App Privacy Policy
This privacy policy explains how personal data is processed in connection with the My Iceberg app. It is intended as the privacy policy URL for app store listings and for direct access by users.
1. Controller
Robert Hehn
Rüdesheimer Straße 65
55545 Bad Kreuznach
Germany
Phone: +49 176 41628580
E-mail: neuropfad@protonmail.com
2. General information
The app is designed to provide digital self-help, reflection and information features. Personal data is processed only to the extent necessary to provide app functions, save your settings and, where applicable, enable user-initiated sharing or store-related purchase functions.
At the current app stage, the app is designed primarily for local on-device use. This means that user-generated content is generally intended to remain on the device unless a specific feature explicitly triggers sharing, an external link, or a store-related transaction.
3. Data processed inside the app
Depending on the functions you use, the app may process content and settings entered or created by you inside the app. This may include, in particular, notes, reflections, journal entries, self-observation entries, selected language, theme and other app settings.
As a rule, this information is stored locally on your device in order to make the app usable and to preserve your content and preferences between sessions.
The app does not require the creation of a user account for basic local use unless this is explicitly introduced and disclosed in a future version.
4. No processing without user action
The app does not disclose your content to third parties merely because you open or use it. Any disclosure to third-party apps or services requires a corresponding technical function and, where applicable, your active use of that function.
5. Share function
The app currently offers user-initiated sharing only for selected Impulse content and for the generated Iceberg view. If you actively use that share function, the selected content or generated image may be exported temporarily and transferred to the app or service chosen by you, for example via WhatsApp, e-mail or another target app offered by your device. In that case, further processing by the selected target app or service takes place under the responsibility of that respective provider.
6. External links and deep links
If the app opens external websites, store pages or app/deep links, the respective target provider may process technical connection data such as your IP address or device-related request data. The same applies where a link or deep link is used to call up app content or related web content.
7. Purchases via app stores
If paid functions or digital content are offered via app stores such as Google Play, purchase processing is carried out by the respective store operator. In that context, the relevant platform provider may process billing, transaction and device-related data under its own responsibility.
The app itself may process technical purchase status information only to the extent required to unlock or restore paid content.
8. Data sharing and third parties
Personal data is not sold. Data is only shared with third parties where this is technically necessary for the chosen function, for example with the selected target app in a share flow or with the relevant app store provider in connection with purchases, restores or store validation.
If third-party providers process data under their own responsibility, their own privacy notices and terms may apply in addition.
9. Secure handling of data
Personal and app-related data is intended to be handled with appropriate technical and organizational safeguards. Where data is transmitted to third-party services, this is intended to happen only over the technical channels provided by the operating system, the app store, or the selected target app/service.
Nevertheless, no transmission over the internet or between apps can be guaranteed to be completely risk-free. Users should therefore avoid sharing sensitive content with third-party apps unless this is intended.
10. Legal basis
Personal data is processed on the basis of Art. 6(1)(b) GDPR where processing is necessary to provide the requested app functions. Processing may also take place on the basis of Art. 6(1)(f) GDPR where there is a legitimate interest in ensuring technical stability, usability and security of the app. If a specific function requires consent, the processing takes place on the basis of Art. 6(1)(a) GDPR.
11. Storage period and deletion
Data stored locally in the app remains on your device until you delete it yourself, remove the app or reset the relevant app data. Where legal retention obligations apply to individual communication or transaction processes, statutory retention periods remain unaffected.
If you contact me directly regarding stored communication data or legal inquiries, deletion may only take place insofar as there are no statutory retention duties or overriding legal reasons to keep the data.
12. Your rights
- Right of access under Art. 15 GDPR
- Right to rectification under Art. 16 GDPR
- Right to erasure under Art. 17 GDPR
- Right to restriction of processing under Art. 18 GDPR
- Right to data portability under Art. 20 GDPR
- Right to object under Art. 21 GDPR
- Right to lodge a complaint with a supervisory authority under Art. 77 GDPR
Privacy-related inquiries regarding My Iceberg can be sent to neuropfad@protonmail.com.
13. Supervisory authority
Landesbeauftragter für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz
Postfach 30 40
55020 Mainz
Germany
E-mail: poststelle@datenschutz.rlp.de
14. German reference version
Eine deutsche Fassung dieser Datenschutzhinweise für die App: App-Datenschutz (DE)
15. Version
Version: 2026-03-20