Privacy Policy
Privacy Policy
Last updated: 4 November 2026
1. Introduction
This Privacy Policy describes how the iOS app offtime handles personal data. offtime is published by Louie Gaiser (for provider details, see the Imprint).
If you have any questions about this Privacy Policy, you can reach us at apps@louiegaiser.com.
2. Controller
The controller for the processing of personal data in this app within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR" — in German: Datenschutz-Grundverordnung, "DSGVO") is:
Louie Gaiser
c/o Block Services
Stuttgarter Str. 106
70736 Fellbach
Germany
Email: apps@louiegaiser.com
3. Legal Bases for Processing
We process personal data on one or more of the following legal bases under Art. 6 GDPR:
- Art. 6(1)(a) GDPR — Consent: for optional features you actively choose to use, such as saving generated QR codes to your photo library.
- Art. 6(1)(b) GDPR — Performance of a contract: for providing the app and its core features, including subscription handling, the display of purchase offers (paywalls), the use of iOS permissions (camera, NFC, Screen Time / Family Controls) for the corresponding feature, and pre-contractual measures taken at your request.
- Art. 6(1)(f) GDPR — Legitimate interests: for measuring, A/B testing and optimising how paywalls are presented, and for preventing misuse.
Balancing of interests under Art. 6(1)(f) GDPR
Where we rely on legitimate interests, we have weighed your interests against ours:
- Our interests: sustainably financing the app through subscriptions; measuring, testing and improving the way purchase offers are presented; preventing misuse.
- Your interests: protection of your privacy, control over your data, processing kept to a minimum.
- Outcome: processing is limited to pseudonymous identifiers, device and app metadata, and your interactions with the paywall. We do not process your Screen Time data, the apps you block, the content you create in offtime, or any profile data about you. We do not build advertising profiles, do not sell data, and do not pass data to data brokers. You may object to this processing at any time (Art. 21 GDPR).
4. What Data We Process and Why
4.1 Data stored exclusively on your device
The following data remains exclusively on your iPhone or iPad:
- Automatically stored data: session data (such as duration, mode and date) for your personal overview in the app.
- Data you enter: settings, presets, scheduled blocks and other configuration.
- Technical storage: data is stored using local operating-system technologies such as
UserDefaultsand Core Data.
The statistics shown in the app are generated locally on your device.
When you delete the app, iOS generally removes the data stored in the app container. Individual system-managed data, or data held in shared app containers, may persist until the operating system removes it or the app overwrites it.
Legal basis: Art. 6(1)(b) GDPR.
4.2 Screen Time / Family Controls
offtime uses Apple’s FamilyControls and ManagedSettings frameworks to enforce app restrictions on your device. The following applies:
- Local app selection: the app does not receive a complete list of the apps installed on your device, only opaque app and category tokens for the content you have selected.
- No analysis of your usage: offtime does not store or analyse any data about your actual app usage or screen time.
- No disclosure: all Screen Time data remains on your device. It is transmitted neither to us, nor to Superwall, nor to any other third party.
- No automated decisions: blocking periods and restrictions are activated solely on the basis of your own configuration.
Legal basis: Art. 6(1)(b) GDPR.
4.3 Processing by Superwall
Superwall is the only service that receives data from the app. We use it to display purchase offers (paywalls), to measure their effect and to test their presentation. Details about the provider and the full list of data points can be found in Section 7.2. In summary, Superwall processes:
- Identifiers: a pseudonymous user ID generated by the SDK, and the vendor identifier (IDFV) of your device.
- Device and app metadata: such as app version, iOS version, device model, language, region, currency and time zone.
- Paywall interaction data: such as which paywall was displayed, whether you dismissed it, how many paywalls you have already seen, and how long ago the app was installed.
- Purchase data: product and transaction identifiers, price, currency, and your subscription or entitlement status.
As with any internet connection, your IP address is transmitted in the process, since it is technically required in order to send a response to your device. It is not stored as a separate attribute and is not evaluated to determine your location or for advertising purposes.
This data is not linked to your Screen Time data, your sessions, your presets, or any other content you create in the app.
