Privacy Policy

Last updated: 20 September 2026

1. Controller and contact

The controller for the processing described below, to the extent it falls within our responsibility, is:

Vladimir Kidisevic, sole trader (Einzelunternehmer), trading as Zilqaro
Ernst-Moritz-Arndt-Str. 4
89269 Vöhringen, Germany
Email: kidisevic@hotmail.de

You can use this address for privacy questions and for requests to exercise your rights.

2. Scope and overview

This policy covers the Zilqaro Android app, package name de.zilqaro.app, the associated website hosted on Google Sites and your communications with us. In the Google Play Store, the app may appear as "Zilqaro: Dokumente verwalten". This policy is available both on the website and in the app.

Zilqaro processes your documents on your device. We operate no document cloud of our own and no user account system. Documents, images, recognised text and audio recordings are not transmitted to Zilqaro servers — no such servers exist. The app contains no advertising and sends us no crash or diagnostic reports automatically.

In this version, the app holds no permission for network connections of its own and contains no networking code of its own. It therefore cannot send any content to us or to third parties on its own initiative. This does not prevent independent Google system services, the Google Play app or other apps you select from establishing connections of their own. Outside your device, data may be processed in particular by Google components, Google Play, the website hosting and our email service. Recipients and storage providers you select may also receive content.

3. Purposes and legal bases

To the extent the processing in question is attributable to us under data protection law, the following bases apply:

• Document, file, note, audio, reminder, export and backup functions you request — Where the processing is necessary to perform our contract with you: Article 6(1)(b) GDPR. The content remains under your control.

• Checking the trial period, purchases and Pro access — Providing and administering the contractual scope of functions, Article 6(1)(b) GDPR.

• Consent-based Google ML Kit functions and voluntary local diagnostic recording — Your consent, Article 6(1)(a) GDPR.

• Contractual support and pre-contractual questions — Handling your request, Article 6(1)(b) GDPR.

• Other correspondence and necessary security measures — Article 6(1)(f) GDPR; our interests are responding to enquiries and a secure, functioning service.

• Compliance with legal obligations, in particular required retention and privacy requests — Article 6(1)(c) GDPR in conjunction with the relevant legal obligation.

• Establishing, exercising or defending legal claims where necessary — Article 6(1)(f) GDPR; our interest is the proper pursuit and defence of legal claims.

• Making our website content available, to the extent this does not require consent — Article 6(1)(f) GDPR; our interest is the accessible provision of product and support information. For the specifics of the Google Sites platform, see section 17.

Storing information on your device, or accessing information stored there, is additionally governed by Section 25 of the German TDDDG. Access that is strictly necessary to provide a digital service you have expressly requested may fall under Section 25(2)(2); other access generally requires prior consent under Section 25(1). An Android permission does not replace a data protection consent where one is required.

Your contract for the app does not automatically legitimise the processing of other people's personal data contained in your documents. Where you are responsible for that yourself, you must ensure the necessary basis. These bases likewise do not cover processing that other providers carry out on their own account; you will find their information in the privacy notices linked in each case.

4. Local content and storage

Depending on the function you use, the app processes selected images, scans, PDFs and recognised text, file names and storage references, folders and document assignments, case names and descriptions, notes and freehand drawings, editing states, reminders, audio recordings and settings. This information may contain details about you and about other people.

Documents and working files are held in the app's own storage or in a location you select. Administrative data is stored in a local database and in local settings and metadata files. On your device, the app can derive filing and naming suggestions from recognised text, existing document names and case information. This gives us no copy of your content.

5. Confidential content and signatures

Documents may contain health information, financial information or other confidential data. Signatures may form part of imported documents or of your own drawings. Zilqaro does not use them for biometric identification and offers no cloud signature service.

Editing on your device does not mean that we receive this content. If you send such content to us or to other recipients, additional processing arises. For data within Article 9 GDPR, an appropriate exception under Article 9(2) is also required, to the extent that provision applies to the processing concerned. In support requests, please send only the information that is necessary and redact content that is not needed.

The redaction function creates a new PDF file. Existing digital signatures are not carried over as valid signatures of that new document.

6. Android access and permissions

You select images, files and destination folders through the Android or in-app dialogues. A storage provider you select may also be a cloud service.

