Privacy Policy

Eduard Bruch
Kleinfeld 28c, 21149 Hamburg, Germany
Email: support@eduardbruch.com

This website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. When you visit, technically necessary data is processed (IP address, date and time, requested URL, referrer, browser and operating system) to deliver the pages and keep the service secure. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is reliable and secure delivery of the website. Vercel acts as our processor under an agreement pursuant to Art. 28 GDPR. Server logs are kept only as long as needed for operation and security. Transfers to the USA rely on the European Commission’s adequacy decision of 10 July 2023 (EU-US Data Privacy Framework, Art. 45 GDPR), under which Vercel is certified. More information: Vercel Privacy Policy.

This website sets no cookies, stores nothing on your device and reads nothing from it. It uses no analytics or reach measurement, no advertising trackers, no social media plugins and no external fonts or scripts. Fonts and images are served from this website.

Links to the Apple App Store take you to Apple. Once you reach the App Store, Apple is the controller for any further processing.

If you email us, we process your name, email address and message to answer your request. Our mailbox is operated through an email service provider. The legal basis is Art. 6(1)(b) GDPR where the request concerns a contract or the App, otherwise Art. 6(1)(f) GDPR (our interest in answering). We delete the correspondence once the matter is closed, unless statutory retention duties apply.

No data protection officer has been appointed, as there is no legal obligation to do so. You are not obliged to provide personal data. No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place.

We do not operate any servers that receive, store or process your scripts, recordings or settings. There is no account and no sign-in. Everything you create in the App is stored in the App’s storage on your device. We cannot see what you write or record, and we cannot recover it for you.

• Scripts: the text you type, paste or import, with titles, dates and favorites.
• Recordings: the video files you record, with their thumbnails, length and date.
• Settings: prompter, camera and app preferences.
• Purchase status: whether Pro is active, cached so the App works offline.

The App asks for each permission only when it needs it:

• Camera: to show the camera image and record video while your script scrolls. Video is recorded to your device only.
• Microphone: to record your voice with the video. Audio is recorded to your device only. If you deny it, the App records video without sound.
• Photos (add only): to save a recording to your photo library when you ask for it, or when you turn on automatic saving. The App does not read your photo library.
• Notifications (optional): to remind you the day before a free trial ends. The reminder is scheduled on your device.
• Files: when you import a script, the App reads only the file you pick in the system file picker.

You can change every permission at any time in your device’s Settings app.

When you share a recording or save it to Photos, the App prepares a copy on your device and hands it to the iOS share sheet or to Photos. Where it goes from there (for example AirDrop, Messages or another app) is your choice and is governed by that service. In the free version, the shared copy carries a small “Made with Gazecue” mark; this is added on your device.

Subscriptions and the lifetime purchase are processed by Apple through the App Store. We never receive your payment details, name or Apple Account email.

To check whether Pro is active, the App uses RevenueCat, Inc. (San Francisco, USA). RevenueCat receives anonymous purchase and transaction data from Apple and the App (such as product, purchase date, transaction identifiers and subscription status), a random anonymous app user ID created on your device, and a device identifier (the identifier for vendor). This data is not linked to your identity and is not used for tracking or advertising. RevenueCat does not receive your scripts or recordings.

The App also sends a few anonymous usage markers to RevenueCat under the same random ID, so we can see where people drop out of the setup: the furthest setup step you reached, the use case you picked, whether you skipped the camera permission, where you first saw the upgrade screen, and the date you first saved a script and a take. No script text, titles, recordings, name or email are included.

Legal basis: Art. 6(1)(b) GDPR (performance of the purchase contract) for purchase checks and Art. 6(1)(f) GDPR (our interest in improving the App) for the usage markers. Transfers to the USA rely on the EU-US Data Privacy Framework. See RevenueCat’s Privacy Policy.

The App contains no analytics frameworks, no crash-reporting services, no advertising SDKs and no tracking. Apart from the anonymous setup markers described under “Purchases and RevenueCat”, it does not record how you use it. If you have opted in to share analytics with app developers in iOS settings, Apple may provide us with aggregated, anonymous crash and usage statistics under Apple’s own privacy policy.

We do not sell, rent or trade your data, and we do not share it with anyone. The only third party that receives any data from the App is RevenueCat, as described above.

Your data stays on your device until you delete it. You can delete scripts and recordings in the App at any time. Deleting the App removes all of its data from your device. Copies you saved to Photos or shared elsewhere are not affected. If you back up your device to iCloud or a computer, that backup may contain App data under your control with Apple.

If you are in the European Economic Area, the United Kingdom or Switzerland, you have the following rights:

• Access (Art. 15): request information about your data. Because App data is stored on your device, we hold no App data about you on our systems.
• Rectification (Art. 16): correct inaccurate data.
• Erasure (Art. 17): delete your data in the App or by deleting the App.
• Restriction of processing (Art. 18).
• Data portability (Art. 20): your recordings are standard video files you can share or save at any time.
• Objection (Art. 21): object to processing based on legitimate interest.
• Withdrawal of consent (Art. 7(3)): for example by turning off a permission in Settings.

To exercise any of these rights, contact us at support@eduardbruch.com.

• We do not sell your personal information.
• We do not share your personal information for cross-context behavioral advertising.
• Contact support@eduardbruch.com to exercise your rights.

You have the right to lodge a complaint with a supervisory authority. Our competent authority is: Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Ludwig-Erhard-Str. 22, 7. OG, 20459 Hamburg, datenschutz-hamburg.de.

The App is not directed at children under 13 (COPPA) or under 16 (GDPR). We do not knowingly collect personal information from children.

We may update this policy when the App or the website changes. The date at the top shows the latest version. Material changes will also be mentioned in the App’s release notes.

Eduard Bruch
Kleinfeld 28c, 21149 Hamburg, Germany
Email: support@eduardbruch.com