Privacy Policy
Last updated: December 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 specific information with our technology partners. We securely send only the information required for the AI to generate your content.
Google (Gemini API): We use the paid version of Google's Gemini API to analyze your inputs and generate the text content of your guide.
No Model Training: Because we use the paid service, Google does not use your data (images or text) to train their AI models or improve their products.
Data Retention: Google processes your data transiently to generate the response and may retain it for a limited period solely to detect abuse or violations of their Prohibited Use Policy.
You can review the specific terms governing this "Paid Service" processing here: Gemini API Paid Services Terms.
ElevenLabs: We use ElevenLabs to convert the generated text into spoken audio. We send the text content of your guide to the ElevenLabs API, which processes it to create the audio narration delivered to your device. You can review their privacy practices here: ElevenLabs Privacy Policy.
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 agreements with our technology partners.
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.