Fyle - Privacy Policy - Manuel Fessen

1. Introduction

This privacy policy informs you about the processing of personal data when using the fyle app in accordance with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

2. Controller

The controller within the meaning of data protection laws is:

Manuel Fessen c/o Secato GmbH Ungelsheimer Weg 7 40472 Düsseldorf Email: litze.pasten.0i@icloud.com

3. Types of Data Processed

We process the following categories of personal data:

Document contents (scanned documents, OCR results, AI analyses):

Document images and PDFs are stored exclusively on your device. When iCloud synchronization is activated, storage occurs in your personal iCloud.
Text extracted from documents (OCR text) is first processed locally on your device.
If you enable AI analysis on devices that do not support Apple Intelligence on-device processing, filtered OCR text may be sent to OpenAI to generate titles, categories, and summaries. Original document images and PDFs are not sent to OpenAI.
You can configure a privacy blacklist to filter sensitive words from OCR text before supported AI processing steps.
On devices that support Apple Intelligence on-device processing, AI analysis can run locally on your device and document content does not leave your device for that analysis.
AI analysis results are stored on your device and, when synchronization is activated, in your personal iCloud.

We as the provider have no access to documents stored on your device or in your personal iCloud. The security of data stored in iCloud is subject to Apple Inc.’s security standards and your own account security.

Additional data we process:

Technical information (for example device type, operating system version, app version)
Performance and diagnostics data (for example crashes, errors, latency, and feature usage)
Subscription data (for example subscription status and App Store transaction-related information)

4. Purpose of Data Processing

We process personal data for the following purposes:

Providing and improving the app’s core functionality
Processing subscriptions and subscription status
Measuring app performance, stability, and feature quality
Providing customer support
Creating document titles, categories, and summaries using on-device AI or third-party AI services, depending on device capabilities and your settings

5. Legal Basis for Processing

The legal basis for processing personal data is:

Article 6(1)(b) GDPR (performance of contract) for core app functionality
Article 6(1)(a) GDPR (consent) for optional AI analysis features that send filtered OCR text to OpenAI and for optional analytics where consent is requested
Article 6(1)(f) GDPR (legitimate interest) for necessary technical operation, fraud prevention, and limited performance monitoring where applicable

We share data with the following third parties:

Apple Inc.: iCloud synchronization and, on supported devices, Apple Intelligence on-device processing frameworks. For Apple Intelligence on-device processing, document content remains on your device.
RevenueCat Inc.: Subscription management and entitlement status.
OpenAI: On devices without Apple Intelligence on-device processing support, filtered OCR text extracted from your documents may be sent to OpenAI to generate titles, categories, and summaries, but only after you enable the feature and grant permission. Original images and PDFs are not sent to OpenAI.
PostHog EU: Performance and product analytics, such as app version, device information, feature usage, crashes, errors, and latency. We do not send full document images, PDFs, full OCR text, or full AI prompt/output content to PostHog for this purpose.

Where third parties process personal data on our behalf or receive data through your use of optional features, we rely on providers that commit to appropriate data protection safeguards and security measures.

7. Data Retention

We retain personal data only as long as necessary for the purposes stated in this policy:

Subscription data: retained for the duration of the subscription and as required for legal, tax, and accounting obligations
Performance and analytics data: retained only as long as needed for diagnostics and product improvement, subject to the applicable provider retention settings
Documents and AI analysis results: stored on your device until manually deleted and, if iCloud sync is enabled, in your personal iCloud until removed by you
Filtered OCR text sent to OpenAI: subject to OpenAI’s applicable retention policies and your use of the feature

8. Your Rights

Under GDPR, you have the following rights regarding your personal data:

Right to access (Article 15 GDPR)
Right to rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object (Article 21 GDPR)

To exercise these rights, please contact us at the email address provided in section 2.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

Local on-device processing where available
Data minimization for AI and analytics features
Access controls and authentication mechanisms
Use of established third-party providers with contractual and technical safeguards

10. Changes to This Policy

We may update this policy from time to time. The current version is always available in the app settings.

11. Contact Information

For any questions regarding this privacy policy, please contact: