Privacy Policy

Controller: Oliver Kornmann (sole proprietorship, Germany — full provider details added before public launch)
Contact: oliver.kornmann66@gmail.com
Published at: https://pitchroom-app.pages.dev/en/privacy

This Privacy Policy is a working draft. It will be reviewed by data-protection counsel before public launch. It does not constitute legal advice.

1. Who we are and our privacy principle

Pitchroom ("we", "us", "the app") is an iOS app that helps you practice oral exams, job interviews, presentations, negotiations, pitches, small talk, and custom scenarios using on-device AI feedback.

Privacy principle: Pitchroom is an on-device-first app. Audio and video recordings, as well as all AI analysis, happen exclusively on your device. There is no login, no cloud AI service, and no Pitchroom-owned server. The only data leaving your device is anonymized subscription status (Apple/RevenueCat) and optional anonymous crash reports.

The data controller under GDPR is the provider listed above.

2. What we collect, why, and how long

We process the absolute minimum. We do not sell personal data. We do not use it for advertising. We do not engage in cross-app tracking.

2.1 Subscription status (RevenueCat)

• What: Pseudonymous user ID (SHA-256 hash of your anonymous iCloud-account identifier), current subscription status (Free / Pro Monthly / Pro Annual), purchase date, expiry date, trial status. No Apple ID, no email, no real name.
• Why: Unlock premium features, enable "Restore Purchases" on new devices, prevent abuse.
• Legal basis: Contract performance (Art. 6(1)(b) GDPR).
• Retention: During subscription plus 7 years for German tax-record-retention requirements (§ 147 AO).
• Provider: RevenueCat Inc. (USA) — Data Processing Agreement + Standard Contractual Clauses.
• Note: We never see your credit card or your Apple ID password — Apple handles all payments.

2.2 Crash reports (optional, Sentry)

• What: Anonymized crash reports (device model, iOS version, stack traces). No content, no transcripts, no audio/video data, no user ID.
• Why: Find and fix bugs.
• Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) in a stable service.
• Retention: 90 days.
• Provider: Sentry GmbH (EU region) — Data Processing Agreement.

2.3 iCloud sync (Pro only, optional)

• What: Your sessions, recordings, analyses, and profile settings sync with your personal iCloud account.
• Why: Cross-device access to your practice history.
• Storage location: Your private iCloud database — Apple does not see the contents (CloudKit private database, end-to-end encrypted). We have no access to it.
• Legal basis: Contract performance (Art. 6(1)(b) GDPR) — Pro feature.
• Retention: Until you delete it. Account deletion in the app also removes CloudKit data.
• Provider: Apple Inc. (data processor under the Apple Developer Agreement).

2.4 Local data on your device (does NOT leave your device)

• Audio and video recordings during active sessions — processed locally only via Apple Vision Framework, AVFoundation, SFSpeechRecognizer (with `requiresOnDeviceRecognition = true`), and Apple Foundation Models. No upload, no cloud service.
• Transcripts and analyses — generated entirely on-device.
• Session history, streaks, personal best — in local SwiftData storage.
• Display name, goal selection, app settings — local.
• Storage location: Sandboxed app container on your device. For Pro: mirrored to your private iCloud database (see 2.3).
• Who has access: Only you. Not us. Not Apple (CloudKit encryption).

2.5 What we explicitly do NOT collect

• ❌ No account system — no email, no password, no login. No "Sign in with Apple".
• ❌ No cloud AI service — no OpenAI, Anthropic, Google, or other LLM provider. All AI runs on-device via Apple Foundation Models.
• ❌ No own backend — we do not operate a Pitchroom server, database, or auth system.
• ❌ No tracking — no IDFA, no advertising SDKs, no cross-app tracking, no App Tracking Transparency prompt needed.
• ❌ No advertising networks — no Facebook SDK, no Google Analytics, no AppsFlyer, no Branch.
• ❌ No product analytics — no PostHog, Mixpanel, Amplitude. An `AnalyticsService` interface exists in code as a stub for possible future use; currently it sends nothing.
• ❌ No access to Contacts, Photos, Location, Calendar, or Health data.
• ❌ No data sharing or sale to third parties.

3. Data processors

For data transfers outside the EU/EEA, we use Standard Contractual Clauses (SCCs) and supplementary measures.

4. Children

Pitchroom is rated 12+ in the App Store. Because the app has no account mechanism and no data uploads of its own, we do not collect personal data from children. Parents with questions can contact oliver.kornmann66@gmail.com.

5. Your rights

Under GDPR you have the following rights:

• Access to your data (oliver.kornmann66@gmail.com).
• Rectification of inaccurate data (display name editable in app).
• Erasure of all data: Settings → "Delete all data" — removes all local data, your CloudKit data, and dissociates your RevenueCat pseudonymous ID.
• Portability of your sessions (in preparation — v1.1).
• Objection to processing based on legitimate interest.
• Complaint to your supervisory data-protection authority.

We respond within 30 days.

6. Security

• Audio, video, and speech processing happens exclusively on-device — this data never leaves your device.
• iCloud sync (Pro) uses Apple's end-to-end-encrypted CloudKit Private Database. Even Apple does not see the content.
• RevenueCat traffic encrypted (TLS 1.2+). Only pseudonymous ID + subscription status are transmitted, no personal data.
• Sentry crash reports are transmitted without personal identifiers.

In the event of a notifiable data breach, we will inform affected users within 72 hours (Art. 33/34 GDPR).

7. Cookies and tracking

The app uses no web cookies. We do not use App Tracking Transparency (ATT) because we do not track you across other apps or websites.

This website (pitchroom-app.pages.dev) uses no tracking cookies, no analytics pixels, and no advertising tracking.

8. Apple App Privacy Labels

The App Store shows the following Privacy-Label categories for Pitchroom:

• Diagnostics — Crash Data (App Functionality / Not Linked to You / Not Used for Tracking)
• Purchases — Purchase History (App Functionality / Not Linked to You / Not Used for Tracking)
• All other categories: Not collected

9. Changes

We may update this policy. Material changes will be announced at least 30 days in advance in the app. The current version is at https://pitchroom-app.pages.dev/en/privacy.

10. Contact

• Email: oliver.kornmann66@gmail.com
• Response time: 72 hours
• Postal address: added before public launch

Deutsche Version: /privacy