Privacy Policy App

Last updated: May 2026

1. Data 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 PROG mobile app. For information about visiting our website, please refer to our separate 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 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 & Subscription Management (RevenueCat)

PROG uses RevenueCat (RevenueCat, Inc., USA) to manage purchases and subscriptions. RevenueCat processes the following data: an anonymous user ID (automatically generated, no personal reference), the selected subscription type (e.g. monthly, yearly, lifetime), and the creator code if voluntarily entered. No name, email address, or usage behavior is collected.

Purpose: Subscription management and fair creator compensation. Legal basis: Performance of contract (Art. 6(1)(b) GDPR) and legitimate interest (Art. 6(1)(f) GDPR). Privacy policy: https://www.revenuecat.com/privacy

3.4 Operating System Diagnostics (optional)

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

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 features (local storage): Performance of contract (Art. 6(1)(b) GDPR)

• Local notifications: Performance of contract (Art. 6(1)(b) GDPR)

• Purchase & subscription management: Performance of contract and legitimate interest in fair partner compensation (Art. 6(1)(b) and (f) GDPR)

• Support contact (email): Processing your inquiry (Art. 6(1)(b) GDPR)

• Apple diagnostics: Apple 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 for processing and legal obligations. Purchase data is stored at RevenueCat in accordance with their privacy policy (https://www.revenuecat.com/privacy).

6. Recipients / Disclosure

• No disclosure of your app data to third parties

• RevenueCat (RevenueCat, Inc., USA): Processing of anonymized purchase data under data processing agreement. Standard contractual clauses are in place.

• Support emails are processed by our email provider (data processing agreement)

• No transfer of personal data to third countries through app features beyond RevenueCat as described above

7. Your Rights

Under the GDPR, you have the right to access, rectification, erasure, restriction, data portability, and objection to certain processing activities. You may also lodge a complaint with a data protection supervisory authority (e.g. LfDI Baden-Württemberg, Germany).

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

8. Use by Children and Minors

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

9. Security

The app stores data exclusively on your device. 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/privacy-policy-app