Voice notes require microphone access. Notifications are used for local reminders; boot events serve to reschedule them, and vibration may accompany a notification. The billing permission enables Google Play purchase management. A signature-protected permission of our own secures internal Android communication within the app.

The app requests no camera, location, advertising ID or broad storage and media permission of its own, and no permission for network connections of its own. The document scanner uses Google components for this purpose. You can manage permissions and notifications in Android. Withdrawing them may limit functions, but does not delete content already stored.

7. Document scanner and text recognition with Google ML Kit

Zilqaro uses Google ML Kit components for scanning documents and for text recognition.

Text recognition runs entirely on your device. The recognition model is part of the app. Nothing is downloaded for it, and no image or text content is transmitted to Google.

The document scanner additionally uses Google Play services. When you first start it after giving your consent, Google Play services may download the component required for it onto your device. Google Play services carries out that step on its own responsibility. According to Google's ML Kit information, the capture and processing of the pages takes place on the device.

When the app starts, all that happens is that an internal ML Kit component list is created on the device. No scanner and no text recognition is created in the process, nothing is downloaded, and no usage, performance or diagnostic data is sent to Google.

Before the first use of the scanner or text recognition, the app asks for your consent. Without stored consent, both functions remain blocked; technically, they are not called until consent has been successfully stored. You can withdraw your consent in the app settings under "Google ML Kit". A stored withdrawal blocks any further calls until you consent again. If the decision cannot be stored, the app displays a notice and treats consent as not given. All other functions remain usable regardless.

Once consent has been given and these functions are used, Google may, according to its own information, process technical device, app and installation information, identifiers, performance values, and usage and error events for diagnostics and analysis. This is to be distinguished from the content of your documents. Google describes the details in its ML Kit data disclosure. Google's retention periods for this technical data are not stated for each individual data type in its publications, so we cannot quantify them.

A withdrawal does not delete data already processed by Google and does not switch off Google Play services as an independent system service.

8. Notes, editing and reminders

Note drafts, drawings, previews and editing states are stored or cached on your device. A result saved as a PDF is a file in its own right. Deleting a draft therefore does not automatically remove results you have already exported.

On your device, reminders contain dates, any text you enter, and links to documents or cases. The due notification shows only the app name and the message "A deadline is due."; your individual reminder text is not included in it. Whether notifications appear on the lock screen is determined by your Android settings.

9. Voice notes

When you start a recording, the app processes the microphone signal on your device. Completed recordings are stored as M4A/AAC files together with accompanying information such as title, duration, timestamps and document assignment. Working files are created while recording. We operate no speech or audio cloud of our own, and the function performs no automatic transcription.

Audio may form part of an export or app backup that you initiate. Password protection applied to a PDF file does not protect a separate recording or its accompanying information.

10. Google Play, trial period and subscription

When the app starts, Zilqaro initialises purchase management. Where Google Play is available, product information and existing purchase entitlements are queried in order to check and restore your Pro access. This check does not require a new purchase. The app manages the trial period separately from this, on your device.

The app processes product and base plan details, prices, purchase and subscription status, and technical proofs of purchase. Only a reduced form is stored permanently on your device, in particular product identifiers, timestamps, processing states and check values derived from transaction information. Complete purchase tokens are not stored permanently and are not transmitted to a purchase server of our own — no such server exists. The app receives neither your Google password nor card or bank account details.

The purchase itself takes place in the Google Play purchase dialogue. In doing so, Google processes account, order, payment, refund and subscription data in particular. As part of the Play process, order and billing information may be accessible to us for support, accounting or legal claims; this is to be distinguished from storage on your device. We retain records subject to statutory retention in accordance with the relevant obligation.

The free trial period lasts 30 days and triggers no automatic purchase. You purchase the optional Pro subscription expressly in the Google Play dialogue; it renews annually in accordance with the terms shown there. The price and contract information in the purchase dialogue are authoritative. Management and cancellation take place through Google Play. A review you submit there is also processed by Google. Google Privacy Policy

11. Additional PDF safety copies

You can enable an additional PDF backup. Without a destination folder of your own, the copies are held in the app's own storage. Instead, you can select another local location or one connected through Android, including a cloud provider. When the function is enabled, additional copies may be created during later save operations.

