Privacy Policy/Datenschutzerklärung
Last updated: May 2026
1. Controller
The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:
Jona Fengler
JF Software
Zietenring 11
65195 Wiesbaden
Germany
E-Mail: step2scrollapp@web.de / jona.fengler@gmail.com
2. Overview
step2scroll is designed with privacy in mind. We do not collect, store, or process any personal data ourselves. The app operates entirely on your device. No account registration is required. No analytics SDK, tracking library, or advertising framework is integrated.
The only data processing that occurs in connection with the app is carried out by Apple Inc. as part of operating the App Store and processing in-app purchases, as described in Section 4 below.
3. Data Processed Locally on Your Device
The following data is stored exclusively on your device (via iOS UserDefaults and iCloud Key-Value Storage tied to your own Apple ID) and is never transmitted to us:
Step count data (read from Apple Health with your permission)
Screen Time authorization status and selected apps/categories
App balance, unlock history, and usage statistics
App settings (earn rate, daily goal, theme, notification preferences)
Apple Health: The app requests read access to your step count solely to calculate your balance. We do not upload or share this data. You can revoke this permission at any time in the iOS Health settings.
Screen Time / Family Controls: The app requests Screen Time authorization to enable app blocking. This data stays on your device and within Apple's system frameworks. We have no access to it.
iCloud: Balance spend data is synced via Apple's iCloud Key-Value Store (NSUbiquitousKeyValueStore) to keep data consistent across your devices. This data is associated with your Apple ID and governed by Apple's Privacy Policy. We do not have access to your iCloud data.
4. In-App Purchases (step2scroll Pro)
When you purchase a step2scroll Pro subscription, the transaction is processed entirely by Apple Inc. Apple acts as the merchant of record and reseller. We receive only an anonymized confirmation of the purchase status — no payment details, no name, no email address.
Legal basis: Art. 6(1)(b) GDPR — processing is necessary for the performance of a contract (subscription service).
Apple's data processing in connection with purchases is governed by Apple's Privacy Policy:
https://www.apple.com/legal/privacy/
5. Notifications
If you grant permission, the app sends local push notifications (e.g., low balance alerts, goal achievements). These notifications are generated and delivered entirely on-device by iOS. No notification content or delivery data is sent to us.
Legal basis: Art. 6(1)(a) GDPR — your consent, which you can withdraw at any time in iOS Settings → Notifications → step2scroll.
6. No Tracking, No Analytics, No Advertising
step2scroll does not use:
Any analytics or crash-reporting SDK (e.g., Firebase, Mixpanel, Sentry)
Any advertising network or tracking framework
Any third-party SDKs that collect data
7. Your Rights Under GDPR
As a data subject you have the following rights under the GDPR:
Right of access (Art. 15 GDPR): You may request information about whether and which personal data we process about you.
Right to rectification (Art. 16 GDPR): You may request correction of inaccurate personal data.
Right to erasure (Art. 17 GDPR): You may request deletion of your personal data, subject to statutory retention obligations.
Right to restriction of processing (Art. 18 GDPR): You may request that processing be restricted under certain circumstances.
Right to data portability (Art. 20 GDPR): You may request your data in a structured, machine-readable format.
Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests.
Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
Because we do not collect personal data ourselves, most of these rights relate to data held by Apple Inc. For data processed by Apple, please refer to Apple's Privacy Policy and contact Apple directly.
To exercise rights regarding the limited data we may hold (e.g., contact correspondence), please email us at step2scrollapp@web.de
8. Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority. The competent authority for Wiesbaden, Germany is:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (HBDI)
Postfach 3163
65021 Wiesbaden
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The current version is always available within the app and at the links provided in the App Store listing. Continued use of the app after changes are posted constitutes acceptance of the updated policy.
10. Contact
For any privacy-related questions or to exercise your rights, please contact: step2scrollapp@web.de