Privacy Policy

This privacy notice for D'kluteř ('we', 'us' or 'our') describes how and why we might collect, store, use and/or share (process) your information when you use our Services, such as when you:

Download and use our mobile application (D'kluteř)
Create an account for subscription management
Use our AI-powered features
Engage with us in any other related ways

1. WHAT INFORMATION DO WE COLLECT?

1.1 Local Device Data (Not Collected by Us)

Your Asset Data Remains Private:

All your personal assets (images, documents, metadata, tags, reminders, warranties, invoices, certificates, expenses, etc.) are stored exclusively on your device in an encrypted database.
This data is never uploaded to our servers, never synced through our systems, and never linked to your account.
We have no access to your asset data, and it remains entirely under your control.

1.2 Account Information (Collected for Subscription Management)

When you create an account for subscription purposes, we collect:

Email Address (Hashed):

Your email address is transformed using a one-way cryptographic hash function before storage
We store only the hashed value, not your actual email address
The hash is used solely for login verification and account matching
The original email cannot be recovered or reconstructed from the hash
This approach ensures we can authenticate you without storing your personal email

Subscription Metadata:

Subscription status (active, expired, cancelled)
Subscription type and tier
Subscription start and expiration dates
Payment platform identifier (from App Store/Google Play)

Device Information (for Multi-Device Management):

Device identifiers (unique device IDs)
Platform type (iOS/Android)
Number of devices associated with your subscription (maximum 5)
Device registration and last active timestamps

Purpose:

This information is collected solely to:

Authenticate your login across devices
Manage your subscription and enforce the 5-device limit
Enable you to access your subscription on multiple devices
Provide account management features

1.3 User-Submitted Feedback & Support

If you choose to submit feedback, FAQs, or use our help form, we may collect:

Email Address: To respond to your inquiries and feedback
Device, OS and App Version: To understand your device environment
Feedback Information: The content of your feedback or inquiry
SQL Query Log: The underlying SQL queries generated by the app to diagnose problems

1.4 AI Service Usage Data

When you choose to use our optional AI-powered asset creation/update features:

Data Sent to Google Gemini:

Asset images you explicitly select for AI processing
Field titles (e.g., "Purchase Date", "Model Number") - not field values
Tags associated with the asset
Asset title (if provided)
Asset description (if provided)

Important Notes:

This feature is completely optional and activated only when you explicitly request AI assistance
We do not send any personal profile information (name, email, account details) to Gemini
We do not send field values, only field names/titles
This data is used solely for generating AI-powered suggestions and is not stored on our servers
The data sent to Gemini is not linked to your account or subscription

1.5 Information We Do NOT Collect

We do not collect:

Your personal asset data stored on your device
Location data
Contacts or address book information
Browsing history or app usage patterns
Any sensitive personal information
Any data for advertising or analytics purposes

We do not process sensitive information.

Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

2. HOW DO WE PROCESS YOUR INFORMATION?

2.1 Account Authentication & Subscription Management

We process your hashed email and subscription metadata to:

Verify your identity during login
Manage your subscription across multiple devices
Enforce subscription limits (5-device maximum)
Enable account recovery and device management
Process account deletion requests

2.2 Support & App Improvement

We use support-related information to:

Respond to your inquiries and feedback
Diagnose technical problems
Improve the App's functionality and user experience

2.3 AI-Powered Features

When you use AI features:

Selected data is transmitted to Google Gemini for processing
Gemini generates suggestions based on your input
Results are returned to your device
No data is retained by us or linked to your account

We do not use your information for:

Marketing or advertising
Selling or sharing with third parties (except as disclosed below)
Building user profiles
Training AI models
Any purpose other than those explicitly stated

3. WITH WHOM DO WE SHARE YOUR INFORMATION?

3.1 Third-Party Service Providers

Google Gemini (AI Services):

When you explicitly use AI features, the selected asset data is sent to Google Gemini for processing
Purpose: To generate AI-powered suggestions for asset creation and updates
Data shared: Only the specific content you select (images, field titles, tags, titles, descriptions)
Retention: We do not control Google's data handling; refer to Google's Privacy Policy
Opt-in: This feature is optional and used only when you trigger it

Payment Processors (Apple App Store / Google Play Store):

Subscription payments are processed through Apple App Store or Google Play Store
We receive only a platform-generated identifier to verify subscription status
We do not process or store payment card information

3.2 Legal Requirements & Business Transfers

We may share information:

To comply with legal obligations, court orders, or government requests
To protect the rights, property, or safety of D'kluteř, our users, or others
In connection with any merger, sale, financing, or acquisition of all or a portion of our business

3.3 What We Do NOT Share

We do not share:

Your asset data (it never leaves your device)
Your raw email address (we only store hashed values)
Your personal information with advertisers or data brokers
Any data for marketing purposes

4. WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we have a valid legal basis under applicable law:

Consent: When you create an account, use AI features, or submit support requests
Contractual Necessity: To provide subscription services and authenticate your account
Legitimate Interests: To maintain app security, prevent fraud, and improve our services
Legal Compliance: To comply with applicable laws and regulations

5. DATA SECURITY

5.1 Local Data Security

Device-Level Encryption:

All asset data stored on your device is maintained in an encrypted database
Data remains encrypted until you authenticate using your device's security (PIN, passcode, FaceID, fingerprint)
Data is decrypted in memory only during active use
When you close the app, data returns to an encrypted state

5.2 Data Transmission Security

Secure Communication:

All data exchanges (login, subscription verification, support communications) use encryption (HTTPS/TLS)
We employ secure communication protocols to protect data in transit