This function backs up PDFs, not the app's entire data set. Disabling it or changing the folder does not delete existing copies. This gives us no access to your storage account.

12. App backup and restoration

A manually created app backup may contain active PDFs, folders, cases, reminders, completed audio recordings together with their accompanying information, and selected settings. It does not contain editable note drafts, ongoing recordings, trash, caches, diagnostic entries, consents, device permissions, purchase entitlements or the local trial period. Notes already saved as PDFs may be included.

The ZIP archive is not additionally encrypted. Names, administrative data, audio and unencrypted PDFs can be read by anyone with access to the archive. Checksums it contains serve to detect damage; they are not encryption and not confirmation of origin.

You select the storage location. A cloud provider may transmit and store the archive under its own terms. A restoration checks the archive and replaces the data set covered by the backup; working and fallback files are created in the process. You must delete archives outside the app separately.

13. Sharing, exporting and external apps

By sharing, exporting or opening externally, you pass selected content to another app or to a recipient you choose. PDFs can be shared with or without their assigned audio. Recognised text, images, backups or diagnostic reports can also be passed on through the routes offered in each case. This passing on only ever happens through an express action by you.

Temporary copies and limited file access grants may arise for the handover. The recipient may keep copies of their own; their further processing is governed by their terms. Passing content on does not mean that Zilqaro receives it. Deleting content on your device later does not remove other people's copies.

14. Voluntary diagnostic recording

Diagnostic recording is switched off by default. When enabled, the app stores technical details on your device, such as app and Android version, language, time of error, error area, error code, shortened error messages and technical states. The buffer holds at most 100 entries; after that, the oldest are replaced.

The app shortens error messages and cleans up certain path-like details. This does not guarantee complete anonymisation: personal elements may remain. Please review reports and screenshots before sending them and remove information that is not needed.

Switching the function off ends the recording; the app also attempts to delete existing entries. Storage errors may leave remnants behind. No automatic upload takes place. A report is only passed on once you expressly share it and select a recipient. The support rules in section 18 apply to reports sent to us.

15. PDF passwords and security

The optional PDF password protection uses AES-256 for the PDF file concerned. The password is used on your device for processing that file. We receive no recoverable copy of the password and cannot reset lost passwords.

This protection does not automatically cover other documents, nor the local database, note drafts, audio, accompanying information or the ZIP backup. The Android app sandbox limits access by other apps; protection beyond that depends among other things on your device lock, the operating system and the storage locations you choose. There is no guarantee of complete security.

16. Google services in the app

Besides ML Kit, Zilqaro uses Google Play for distribution, purchase processing, subscription management and, where applicable, reviews. The app contains no integration of our own for Firebase Analytics, Firebase Crashlytics, Firebase App Check or the Play Integrity API. Technical helper libraries shipped with other components are not a Firebase cloud service of ours. We use no advertising or analytics services; no advertising ID is queried.

Google may secure and operate its platform independently of this and in accordance with its own terms. The switches in the app do not control every processing operation of your Google account or of the Google system services installed on your device.

17. Google Sites website, cookies and browser storage

The website is operated through Google Sites under a private Google account. For technical reasons, Google receives your IP address on every page view in particular, and may process the time of access, the pages requested, browser and device information, and security data.

What we checked. When we accessed the pages on 20 September 2026 with a fresh, empty browser profile and without prior consent, we established the following:

• Cookie set — exactly one: NID, set by Google

• Scope — domain .google.com, path /

• Lifetime — around six months, stored persistently

• Attributes — Secure, HttpOnly, SameSite=None

• Local storage, session storage, IndexedDB, service worker — no entries

• Statistics or analytics set up by us — none; the Google Sites statistics function is switched off and no Google Analytics ID is entered

• Contact form — none

The cookie is therefore actually stored on the very first visit, not merely offered. Because it applies to .google.com, it is also sent to other Google services; conversely, Google cookies that your browser brings with it from other Google services may be transmitted to Google when our pages are accessed. For NID, Google describes a lifetime of six months from last use and names different purposes depending on the context of use, including functionality, analytics and advertising. Google's cookie information

What we cannot claim. Which of these purposes Google pursues with NID specifically in connection with a Google Sites page is not conclusively published by Google and cannot be established by us. We therefore claim neither that this cookie is used for advertising or for tracking across websites, nor that it is exclusively technically necessary.

