Privacy Policy

1. Data Controller

The data controller responsible for processing your personal data is:

2. Overview

We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations, in particular the General Data Protection Regulation (GDPR) and this privacy policy.

This policy explains what data we collect when you use the Puppy Journal app, how we use it, and what rights you have.

3. Data We Collect

3.1 Data Stored Locally

All data you enter in the app (puppy profiles, events, settings) is stored locally on your device and, if enabled, synced via Apple's iCloud service to your personal iCloud account. We do not have access to this data. This includes:

• Puppy profile information (name, birthdate, photo)
• Event logs (potty breaks, meals, walks, etc.)
• App settings and preferences

Legal basis: Contract fulfillment (Art. 6(1)(b) GDPR) - necessary to provide the app's core functionality.

3.2 Analytics

To improve the app, Puppy Journal sends anonymous usage statistics to our own analytics server at analytics.keitgen.de. The server runs the analytics software Countly and is operated by Keitgen GmbH. The app sends:

• Sessions - when the app is in use and for how long
• Device information - device model and type, operating system and version, app version, screen resolution, screen orientation, language and region setting, and time zone
• Events - the color theme and app icon you choose, whether you switch the potty reminder on or off, your puppy's birth date when you change it or add a puppy after the first setup, and the status of your advertising consent from Google's consent form (see 3.3), including whether that form applies in your region. Versions before 2026.3 also sent whether you allowed tracking in Apple's tracking prompt.
• Crash reports - technical details when the app crashes, such as where in the code the error happened, the device model, the system version, and free memory and storage

This data is stored under a random identifier that the app creates when it is first started. It is not the device's advertising identifier, and it is not linked to your name, your Apple ID or your journal entries. The app sends no personal data to our analytics server, and the server stores no IP addresses.

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) - to improve the app and fix issues.

3.3 Advertising (Google AdMob)

The free version of Puppy Journal displays advertisements provided by Google AdMob. Google may collect the following data:

• Device identifiers - used for advertising. Google receives the device's advertising identifier only if you allowed the app to track you (see below).
• IP address - used to estimate general location
• User interactions - such as app launch taps and video views, used to improve ad performance
• Advertising data - information about ads shown to you
• Performance data - app launch time, hang rate, and energy usage
• Crash logs - diagnostic data for SDK improvement

Your choice: Where consent is required, the app shows Google's consent form before any ads are loaded. You can change your choice at any time in the app under Settings > Manage Ad Privacy Settings. This entry appears where Google's consent form applies.

Tracking permission: From version 2026.3, the app does not ask for permission to track you (Apple's App Tracking Transparency). Earlier versions asked for it after Google's consent form. If you allowed tracking there, you can withdraw it on your iPhone under Settings > Privacy & Security > Tracking.

Legal basis: Consent (Art. 6(1)(a) GDPR), given in Google's consent form, or legitimate interest for non-personalized ads.

More information: Google Privacy Policy · AdMob Data Disclosure

You can remove all advertisements by purchasing the ad removal option within the app.

3.4 In-App Purchases

Purchases are processed by Apple through the App Store. We do not receive or store your payment information. Apple may share transaction data (purchase date, product purchased) with us for record-keeping purposes.

Legal basis: Contract fulfillment (Art. 6(1)(b) GDPR).

3.5 Contacting Us

If you write to us by email, we receive your email address and everything your message contains, including any technical details you choose to include. We use this only to answer you.

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) - to answer your request.

4. Data Retention

Your app data is stored on your device and in your iCloud account for as long as you use the app. When you delete the app, local data is removed. iCloud data can be managed through your iCloud settings. For more information, see Apple's Privacy Policy.

Usage statistics and crash reports (see 3.2) are stored on our analytics server under the random identifier, without personal data and without IP addresses.

We retain purchase records as required by applicable tax and commercial law.

Our web server may collect log files containing IP addresses, access times, and requested pages. This data is automatically deleted after seven days and is used solely for security and troubleshooting purposes.

5. Data Sharing

We do not sell your personal data. Data may be shared with:

• Apple Inc. - for iCloud sync and App Store purchases. Apple Privacy Policy
• Google LLC - for advertising (free version only). Google Privacy Policy

These providers act as data processors under GDPR and are contractually bound to protect your data.

6. International Data Transfers

Some of our service providers (Apple, Google) may transfer data to countries outside the European Economic Area. These transfers are protected by appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.

7. Your Rights

Under GDPR, you have the following rights:

• Right of access (Art. 15 GDPR) - to request information about your personal data
• Right to rectification (Art. 16 GDPR) - to correct inaccurate data
• Right to erasure (Art. 17 GDPR) - to request deletion of your data
• Right to restriction (Art. 18 GDPR) - to restrict processing of your data
• Right to data portability (Art. 20 GDPR) - to receive your data in a portable format
• Right to object (Art. 21 GDPR) - to object to processing based on legitimate interests
• Right to withdraw consent (Art. 7(3) GDPR) - to withdraw consent at any time

To exercise these rights, contact us at support@keitgen.de.

Since your app data is stored locally on your device, you have full control over it. You can view, modify, or delete all data directly within the app or by deleting the app.

8. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. The competent authority for Keitgen GmbH is:

9. Children's Privacy

Puppy Journal is not directed at children under 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us.

10. Cookies

The Puppy Journal app itself does not use cookies. The Google Mobile Ads SDK, which shows the ads in the app, may store identifiers and similar data on your device as described in Google's privacy policy, as far as your choice in Google's consent form allows (see 3.3).

This website does not set cookies and loads no content from other providers.

11. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of significant changes through the app or by posting an updated policy on this page with a new "Last updated" date.

12. Contact

For questions about this privacy policy or to exercise your rights, contact us at: