Legal
Last updated: September 26, 2026
This policy describes, pursuant to Articles 13 and 14 GDPR, which personal data we process in connection with the Writely app and this website (getwritely.app), for what purposes and on what legal basis. The German version is the legally authoritative one.
The essentials up front: Writely is built local-first. Your handwriting and your documents never leave your device. There is no user account, no server holding your content, no advertising, no tracking across apps or websites, and no training of AI models on your data. We collect anonymous usage statistics in the app only if you expressly consent — see section 8 for details.
The controller within the meaning of Art. 4 (7) GDPR is:
Alluson UG (haftungsbeschränkt)
Papenbütteler Weg 32
27729 Hambergen
Germany
Represented by its Managing Director, Mario Allers. Further details are set out in the Imprint.
Contact for all data protection matters: support@getwritely.app
We are not legally required to appoint a data protection officer and have not done so. Your enquiries are handled at the address above.
Writely is deliberately built local-first: your handwritten characters (“glyphs”), the documents created from them, your folder structure and your settings are stored solely on your device — not on a server of ours. The app embeds no advertising and no crash-reporting SDKs and does not track you across apps or websites. It can send anonymous usage statistics to our processor PostHog — but only after you have expressly agreed in the app, and never including content from your documents or handwritings (section 8).
This website collects anonymous first-party usage statistics only if you expressly consent beforehand — no advertising, no third-party trackers, no cross-site profiles. Without your consent, nothing is collected. Details are on the Cookies & Tracking page.
What: your handwriting glyphs, the documents you create including handwritten notes, your folder structure and your app settings.
Where: solely in the protected app container on your device.
Why: so the app can perform its core function — turning typed text into your own handwriting. Legal basis: Art. 6 (1) (b) GDPR (performance of the user agreement).
Disclosure: none. This data leaves your device only if you export or share it yourself, or if it is included in an iCloud or device backup. Such a backup is an operating system feature and is governed by Apple's privacy policy.
Retention: until you delete the content in the app or uninstall the app. See Data Deletion for details.
The app contains a prepared, optional account and cloud backup feature. It is fully disabled in the currently published build: there is no visible sign-in entry point, no account is created, and no account data is transmitted to any server. Instead the app uses a fixed local identifier that never leaves your device.
Supabase is intended as the infrastructure for later operation but is not currently connected. Before the feature is activated, we will update this section in advance with the data categories then transmitted, the storage location, the processing arrangement and the legal basis.
Writely Pro (subscription) and Writely Lifetime (one-time purchase) are handled exclusively through the in-app purchase system of the Apple App Store. Apple takes care of payment, invoicing and distribution; you conclude the contract for the unlocked features with us (see Terms and Subscription Terms).
We receive no payment data. Neither payment or bank details nor your name, billing address or Apple ID are transmitted to us. That data is processed solely by Apple as an independent controller under Apple's own privacy policy.
How the app checks your purchase status: using Apple's native StoreKit interface, the app reads directly on your device whether a valid purchase confirmation cryptographically signed by Apple exists. In doing so, the product identifier of the item purchased, the purchase date, any expiry date and the renewal status are processed on your device. This information remains local.
No third parties: no third-party purchase-mediation SDK is used — in particular no RevenueCat. We operate no server of our own to which purchase or device data would be transmitted, and no purchase data is passed on to us or to third parties. Only whether Pro is unlocked may be included as a yes-or-no attribute in the anonymous usage statistics described in section 8 — with no link to your person, your Apple ID or a purchase receipt.
Legal basis: Art. 6 (1) (b) GDPR (performance of the contract for the unlocked features).
The app counts locally on your device how many free exports you have created within the last 24 hours and how many handwritings and documents you have created. This count serves solely to enforce the free usage limits, remains exclusively on your device and is never transmitted to a server. Legal basis: Art. 6 (1) (b) GDPR.
Apple provides us as the developer with aggregated reports (App Analytics and sales reports): App Store page views, download figures, purchases, cancellation rates, device and country groupings, and aggregated crash statistics.
We receive these reports in aggregated form only. They do not permit any conclusions about individual persons, and Apple does not provide us with names, email addresses, Apple IDs or device identifiers. You control whether your device contributes to these statistics in the iOS settings under “Privacy & Security” › “Analytics & Improvements”.