Further Google requests on a page view. When the pages load, the Google Sites platform independently calls further Google addresses. These include fonts and presentation resources from Google servers, as well as two Google logging addresses (naLogImpressions and play.google.com/log), to which, according to our measurement, browser identification, operating system version, language, window and display dimensions, colour scheme, timing values and technical identifiers are transmitted among other things. These requests originate from the platform itself and not from any analytics we have set up.

Why there is no consent dialogue here. Google Sites does not technically allow us to place a consent banner of our own effectively in front of these requests. The page is generated and delivered by Google, the cookie is set with the very first response, it is neither readable nor deletable by JavaScript, and our own content runs only in an isolated frame that loads after the page. As long as we use Google Sites, we can neither prevent these requests within that platform nor make them conditional on prior consent of our own.

What you can do. You can delete or block cookies and website data using your browser's functions; this may limit the functionality of the page. This policy, the legal notice and the contact information are also available in the app itself, so that you can read them without visiting the website. Further information: Google Privacy Policy.

18. Contact and support

When you contact us, we process your email address, sender details, content, time and any attachments. The purpose is to handle questions, technical problems, contractual matters and privacy requests. The legal basis follows from section 3.

Email communication runs through a private Microsoft account for Outlook.com or Hotmail. The provider for users in the EEA is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For these consumer services, Microsoft designates itself as a controller in its own right and processes message and technical service data under its own terms. No processor agreement under Article 28 GDPR exists for this private account. Microsoft Privacy Statement

Please send only the information that is necessary. Complete payment details, passwords and unredacted confidential documents are not required for general support.

We delete ordinary support emails and attachments as soon as they are no longer needed, and at the latest six months after the matter has been finally dealt with. This commitment concerns our mailbox. Microsoft does not publish in detail how long it keeps copies in its own systems and backups for consumer mailboxes; that is outside our control. We retain data for longer only where statutory retention obligations or necessary legal grounds exist; in those cases we limit further use to that purpose and delete once the ground ceases to apply. This rule also applies to diagnostic reports you send us voluntarily.

19. Recipients, roles and transfers to third countries

Depending on your use, Google, Microsoft and storage providers, apps and recipients you select receive data. We disclose information to competent authorities to the extent a legal obligation exists.

Roles and providers or contracting parties:

• Website on Google Sites — Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Role: controller in its own right. Processor agreement: no — not envisaged and not available for a private Google account.

• Google Play and Play Console — Provider: Google Ireland Limited. Role: independent controller. Processor agreement: no — instead, Google's controller-to-controller data protection terms apply, under which both parties expressly act as independent controllers.

• Purchase processing for users in the EEA — Provider: Google Commerce Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as merchant of record. Role: controller in its own right. Processor agreement: no.

• Google ML Kit — Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, USA, under the applicable Google API and ML Kit terms. Role: controller in its own right. Processor agreement: no.

• Google Play services on your device — Provider: Google. Role: controller in its own right towards you; we are not a contracting party here. Processor agreement: not applicable.

• Support email via Outlook.com — Provider: Microsoft Ireland Operations Limited. Role: controller in its own right. Processor agreement: no.

None of these providers acts as a processor on our behalf. In particular, we do not claim any processor agreement arising from a business or Workspace account, which we do not have.

Transfers to third countries. Our direct contracting parties for the website, Google Play, purchase processing and support email are established in Ireland and therefore within the EEA. For ML Kit, Google LLC in the USA is named as the provider. To the extent these providers process data beyond that outside the EU or the EEA, in particular in the USA, they do so on their own responsibility. For this they name, depending on the recipient and the processing, adequacy decisions, the EU-US Data Privacy Framework for covered certified US recipients, and standard contractual clauses. Google LLC and Microsoft Corporation are listed as active participants in the public register of the EU-US Data Privacy Framework.

These mechanisms do not apply across the board to every individual transfer, and which mechanism applies to a particular data flow within these companies cannot be established by us. The providers publish the relevant information and safeguards themselves: Google's transfer mechanisms, Microsoft Privacy Statement. On request, we will also point you to these sources using the contact address in section 1.

