (Art. 6(1)(b) GDPR)
  • Local notifications: performance of the usage agreement (Art. 6(1)(b) GDPR)
  • Purchase and subscription management: performance of the usage agreement and legitimate interest in fair partner compensation (Art. 6(1)(b) and (f) GDPR)
  • Support contact (email): handling your inquiry (Art. 6(1)(b) GDPR)
  • Apple diagnostic data: Apple alone is responsible; our legitimate interest is limited to anonymized stability information (Art. 6(1)(f) GDPR)

5. Storage location and duration

All content data remains on your device until you delete it or uninstall the app. Support emails are retained only as long as necessary to handle your request and to meet legal obligations. Purchase data is stored by RevenueCat according to their privacy policy (https://www.revenuecat.com/privacy).

6. Recipients / disclosure

  • No disclosure of your app data to third parties
  • RevenueCat (RevenueCat, Inc., USA): processes anonymized purchase data as a data processor. Standard Contractual Clauses are in place.
  • Support emails are processed by our email provider (data processor)
  • No transfer of personal data to third countries through app functionality, except RevenueCat as described above

7. Your rights

Under the GDPR, you have the right to access, rectify, erase, restrict processing, receive a copy of your data (data portability), and object to certain processing. You may also lodge a complaint with a data protection supervisory authority (e.g. LfDI Baden-Württemberg).

Contact for privacy matters: contact@prog-app.com

8. Use by children and teenagers

The PROG app can generally be used by people of any age. We do not collect personal data via any server and do not perform age verification or profiling. Parents or guardians should make sure children handle their personal entries responsibly.

9. Security

The app stores data exclusively locally. Please protect your device (e.g. passcode / Face ID) and use encrypted device backups regularly.

10. Changes

This privacy policy may be updated if features or legal requirements change. The current version is always available at https://prog-app.com/en/datenschutzerklarung-app