Privacy Policy

1. Controller

Responsible for data processing under the EU General Data Protection Regulation (GDPR) is:

Dennis Donner
Eduard-v-Winterstein-Straße 11
14480 Potsdam, Germany
Email: app-support@donner.io

For any privacy question, write to the email address above. A data protection officer has not been appointed, as there is no legal obligation to do so.

2. In short

3. Data stored on your device

Everything you create in PinPoints is stored in a local database on your iPhone or iPad:

• places and stops with name, address and coordinates,
• trips, their order and travel modes,
• favorites, tags and notes,
• your settings (for example unit and map style),
• downloaded offline map areas.

I have no access to this data. It is not synced to any server. If you delete the app, this data is deleted as well. Whether it is included in your iPhone backup (iCloud or computer) depends on your device settings; such backups are governed by Apple’s privacy policy.

4. Location

PinPoints asks for access to your location only while you use the app (“While Using the App”). The app never requests background (“Always”) access. Your location is used to show where you are on the map, to centre the map and to use your current position as a starting point. PinPoints does not determine your location while the app is in the background.

Your position is processed on your device and is not sent to me or to the analytics providers. When the app calculates a route that starts at your position, the coordinates of that leg are sent to the routing service (section 5).

The permission is voluntary. You can use PinPoints without it and change your choice at any time under Settings → Privacy & Security → Location Services → PinPoints.

Legal basis: your consent via the system dialog, Art. 6(1)(a) GDPR, and the performance of the app’s functions, Art. 6(1)(b) GDPR.

5. Search, maps and routing

To find places, draw maps and calculate distances, the app sends the data needed for each request directly from your device to the following services. Your IP address is technically transmitted with every request.

• Apple Maps (MapKit). Search terms when you search for a place, coordinates for address lookups, start and end points of each leg for route calculation, and the map area for route previews. Provider: Apple (privacy policy).
• OpenRouteService. If Apple Maps finds no route for a leg and you have unlocked the extended features by in-app purchase, the app asks OpenRouteService for that leg. Only the start and end coordinates of the leg and the travel mode are transmitted. The same applies if you choose OpenRouteService as routing service in the settings. Provider: HeiGIT gGmbH, Heidelberg, Germany (privacy policy).
• OpenFreeMap. Map tiles for offline map downloads and for the offline map view are loaded from OpenFreeMap. The server receives your IP address and the requested map area. Provider: Hyperknot Software Kft., Hungary (privacy policy).
• Opening in Apple Maps or Google Maps. If you choose to open a place or a route in another app, PinPoints passes the coordinates to that app. From then on, the privacy policy of that app applies (Apple: privacy policy; Google: privacy policy).

If no route can be found, PinPoints falls back to the straight-line distance, calculated on your device.

Legal basis: performance of the functions you use, Art. 6(1)(b) GDPR.

6. Contacts

You can add a place from a contact’s address. For this, PinPoints opens the system contact picker. The app does not get access to your address book; it only receives the address of the contact you select. That address is stored as a place on your device only.

7. Usage analytics and crash reports

To understand which features are used and to fix errors, PinPoints uses the following services. They receive pseudonymous data only: no names, no email addresses, no contacts, no place names and no coordinates.

• Amplitude (data storage in the EU). The app has been configured so that Amplitude does not record your IP address, the vendor identifier (IDFV), your mobile carrier, or a city or region derived from your IP address. Recorded are: app start and session events; which features and settings you use; purchase events (product, amount, currency and transaction number); whether extended features are unlocked and which subscription product and period you have; which paywall variant was shown; device model, operating system and app version; the language and region set on your device; whether you allowed location access and notifications (the app only reads this status and does not ask for notification permission); the number of saved trips and places; the install date and the source of the download (see Apple Search Ads below). The events are linked to a random pseudonymous ID, which is the same ID that RevenueCat uses (section 8). Provider: Amplitude, Inc. (privacy policy).
• Google Firebase: Firebase Analytics (automatically recorded events such as first launch, sessions, app updates and in-app purchases, linked to a random app instance ID; Google derives an approximate location at country or region level from your IP address), Firebase Crashlytics (crash reports with device model, system version, a random installation ID and the technical crash trace; release versions only) and Firebase Performance Monitoring (load times of the app and duration of network requests, recorded with the server address and path but without content). Provider: Google (privacy policy, Firebase privacy information).
• Apple Search Ads attribution. On first launch, the app asks Apple via the AdServices interface whether it was installed through an Apple Search Ads campaign. Apple returns campaign information without any personal identifier. This does not use the advertising identifier and does not require tracking permission. Provider: Apple (privacy policy).

Legal basis: the legitimate interest in a stable, well-working app and in understanding which features matter, Art. 6(1)(f) GDPR. Storing and reading these identifiers on your device is necessary for this service you requested, § 25(2) no. 2 TDDDG.

