Privacy Policy
Last updated: October 13, 2025
We are committed to protecting your privacy. This policy explains what information we process, why we do it, and what your rights are. Our goal is to be transparent and empower you to control your data.
1. Our Legal Basis for Processing Your Data
As a company based in Germany, our legal basis for processing data under the EU's General Data Protection Regulation (GDPR) is the performance of a contract. When you ask us to create an audio guide, we process the necessary data to fulfill that service request.
2. What Information is Stored on Your Device
To work properly, the app stores two main types of information securely on your device:
Your Inputs and Creations. The app saves the information you provide to create a guide and the resulting content that is generated for you. Please note, this feature is intended for images of places and objects, not photos that prominently feature identifiable people.
Your Settings. The app also saves your preferences and purchase information to ensure it works as you expect.
3. Data We Share with Third-Party Services
To generate your audio guide, we must share some information with our technology partner, Google, for the use of the Gemini API.
We securely send only the information required for the AI to generate your guide. This data is processed by the Gemini API to create your content, which is then sent back to your device. You can review the terms governing this processing here: Gemini API Terms of Service.
International Data Transfers:
Your data may be transferred to servers outside of the European Economic Area (EEA). We ensure your data is protected during these transfers by relying on legally-approved mechanisms, such as Standard Contractual Clauses (SCCs), as part of our agreement with Google.
4. In-App Purchases & Financial Data
All payments are processed securely by the Apple App Store. We never see, handle, or store your credit card number or other financial details.
5. Your Privacy Rights and Choices
We believe in providing a high standard of privacy to all our users. Your specific rights may vary depending on where you are located.
For Users in the European Economic Area (EEA), UK, and Switzerland:
You have specific rights under the GDPR, including the rights to access, rectify, erase, and object to the processing of your data. You also have the right to lodge a complaint with a supervisory authority. As we are based in Bavaria, our lead supervisory authority is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA).
You can exercise most of these rights directly in the app. For any other requests, please contact us at the email listed in Section 10.
For Users in California (CCPA/CPRA):
This section provides additional details for California residents.
Personal Information We Process: While your content is stored locally, our app processes information that falls into the following categories as defined by the CCPA: Identifiers (such as user preferences), Visual and Audio Information (the images you provide and audio we generate), and Geolocation Data.
"Do Not Sell or Share My Personal Information": We do not "sell" or "share" your personal information as those terms are defined by the CCPA.
Your Rights: You have the right to know what categories of personal information our app processes and the rights to delete and correct your information. You can exercise most of these rights directly by editing or deleting content within the app. For any other requests, please contact us at the email listed in Section 10.
Right to No Retaliation: We will not discriminate against you for exercising your privacy rights.
6. Data Retention
As all the content you create is stored exclusively on your own device, we do not retain a copy of it. The data remains on your device until you choose to delete it using the app's functions.
7. Your Control Over Your Data
You are in full control of your content. The app provides simple functions to delete or reset any of the guide data you have created.
8. App Features
The app integrates with your device's media controls to allow you to listen to guides while the app is in the background and use the playback controls on your device's lock screen.
9. Changes to This Privacy Policy
We may update this policy from time to time. If we make significant changes, we will notify you through the app or by other means, giving you the opportunity to review the changes before they become effective.
10. Contact & Data Controller Information
Name: Liang Zhao
Address: Residenzstraße 11, 80333 Munich, Germany
Contact: For any privacy-related questions, please email us at info@app-wanderlens.com.