Privacy Policy

This Privacy Policy explains how the Mark application ("Mark", "the App") handles information. Mark is built on one principle: your moments belong to you and only you. No account. No cloud. No tracking. Everything you capture is stored only on your device and is never shared. We run no server that holds your content, we have no accounts, and we do not use any analytics, advertising, or tracking SDKs.

Mark is provided by Elva Lab ("we", "us", "our"), an independent app developer operating as an autonomous professional (autónomo) based in Spain. For any privacy question, contact [email protected]. By using Mark, you agree to the practices described here.

1. Definitions

• App — the Mark mobile application for iOS (and Apple Watch).
• Moment (or "Point") — an entry you save in Mark: a timestamp, and optionally a location, a text note, an audio note, a photo, and tags.
• Personal Data — any information relating to an identified or identifiable person.
• Device — the iPhone, iPad, or Apple Watch on which you use the App.
• Mark Plus — the optional paid subscription that unlocks additional features.
• GDPR — the EU General Data Protection Regulation (2016/679).

2. Data That Stays On Your Device

Everything you create in Mark is stored locally on your device using Apple's SwiftData framework. It is never transmitted to us or to any server we operate, and it is not linked to your identity. This includes:

• Location. When you tap to save a Moment, the App requests your precise GPS location once — only at the exact moment of capture, never in the background — and stores it locally with that Moment. If you decline location permission, Mark still works; Moments are simply saved without coordinates.
• Audio notes (Mark Plus). If you record an audio note, it is stored on your device as an .m4a file and deleted when you delete the Moment. The microphone is accessed only during a recording you start.
• Photos (Mark Plus). If you attach a photo, the App opens your camera only — it does not access your photo library — and the photo is stored on your device as a .jpg. You cannot attach existing gallery photos; this is intentional.
• Text notes and tags you add to a Moment.

We have no access to any of the above. It is visible only to you, on your device.

3. Purchase Information

If you subscribe to Mark Plus, the purchase is processed entirely by Apple through the App Store and StoreKit. We receive only your subscription status (active / not active) so the App can unlock features. We never see or store your payment card details or Apple ID. Apple's Privacy Policy governs the transaction.

4. What We Do NOT Collect

To be completely clear about what Mark does not do:

• We do not collect your name, email address, or any account information — Mark has no account and no sign-in.
• We do not upload, sync, or store the content of your Moments (notes, audio, photos, GPS locations) on any server.
• We do not use any analytics SDKs — no Google Analytics, no Firebase, no Mixpanel, no Amplitude, or anything similar.
• We do not use advertising SDKs and do not show ads.
• We do not collect crash reports automatically.
• We do not collect device identifiers such as Apple's advertising identifier (IDFA), and we do not track you across other apps or websites.
• We do not sell your personal data — ever.

5. How We Use Information

Simply: we do not use your information, because we never receive it. All data the App handles stays on your device. Mark has no server, no backend, and no database outside your phone. There is no account to log into, nothing to sync, and no analytics pipeline. The only purpose of the data is to display it back to you inside the App.

6. Third-Party Services

Mark relies only on Apple's own platform services, which run on your device or are operated by Apple:

• Apple — CoreLocation (GPS), AVFoundation (audio and camera), SwiftData (local storage), WidgetKit (widget), WatchConnectivity (Apple Watch), StoreKit 2 (subscriptions), and MapKit (map display). Your use of these is subject to Apple's terms and privacy policy.

We do not integrate any third-party analytics, advertising, or tracking SDKs. The only time your content leaves your device is when you choose to share a Moment yourself (for example, via the iOS Share sheet) — in that case you are sharing it, not us.

7. Legal Basis for Processing (GDPR)

Because we do not collect or process your personal data on any server, there is very little processing to speak of. Where the GDPR applies, we rely on:

• Consent (Art. 6(1)(a)) — for optional device features such as location, microphone, camera, and notifications, which iOS asks you to permit. You can withdraw consent at any time in iOS Settings.
• Contract (Art. 6(1)(b)) — to provide the App and your Mark Plus subscription (processed by Apple).

8. Data Retention and Deletion

You are in full control of your data:

• Delete individual Moments in the App at any time.
• Delete everything by uninstalling the App — all locally stored Moments, audio, and photos are permanently removed.

We hold no copy of your data and cannot recover it after deletion.

9. Data Storage and Security

Your Moments are stored in the App's sandboxed storage, protected by iOS's built-in sandboxing and encryption. They are included in your iCloud Backup only if you have iCloud Backup enabled on your device (this is controlled by iOS, not by us) and are not synced to any server we operate. We recommend using a device passcode and Face ID / Touch ID to protect all apps on your phone, including Mark.

10. International Data Transfers

Because your data never leaves your device (unless you choose to share it yourself), we do not transfer your personal data internationally. Any Mark Plus purchase is handled by Apple under Apple's own arrangements.

11. Your Rights

Depending on where you live (including the EEA, the UK, and California), you may have some or all of the following rights:

• Access — the data we hold about you (answer: none — your Moments are on your device, and we collect nothing on a server).
• Deletion — delete individual Moments in the App, or delete everything by uninstalling the App.
• Portability — your Moments are already fully portable: they live on your phone.
• Object / restrict — there is no server-side processing to object to.
• Withdraw consent — revoke location, microphone, camera, or notification permissions at any time in iOS Settings.
• Complain — to the Spanish Data Protection Authority (AEPD) or your local supervisory authority.

To exercise a right or ask a question, contact [email protected]. We aim to respond within 30 days.

12. Children's Privacy

Mark is rated 4+ and is not directed at children under 13, and we do not knowingly collect personal data from them. Because the App keeps everything on your device and collects nothing on a server, there is no special risk to children's privacy. We comply with applicable children's privacy laws, including COPPA (U.S.) and Article 8 of the GDPR (EU). If you believe a child has provided us with personal data, contact us and we will address it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date above and, for material changes, notify you through the App or the App Store update notes. Your continued use of the App after changes are published constitutes acceptance of the updated Policy.

14. Contact Us

If you have any questions about this Privacy Policy, contact us:

[email protected]
https://elva-lab.com