Privacy Policy
Effective: 6 May 2026
This privacy policy applies to the Noggi mobile application (the "App") for iOS, distributed via the Apple App Store. It informs you, pursuant to Articles 13 and 14 of the EU General Data Protection Regulation (GDPR), about the nature, scope, and purposes of any processing of personal data.
The German-language version of this privacy policy is the legally binding original. This English translation is provided for information only.
1. Controller
The data controller within the meaning of the GDPR is:
Markus Freise Bossestraße 15, 33615 Bielefeld, Germany
Email: markus@freise.de
A data protection officer is not required, as the conditions of § 38 BDSG (German Federal Data Protection Act) are not met.
2. Core principle: local processing only
Noggi is a fully local-first app. All data you create while using it — routines, templates, completed tasks, app settings — is stored exclusively on your device in the WebView's local storage (localStorage).
There is no transmission to any server operated by the provider. There is no account, no sign-in, no cloud sync, and no backup performed by the provider. If you delete the App or reset its data in iOS Settings, the data is gone for good.
3. Data we do not collect
The provider does not collect, store, or process any of the following:
- name, email address, or other contact details,
- passwords or sign-in credentials,
- IP address, server logs, cookies,
- location, contacts, calendar, photos, microphone, camera,
- advertising IDs (IDFA) or any device identifier for advertising or tracking purposes,
- usage statistics, telemetry, or crash reports,
- the contents of your routines, task lists, or settings.
The App does not embed any third-party SDKs for analytics, advertising, tracking, or error reporting.
4. Device permissions used by the App
The App makes use of the following device functions — each of them strictly local, with no data leaving the device:
| Function | Purpose | Data flow |
|---|---|---|
| Vibration / haptics | Tactile feedback for "hold to confirm" | none |
| Network status | Display of an offline indicator (informational only; the App works fully offline) | none |
The App does not request access to any sensitive device resources (location, contacts, calendar, photos, microphone, camera, health data).
5. Processing by Apple (App Store)
The App is distributed via the Apple App Store. When you obtain, install, use, and update the App, Apple processes the following data on its own responsibility, as a separate controller:
- your Apple ID,
- device model and operating system version,
- install, update, and crash data,
- where applicable, payment data (for in-app purchases — Noggi currently offers none).
The provider has no control over this processing. Apple's privacy policy applies:
If Apple transfers data to servers in the United States, this is based on the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023) and additionally on the EU Standard Contractual Clauses.
6. Recipients and third-country transfers by the provider
Because the provider does not collect any personal data, there are no transfers to recipients, processors, or third countries.
7. Retention
Locally stored App data remains on your device until you
- delete it from within the App,
- uninstall the App, or
- reset the App's storage in iOS Settings.
There is no retention period at the provider, because no data is stored at the provider.
8. Your rights
In principle, you have the following rights as a data subject under GDPR:
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR)
- Withdrawal of consent (Art. 7(3) GDPR)
Since the provider does not collect or store any personal data, these rights are typically moot in relation to the provider. You may at any time view, export (within the App), or delete your local data; uninstalling the App removes it entirely.
For data Apple processes, please address your rights to Apple directly.
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR): you may complain to a data-protection supervisory authority — the one for your habitual residence or the one for the controller's place of establishment, in our case:
[COMPETENT GERMAN STATE DATA-PROTECTION AUTHORITY]
9. Security of processing
Local App data is stored within the App's sandboxed storage on your iOS device. It is protected by iOS device-level encryption, provided your device has a passcode (Face ID, Touch ID, or numeric passcode) configured.
The provider does not operate any server infrastructure and does not transmit any personal data over networks.
10. Minors
The App is intended for users aged 16 and above. Because the App collects no personal data, no processing of minors' data within the meaning of Art. 8 GDPR takes place. The Apple App Store provides additional age ratings and Family Sharing features.
11. Changes to this privacy policy
We update this privacy policy if legal requirements change or if we add features that involve data processing. The current version is always available in the App under "Settings → Privacy"; the "Effective" date above marks the applicable version. For substantive changes, you will additionally be notified at the next launch of the App.
12. Contact
For questions about data protection or to exercise your rights, contact the controller at:
Email: markus@freise.de