4.4 Correspondence with the App Store privacy details
Apple requires us to declare the same processing activities in the "App Privacy" section of the App Store. The following table maps those declarations to the sections of this policy:
| Declaration in the App Store | What it refers to in offtime | Declared purposes | Section |
|---|---|---|---|
| Identifiers → User ID | Superwall’s pseudonymous user ID and its aliases | Analytics, App Functionality | 7.2 |
| Identifiers → Device ID | Vendor identifier (IDFV) of the device | Analytics, App Functionality | 7.2 |
| Purchases | Product and transaction identifiers, price, currency, entitlement status | Analytics, App Functionality | 7.1, 7.2 |
| Usage Data → Product Interaction | Paywall views, dismissals, purchase events, time since installation | Analytics, App Functionality | 7.2 |
We declare no further data types. None of the data declared above is used for tracking.
"Analytics" here means measuring how purchase offers perform — not measuring how you use your device or which apps you block. That data never leaves your device (see Section 4.2).
5. Retention Periods
| Data category | Purpose | Retention period | Legal basis |
|---|---|---|---|
| Local app data (sessions, presets, settings) | Operation of the app | Until the app is deleted | Art. 6(1)(b) |
| Screen Time configuration (app tokens) | Enforcement of blocks | Until the app is deleted | Art. 6(1)(b) |
| Pseudonymous user ID, vendor identifier (IDFV) | Loading the assigned paywall, linking purchases to the installation | Only for as long as required for the purpose, in accordance with Superwall’s privacy policy and the data processing agreement | Art. 6(1)(b), (f) |
| Device and app metadata | Displaying the appropriate offer for your region, language and currency | Only for as long as required for the purpose, in accordance with Superwall’s privacy policy and the data processing agreement | Art. 6(1)(b), (f) |
| Paywall interactions, experiment assignments | Measurement, A/B testing and optimisation of purchase offers | Only for as long as required for the purpose, in accordance with Superwall’s privacy policy and the data processing agreement | Art. 6(1)(f) |
| Purchase and entitlement data | Unlocking paid features | Duration of the subscription plus statutory retention periods | Art. 6(1)(b) |
| IP address | Establishing the technical connection | Only for the duration of the respective request | Art. 6(1)(b), (f) |
| Support emails | Handling your enquiry | Until your enquiry has been resolved | Art. 6(1)(f) |
6. iOS Permissions
offtime requests the following permissions only where they are needed for the relevant feature. You can grant or revoke each permission at any time in the iOS Settings.
- Family Controls / Screen Time: for blocking apps and categories (see Section 4.2 for details — processing takes place exclusively on the device). Legal basis: Art. 6(1)(b) GDPR.
- Camera: for scanning QR codes. Camera images are processed locally; no recordings are stored or transmitted. Legal basis: Art. 6(1)(b) GDPR.
- Photo library: for saving generated QR codes. Access is limited to the images you deliberately save. Legal basis: Art. 6(1)(a) GDPR.
- NFC: for optional NFC features, such as triggering blocks via NFC tags. The content of a tag is processed locally during a scan you initiate. Legal basis: Art. 6(1)(b) GDPR.
offtime does not request access to your location, and does not use the iOS location services.
App Tracking Transparency (ATT)
offtime does not carry out tracking for advertising purposes. We do not use an advertising identifier (IDFA), do not display advertising, and use neither advertising or attribution SDKs nor Superwall’s attribution features. Data about you or your device is not combined with third-party data for advertising or advertising measurement. For that reason, we do not request the App Tracking Transparency permission.
7. Subscription Management
7.1 Apple App Store / in-app purchase
Payment is handled exclusively through your Apple account. We do not receive your payment details. Apple’s privacy policy applies.
7.2 Superwall
Provider: Nest 22, Inc. (trading as "Superwall"), 2093 Philadelphia Pike #5307, Claymont, DE 19703, USA.
We use Superwall to display purchase offers (paywalls), to measure their effect, and to test and improve how they are presented. According to Superwall’s documentation, the following data may be processed through the SDK:
Identifiers
- A pseudonymous user ID (UUID) that the SDK generates automatically and stores on your device until you reinstall or reset the app, together with the aliases assigned to it
- The vendor identifier (IDFV) of your device — an identifier assigned by iOS that applies to this developer’s apps on your device and is reset once you delete all of them
- The public API key and the bundle ID of the app
Device and app metadata
- App version and build number, SDK version, and whether the app is running in a test environment
- iOS version, device model, interface type, whether the app is running on a Mac, network type, low power mode status, and light or dark appearance
- Language and preferred language, locale, region, currency code and currency symbol, time zone offset and local time
Product interaction
- Paywall events (such as paywall displayed, paywall dismissed, purchase started, purchase completed, purchase failed)
- Number of paywalls seen, time since installation, time since the last paywall view, and whether this is the first launch
- Assignment to A/B tests (experiments)
Purchases
- Details of completed in-app purchases (product identifier, transaction identifier, price, currency)
- Subscription or entitlement status
The Superwall SDK does not access the advertising identifier (IDFA). We do not use Superwall’s attribution features (Performance Marketing, Apple Search Ads). Superwall receives no Screen Time data, no session data, no presets and no other content that you create in offtime.
Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures and performance of the subscription contract) and Art. 6(1)(f) GDPR (legitimate interest in measuring, A/B testing and optimising paywall presentation).
7.3 Processing on our behalf
Superwall processes the data listed in Section 7.2 exclusively on our instructions and for the purposes stated there. A data processing agreement under Art. 28 GDPR (Data Processing Addendum) is in place with Nest 22, Inc. and forms part of Superwall’s terms of use. It governs, in particular, the scope of the processing, confidentiality obligations, the technical and organisational measures, the engagement of further sub-processors, and the deletion of data once the agreement ends.
Sub-processors: Superwall engages further service providers in order to deliver its services, in particular for hosting and infrastructure, databases and data analysis, and for notifications and support. These are contractually bound to a level of protection equivalent to that of the data processing agreement. The current list is available in Superwall’s Data Processing Addendum: https://superwall.com/legal/dpa
7.4 Transfers to the USA
Nest 22, Inc. processes data on servers in the USA. This covers the identifiers, metadata, interaction data and purchase data listed in Section 7.2, as well as your IP address for the duration of the respective request. The following safeguards apply:
- Standard Contractual Clauses of the European Commission under Art. 46(2)(c) GDPR, which Superwall makes available under the data processing agreement for transfers to countries without an adequacy decision.
- Technical measures: encryption of transmissions using TLS/SSL; pseudonymisation of user identifiers.
Please note: despite these safeguards, US authorities may under certain conditions gain access to data, in particular under FISA and the CLOUD Act. You can request a copy of the safeguards at apps@louiegaiser.com.
Superwall’s privacy policy: https://superwall.com/legal/privacy-policy/
8. Contacting Us
If you write to us by email, we process your name, your email address and the content of your message solely in order to handle your enquiry. Once it has been resolved, the data is deleted, unless statutory retention obligations apply.
Legal basis: Art. 6(1)(f) GDPR; for contract-related enquiries, additionally Art. 6(1)(b) GDPR.
9. Your Rights as a Data Subject
The GDPR grants you extensive rights in relation to the controller. In particular:
- Access (Art. 15 GDPR): information about the data we hold about you.
- Rectification (Art. 16 GDPR): correction of inaccurate or incomplete data.
- Erasure (Art. 17 GDPR): deletion of your data where the conditions are met.
- Restriction of processing (Art. 18 GDPR).
- Data portability (Art. 20 GDPR): receipt of your data in a structured, commonly used and machine-readable format.
- Objection (Art. 21 GDPR): against processing based on Art. 6(1)(f) GDPR.
- Withdrawal of consent (Art. 7(3) GDPR) with effect for the future.
- Complaint to a supervisory authority (Art. 77 GDPR).
An informal email to apps@louiegaiser.com is sufficient to exercise your rights. Since the majority of the data remains locally on your device, you can also take full control of your data by deleting the app.
Right to object
Where we process personal data on the basis of legitimate interests (Art. 6(1)(f) GDPR) — in particular for measuring, A/B testing and optimising paywalls via Superwall — you have the right to object to that processing at any time on grounds relating to your particular situation. An informal email to apps@louiegaiser.com is sufficient.
10. Security
We take technical and organisational measures appropriate to the state of the art to protect your personal data:
- Encrypted transmission: communication between the app and Superwall takes place over TLS/SSL.
- Protection on the device: local data is held in the iOS app sandbox and protected by iOS Data Protection.
- Selection of service providers: we select the service providers we use carefully and conclude data processing agreements under Art. 28 GDPR.
11. Children
offtime is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16 without the consent of a parent or guardian.
12. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy where necessary, for example because of new features or changes in legal requirements. The current version is always available in the app and on the website.
13. Contact
For questions about this Privacy Policy, to exercise your rights, or for any other data protection matter, you can reach us at:
Email: apps@louiegaiser.com
14. Last Updated
This Privacy Policy was last updated on 4 November 2026.