Privacy Policy

This policy explains what data Luther ("the App," "we," "us") collects, why, and how it's handled. Luther is developed by KiroLabs.

This is a starting draft, not legal advice. Have a lawyer or a service like iubenda/Termly review it against current German (TMG/TTDSG) and EU (GDPR) requirements before publishing — particularly the sections on third-party processors and the legal basis for each data use, since those need to match your actual implementation exactly.

Controller

KiroLabs
Email: labskiro@gmail.com
Website: kirolabs.io

1. What We Collect

1.1 Photos You Upload

When you select a photo for analysis, the App first reads its metadata (EXIF: GPS coordinates, timestamp, device model) on your device only — this never leaves your phone if location data is already present.

If no metadata is found and you choose to run an AI location scan, the photo is uploaded to our backend and forwarded to third-party AI models for processing.

We do not store your photos. Images are processed transiently and discarded after the analysis completes.

1.2 Account & Usage Data

Anonymous or authenticated user ID (Firebase Authentication)
Credit balance and purchase history
Scan history metadata (timestamp, number of images, result confidence) — not the images themselves
App version, device type, OS version (for support and force-update logic)

1.3 Purchase Data

Purchases are processed by Apple App Store / Google Play and RevenueCat. We receive transaction IDs, product IDs, and purchase status — we do not receive or store your payment card details, which are handled entirely by Apple/Google.

1.4 Analytics

We use Firebase Analytics to track app usage, including events such as app opens, scan initiations, and purchase completions.

2. Third-Party Processors

Your data may be shared with the following processors, solely to provide the App's functionality:

Processor	Purpose	Data shared
AI model providers	AI-based photo location analysis	The uploaded photo(s), transiently, for the duration of processing
Google Firebase	Backend infrastructure, authentication, database, cloud functions	User ID, credit balance, scan metadata, app usage
RevenueCat	Purchase and subscription management	Transaction ID, product ID, purchase status, anonymized user ID
Google Play / Apple App Store	Payment processing	Handled entirely by Apple/Google under their own privacy policies

Add/remove rows to match your actual stack exactly — this table needs to be accurate, not aspirational, since it's the part most likely to be checked against your real Firebase Function code in a dispute.

We require all processors to handle data in accordance with GDPR where applicable. If any processor is US-based, a Data Processing Agreement (DPA) and a valid transfer mechanism (Standard Contractual Clauses) should be in place — verify this with each provider before publishing.

3. Legal Basis for Processing (GDPR, EU/EEA users)

Photo analysis: Consent (Art. 6(1)(a)) — you actively choose to upload a photo and trigger a scan; nothing is processed without this action.
Purchases and credit tracking: Contract performance (Art. 6(1)(b)) — necessary to deliver what you paid for.
Analytics: Consent (Art. 6(1)(a)) — you are asked to consent before analytics tracking is enabled.

4. Photos of Other People

Luther can only analyze photos you choose to upload. If a photo contains other identifiable people, you are responsible for having a lawful basis to process their image (for example, their consent) before uploading it. Luther is not designed or intended to be used to locate, track, or monitor another individual without their knowledge, and using it for that purpose violates our Terms of Service.

5. Your Rights (GDPR)

If you are in the EU/EEA, you have the right to:

Access the data we hold about you
Request correction or deletion
Withdraw consent at any time (this will disable AI photo analysis but not affect already-completed purchases)
Data portability
Lodge a complaint with your local data protection authority

6. Children's Privacy

Luther is not directed at children under 16. We do not knowingly collect data from children under this age. [Adjust age threshold per jurisdiction if you support markets with different minimums, e.g. 13 in the US under COPPA.]

7. Data Security

Photos in transit are encrypted (HTTPS/TLS). API keys for third-party services are stored server-side only and never embedded in the App. [Add any additional measures you actually implement — e.g. Firestore security rules, rate limiting.]

8. International Data Transfers

[If our AI model providers, Firebase, or any processor stores/processes data outside the EU/EEA — likely, since most are US-based — disclose this and state the transfer mechanism, typically Standard Contractual Clauses. This is a common gap in indie-app privacy policies and a real enforcement risk under GDPR; don't skip it.]

9. Changes to This Policy

We may update this policy periodically. Material changes will be notified via an in-app notice. Continued use of the App after changes constitutes acceptance.

10. Contact

KiroLabs
Email: labskiro@gmail.com
Website: kirolabs.io