Your right to object: you can object to this processing at any time, without giving reasons, by email to app-support@donner.io. The app currently has no switch for this; I will then delete the data linked to your pseudonymous ID. To find it, include the RevenueCat ID from a support email (section 9) in your message.

8. In-app purchases

Purchases are processed entirely by Apple through the App Store. I do not receive your name, Apple ID or payment details. To check which features you have unlocked, the app uses RevenueCat. RevenueCat receives a random, anonymous app user ID, the purchase receipts from Apple and basic device information. The app also passes the pseudonymous Amplitude IDs to RevenueCat so that purchase and usage statistics can be matched. Provider: RevenueCat, Inc. (privacy policy).

You manage and cancel purchases in the settings of your Apple ID.

Legal basis: performance of the contract, Art. 6(1)(b) GDPR; for matching statistics, the legitimate interest in understanding how purchases relate to app usage, Art. 6(1)(f) GDPR. Purchase records must be kept for the statutory retention periods under commercial and tax law, Art. 6(1)(c) GDPR.

9. Ratings and support emails

Ratings: from time to time the app may ask whether you want to rate it. The dialog is shown by Apple; I do not learn whether you rated or what you wrote, unless you publish a review in the App Store.

Support: if you contact support from the app’s settings, your email app opens with a prepared message. It contains technical information to help with your request: app name, version and build, bundle ID, device model, device name, operating system and version, screen size and scale, language, region, time zone, device memory, your RevenueCat app user ID and a timestamp. You see this text before sending and can change or delete it. Your email and its content are used only to answer your request and delete it when the request is settled, unless statutory retention obligations apply.

Legal basis: Art. 6(1)(b) GDPR for requests about the app, otherwise Art. 6(1)(f) GDPR.

10. Legal bases at a glance

• Art. 6(1)(a) GDPR – consent: location access (via the iOS permission dialog). You can withdraw consent at any time with effect for the future (Art. 7(3) GDPR).
• Art. 6(1)(b) GDPR – contract: search, maps, routing, in-app purchases, support.
• Art. 6(1)(c) GDPR – legal obligation: retention of purchase records.
• Art. 6(1)(f) GDPR – legitimate interests: usage analytics, crash reports, performance measurement, attribution, website server logs.

11. Recipients

Personal data is not sold and not shared for advertising. Data is passed only to the following recipients, and only to the extent described above. Processors act on the controller’s instructions under a data processing agreement (Art. 28 GDPR).

12. Transfers to third countries

Some recipients are based in the USA or may access data from there (Apple, Amplitude, Google, RevenueCat). Where a recipient is certified under the EU-U.S. Data Privacy Framework, the transfer is based on the European Commission’s adequacy decision (Art. 45 GDPR). Otherwise it is based on the EU standard contractual clauses (Art. 46(2)(c) GDPR). Amplitude stores the app’s data in its EU data centre.

13. How long data is kept

• Data on your device: until you delete it in the app or delete the app.
• Usage analytics: only as long as needed for the purposes in section 7, within the retention settings of Amplitude and Firebase; immediately on a justified objection.
• Crash reports (Crashlytics): 90 days.
• Support emails: until your request is settled, unless statutory retention obligations apply.
• Purchase records: for the statutory retention periods (up to ten years).
• Website server logs: only as long as needed for security and error analysis, then deleted.

14. Your rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)). To exercise your rights, write to app-support@donner.io. Because the app has no account and your identity is not known, your RevenueCat ID from a support email may be needed to find data linked to you.

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent authority is: Die Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg, Stahnsdorfer Damm 77, 14532 Kleinmachnow, Germany.

15. Children

PinPoints is not directed at children under 16. Personal data of children is not knowingly processed. If you believe a child has sent personal data, please write to the email address in section 1 and it will be deleted.

16. Permissions and how to change them

• Location (while using the app): optional; change under Settings → Privacy & Security → Location Services → PinPoints.
• Contacts: no permission needed; the system picker only hands over the contact you select.

PinPoints does not request access to your camera, microphone, photos, health data, Bluetooth, notifications or tracking.

17. Security

All connections from the app to the services named above use encrypted HTTPS. Data on your device is protected by the iOS data protection of your device and your passcode. No method of transmission or storage is completely secure, but appropriate technical and organisational measures are taken (Art. 32 GDPR).

18. This website

When you visit pinpoints.donner.io, the web server automatically records technical access data in log files: IP address, date and time, the page requested, the referring page, browser and operating system, status code and amount of data transferred. This is needed to deliver the website and to keep it secure. Legal basis: Art. 6(1)(f) GDPR.

• The website sets no cookies and uses no analytics or tracking.
• It loads no fonts, scripts or images from third parties.
• If you switch the language, your choice is stored in your browser’s local storage under the key pinpoints-lang. It never leaves your browser; you can delete it in your browser settings.
• Links to the App Store take you to Apple; from there, Apple’s privacy policy applies.

19. Changes to this policy

This policy is updated when the app or the law changes. The current version is always available on this page; the date at the top shows when it was last changed.