20. Retention and deletion

Documents, accompanying information, settings and drafts remain on your device until you delete them using the relevant functions or remove the app data. We keep local purchase and trial information in order to administer your access; Google Play may make purchase entitlements available again later.

The PDF trash is cleaned up during certain app operations, in particular at startup, using an age limit of one hour. Certain caches for text recognition and file handover are cleaned up on later calls using a limit of 30 minutes. These are not guaranteed periods from the time of creation: without a corresponding app operation, after an interruption, or in the event of storage errors, files may remain for longer. Recording and other working files may also persist until a later clean-up.

App data is generally removed when the app is uninstalled. Exported documents, recipients' copies, external backups and archives are unaffected by this and must be deleted at the relevant storage location. Clearing the cache alone does not remove all app data. The system-wide Android backup is disabled for this app; this does not rule out every manufacturer-specific device transfer.

Section 14 applies to diagnostics and section 18 to support. For data that other providers process on their own account, their rules apply in addition; Google publishes its own retention information on this. We cannot remotely delete content that is held exclusively on your device or with a provider you have selected.

21. Voluntary use and accounts

You decide which content you use, which recipients you select and which optional functions you enable. Without the necessary content, access permissions or consents, the function concerned is unavailable. The automatic checking of purchase entitlements is described in section 10.

Zilqaro offers no user account of its own; there is therefore no separate Zilqaro account to delete. A Google account may be required for Play purchases and for restoring them. Uninstalling the app and deleting the app data do not cancel a Google Play subscription. You manage that separately in Google Play.

22. Intended audience, children and young people

Zilqaro serves the management of your own documents and is aimed at adults. In Google Play, the target audience selected is exclusively "18 and over"; no age group under 18 is specified. We do not offer the app to children and do not address them in its description, design or range of functions.

The content rating shown in the Google Play Store, "USK ab 0 Jahren" (USK rated 0 and over), means only that the app's content requires no age restriction. It is not a statement about the age group the app is aimed at; the two are separate declarations.

The app contains no advertising, no social features, no chat and no user account of its own. There is no way to make content visible to other Zilqaro users. We carry out no separate age verification.

Two functions are based on consent: the ML Kit functions under section 7 and the voluntary diagnostic recording under section 14. Under Article 8 GDPR, consent-based processing concerning persons under 16 in Germany requires the consent or authorisation of the holder of parental responsibility, to the extent that provision applies. This does not change the fact that Zilqaro is aimed exclusively at persons aged 18 and over.

23. Automated decisions

On your device, the app produces filing suggestions and technically checks your trial or Pro status. These operations serve the operation of the app and the unlocking of functions. We do not use them for advertising profiles, to assess creditworthiness, or for comparable personal evaluations. If you consider a purchase status to be incorrect, you can contact us for a review. Any decision beyond this, based solely on automated processing and producing legal or similarly significant effects, is not envisaged on our part.

24. Your rights, withdrawal and objection

Subject to the statutory conditions, you have in particular the rights to access, rectification, erasure, restriction of processing and data portability under Articles 15 to 20 GDPR. Please use the address in section 1. Where necessary to identify your request, we may need proportionate details to confirm your identity.

You can withdraw consent at any time with effect for the future. The lawfulness of processing carried out previously remains unaffected. For ML Kit and local diagnostics, the app settings described are available; for requests to us, the contact address.

You can object to processing based on Article 6(1)(f) GDPR on grounds relating to your particular situation (Article 21 GDPR). We will then not continue the processing unless legally permissible overriding grounds or necessary legal claims apply. We do not carry out direct marketing with this data. You can also exercise your rights directly with the providers named in section 19 that act as controllers in their own right.

25. Right to lodge a complaint

Under Article 77 GDPR, you can lodge a complaint with a data protection supervisory authority, in particular in the place of your habitual residence, your place of work or the place of the alleged infringement. For private-sector bodies in Bavaria, the following authority is competent in particular:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Postfach 1349, 91504 Ansbach, Germany
Contact and complaint options

26. Changes

We will adapt this policy if relevant functions, processing activities or legal requirements change. The current version is available on the website and in the app. Where necessary, we will also provide information in the app and obtain fresh consent for changed processing that requires it.

Legal sources: GDPR, Section 25 TDDDG.