5.3 Optional Backup & Sync

User-Controlled Cloud Backup:

You may optionally backup your encrypted database to your personal iCloud or Google Drive account
Backups remain encrypted and are stored in your personal cloud storage
We have no access to your cloud storage or backup data
Future versions will include WiFi sync as an additional option

Encrypted Data Sharing:

You can share encrypted data with other users via public key exchange
You can set time-to-live (TTL) restrictions on shared data
Shared data remains encrypted and is only accessible by intended recipients

5.4 Server-Side Security

Minimal Data Storage:

Only hashed email identifiers and subscription metadata are stored on our servers
No asset data, documents, or personal files are ever stored on our servers
Server infrastructure uses industry-standard security measures

5.5 Important Security Notes

No method of transmission over the internet or electronic storage is 100% secure
Users should choose strong, unique passwords for their accounts
Exercise caution when using the app on shared or public devices
Keep your device security features (PIN, biometric authentication) enabled

6. PASSWORDS, AUTHENTICATION & DATA SYNC

Device Authentication:

The app is accessed using your device's built-in authentication (PIN, passcode, FaceID, fingerprint)
This provides an additional security layer beyond account login

Account Password Security:

Account passwords are not stored on our servers
Passwords are hashed using secure cryptographic methods
If you forget your password, you will need to use account recovery procedures

Multi-Device Access:

Your subscription allows access on up to 5 devices
Each device must be authenticated individually
You can manage and remove devices through the app settings

Data Sync:

Asset data is NOT synced across devices through our servers
You control synchronization through your personal cloud storage (iCloud/Google Drive)
All synced data remains encrypted

7. HOW LONG DO WE KEEP YOUR INFORMATION?

7.1 Account & Subscription Data

We retain your hashed email and subscription metadata:

For as long as your account remains active
For a limited period after account deletion to process the deletion and handle any disputes
As required by legal, tax, or accounting obligations

7.2 Support & Feedback Data

Support communications are retained:

For as long as necessary to resolve your inquiry
To maintain a record of technical issues for app improvement
Typically no longer than 2 years after resolution

7.3 AI Processing Data

Data sent to Google Gemini for AI processing is not stored by us
We do not control Google's retention policies; refer to their privacy policy

7.4 Device Data

Your asset data stored locally on your device remains until you manually delete it
Deleting the app will remove all local data from that device
Encrypted backups in your personal cloud storage remain until you delete them

8. ACCOUNT DELETION & YOUR RIGHTS

8.1 Account Deletion

You can delete your account at any time through the app settings or by contacting us at support@dkluter.com .

10. WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change or terminate your account at any time.

If you would at any time like to review or change information or terminate your account you can: contact us at support@dkluter.com

11. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify users of any changes by posting the new Privacy Policy on this page. Users are advised to review this Policy periodically for any changes.

12. CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact us at support@dkluter.com

When you delete your account:

Your hashed email identifier is removed from our servers
Your subscription metadata is deleted
All device associations are removed
You will lose access to subscription features across all devices

What is NOT deleted:

Asset data stored locally on your devices (this remains under your control)
Encrypted backups in your personal cloud storage (you must delete these separately)
Support communications (retained as described in Section 7.2)

8.2 Your Privacy Rights

Depending on your location, you may have rights under applicable data protection laws:

Access & Portability:

Request a copy of the personal information we hold about you
Note: We hold minimal information (hashed email and subscription metadata only)

Correction:

Request correction of inaccurate information

Deletion:

Request deletion of your account and associated data
Use the in-app account deletion feature or contact us

Restriction & Objection:

Request restriction of processing in certain circumstances
Object to processing based on legitimate interests

Withdrawal of Consent:

Withdraw consent for AI feature usage at any time by not using the feature
Withdraw consent for account processing by deleting your account

To exercise these rights, contact us at support@dkluter.com

9. USER-ADDED LINKS & CONTENT

The app allows you to manually paste and store links, documents, and media within your asset records. These are:

User-generated and user-controlled
Stored only on your device
Not monitored, scanned, or accessed by us
Your sole responsibility regarding content legality and appropriateness

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are:

At least 18 years old, OR
The parent or guardian of a minor user and consent to their use of the Services

If we learn we have collected information from a minor without proper consent, we will delete that information promptly.

11. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer information internationally, we:

Use appropriate safeguards to protect your information
Ensure transfers comply with applicable data protection laws
Rely on mechanisms such as Standard Contractual Clauses where required

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

Changes in our practices
Changes in applicable laws
New features or services

Notification of Changes:

We will post the updated policy on this page
The "Last Updated" date will be revised
Material changes may be notified through the app or via email
Continued use of the app after changes constitutes acceptance

We encourage you to review this policy periodically.

13. CONTACT US

If you have questions or concerns about this Privacy Policy, or wish to exercise your privacy rights, please contact us at:

Email: support@dkluter.com

Website: https://dkluter.com

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

14. SUMMARY OF KEY PRIVACY PROTECTIONS

✓ Your asset data never leaves your device - we cannot access it
✓ Email addresses are hashed - we don't store your raw email
✓ No tracking or analytics - we don't monitor your behavior
✓ AI features are optional - used only when you choose
✓ You control your data - local storage, your cloud backup, your deletion
✓ Minimal server data - only what's needed for authentication and subscription
✓ Strong encryption - for data at rest and in transit
✓ No third-party sharing - except as explicitly disclosed (AI service, payment processing)
✓ Account deletion available - remove your account data anytime