KeepWhen Privacy Policy

1. Controller and contact

The data controller is Mattia D’Alleva, operating under the Codalbyte brand, in L’Aquila, Italy, VAT number 02669150696. For information or to exercise your rights, contact [email protected].

2. Your memories and how the app works

You can use KeepWhen without creating an account. Your device stores activities, names and categories you choose, entry dates, notes, any photos, preferences, reminders and technical information needed to handle changes, deletions and purchases. These data provide the features you request. They are not automatically sent to a repository on Codalbyte’s servers.

The app and its widgets share the data needed to display and update your activities on your device. Siri and Shortcuts can invoke available features; Apple handles your interaction with Siri under its own settings and terms. The app does not independently record your voice.

The legal basis for providing requested features is performance of the service, Article 6(1)(b) GDPR. You choose which content to enter: using the journal does not require your name, email address, location or contacts.

3. Photos, reminders and backups

KeepWhen accesses the photos you select through the system picker without requesting general access to your photo library. It stores optimized copies with the original images’ location metadata removed; this does not remove personal information visible within the image itself. The app does not send photos or journal text to analytics or diagnostic services.

Reminders are local notifications scheduled on your device with your iOS permission. We do not use a remote push notification service to deliver them. You can disable them in the app or iPhone Settings. An activity name may appear in a notification depending on your preview settings.

File backup and restore are available without Pro. Exported files may contain activities, notes, history and images: you choose where to save them and whom to share them with. The apps or services you choose process them under their own policies. Exported copies are not automatically deleted when you change or remove data in KeepWhen.

4. Optional iCloud

iCloud synchronization is a Pro feature. It is turned on automatically when Pro is first recognized on an installation, including after restoring the purchase. You can turn it off in Settings > Sync with iCloud; that choice is respected on subsequent launches and restores on the same installation. When synchronization is on and iCloud is available, KeepWhen sends Apple your activities, custom categories, entries, notes, photos and change or deletion information, in the private CloudKit database associated with your iCloud account. App-generated identifiers and an account reference help merge changes and prevent sending memories to a different account. The app does not receive your Apple Account password.

You can continue using local data offline. Synchronization runs when the app can perform it and is not a promise of an immediate backup. Turning it off stops subsequent synchronization but does not erase local copies or data already in iCloud. Recovery of data already in iCloud remains available without Pro: it reads existing data without enabling synchronization or uploading new changes. Processing performs the feature you requested, under Article 6(1)(b) GDPR.

5. Purchasing KeepWhen Pro

KeepWhen Pro is a one-time purchase handled by Apple through the App Store and StoreKit. The app verifies transaction information, the purchased product and any revocation to unlock or restore Pro features. Codalbyte does not receive your card details or payment credentials from the app. Apple processes purchases and payments under its own terms. Recognizing purchases and providing features is based on performance of the service, Article 6(1)(b) GDPR; mandatory legal requirements are based on Article 6(1)(c).

6. Usage data and diagnostics

This version of KeepWhen does not include third-party analytics, advertising or diagnostic SDKs and does not send usage events, installation identifiers or crash reports to Codalbyte or Google. There is no consent request for usage data or diagnostic sharing. Apple may process statistics and diagnostics through its own system and App Store services, under Apple’s settings and terms.

7. No advertising

KeepWhen does not display ads, integrate advertising networks or use advertising identifiers. We do not sell personal data or use it to track your activity across other companies’ apps and websites for advertising. We do not use your memories for automated decisions with legal or similarly significant effects.

8. Recipients and international transfers

Depending on the features you choose, Apple processes data for system services, iCloud and purchases. Synced content resides in your account’s private CloudKit database; Codalbyte has no administrative access to users’ private content. If you contact us for support, we process the data you choose to send and may use email service providers. Data may be disclosed to authorities where required by law.

Provider services may involve processing outside the European Economic Area. Where applicable, transfers rely on adequacy decisions or other safeguards required by the GDPR. Contact us for information about applicable safeguards. See Apple’s Privacy Policy in the links below.

9. Retention and deletion

Activities and journal data remain in the archive while you keep them. Activities in Trash can be recovered for 30 days; after that, the app removes them during subsequent cleanup operations. With synchronization enabled, deletions propagate when iCloud is available. Archiving is not deletion.

The app keeps deletion information to prevent older copies from restoring deleted items. Entries removed from the journal may remain in archive records, including their date and note, until the associated activity is permanently removed; images are unlinked. Unused image files are subject to archive cleanup.

Removing the app does not necessarily delete data in iCloud, system backups or exported files. To remove those copies too, use the tools provided by Apple or the service where you saved them.

Payment, Apple account and system service data follow Apple’s retention periods and applicable legal requirements.

If you contact us, we retain your email and message to handle the request and follow-ups, and subsequently only for legal obligations or protection of rights, for the applicable periods. Responding to requests is based on performance of the service or legal obligations, as appropriate.

10. Your rights

Where provided by applicable law, you may request access, correction, deletion, restriction and portability, object to processing where that right applies, and withdraw consent. Contact [email protected]. We may request proportionate information to verify your request; we will not ask for unnecessary information.

You may complain to the Italian Data Protection Authority or the competent authority in your country. If your request concerns a child’s data, please tell us so we can handle it appropriately.

11. Changes to this policy

We will update this text when features or processing change. The opening date identifies the version. Where necessary, we will notify users of material changes and request fresh consent.