Only after you agree: on first launch the app asks you once whether it may collect anonymous usage statistics. Without your “I agree” nothing is collected, nothing is stored and nothing is sent. Declining is exactly as easy as accepting, and closing the question without answering counts as not agreeing. You can change the decision at any time in the app under “Settings” › “Privacy” › “Usage statistics”.
What is collected: solely events recording that a feature was used — app opened, onboarding completed, document created, document generated, handwriting editor opened, handwriting saved, export started, shared or failed, paywall opened. Each event additionally carries: a random installation identifier, the time, app version and build, the iOS version, the device class (tablet or mobile), the app language setting, the chosen paper pattern, the export format, the page count of a generated document, the number of characters in a saved handwriting, and whether Pro is unlocked. It is also noted whether the build is a developer test build; in the published app this is always “no”.
What is expressly not collected: the content of your documents, their titles, the text you write or its length, the handwriting characters you draw, file names, your name, your email address, your location, your IP address, your Apple ID, or device and advertising identifiers from Apple (in particular the IDFA and the vendor identifier). The transmission explicitly suppresses storage of the IP address, and no country or location is derived from it. Because we use no advertising identifier, the app also shows no Apple tracking prompt.
The installation identifier is a random number (UUID) generated on first launch and stored only inside the app. It makes it possible to count returning use without identifying you, and it cannot be linked to other apps, to this website, or to a person. If you uninstall and reinstall the app, a new identifier is created and the old one leads nowhere.
Processor: the events are processed on our behalf by PostHog and stored on PostHog's infrastructure within the European Union. PostHog acts as our processor pursuant to Art. 28 GDPR; see sections 14 and 15 for details.
Legal basis: your consent pursuant to Art. 6 (1) (a) GDPR, and for storing the installation identifier on your device additionally § 25 (1) TDDDG. Purpose: to see which features are actually used and where people drop off, in order to improve the app in a targeted way.
Withdrawal: you can withdraw your consent at any time with effect for the future using the switch in the app settings. Nothing further is then collected or sent, and events on your device that have not yet been transmitted are discarded. Withdrawal does not affect the lawfulness of processing carried out up to that point. How to request deletion of events already transmitted is described under Data Deletion.
In the app, “Contact support” opens a pre-filled email to our support address in your own mail app — the app itself neither stores nor transmits anything in the process.
On the website we process the data entered in the contact form (name optional, email address, subject, message) in order to answer and handle your request. The legal basis is Art. 6 (1) (b) GDPR where the request serves the initiation or performance of a contract, and otherwise Art. 6 (1) (f) GDPR (legitimate interest in responding to enquiries). Your message is delivered to our support mailbox and additionally stored in an access-protected ticket store on our hosting server so that we can handle requests reliably and traceably. Only authorised persons have access; no disclosure to third parties takes place apart from the technical email delivery (see section 14).
If you reply to an email from our support team or write directly to our support address, that message is also assigned to the relevant case and stored. In addition to the message text, any file attachments, any HTML version of the message and the unaltered original email including its technical headers (among others sender, recipient, timestamp, message ID and delivery path) are stored in the same access-protected store. The purpose is handling your request and keeping it traceable.
Retention: cases are deleted once they are no longer required for handling, and at the latest three years after the last contact relating to that case; attachments and original emails are deleted together with the case. Longer statutory retention obligations — in particular under § 147 of the German Fiscal Code and § 257 of the German Commercial Code — remain unaffected; in those cases processing is restricted until the period expires. You may request deletion at any time (see Data Deletion).
To prevent spam, on submission we additionally check an invisible form field (honeypot), a time-based safety check and a short-lived server-side rate limit; for this only a pseudonymised counter (hash value) is stored briefly. Legal basis: Art. 6 (1) (f) GDPR (protecting our systems against automated abuse).
If you sign up for the waitlist on this website, we process your email address, your language choice (German/English) and the times of sign-up and confirmation.
Purpose: to notify you as soon as test slots or the launch of Writely are available. Legal basis: your consent under Art. 6 (1) (a) GDPR. We use a double opt-in procedure: without clicking the confirmation link in the sign-up email, your address is not added to the list and is not used further. We store the sign-up and confirmation timestamps in order to be able to demonstrate consent pursuant to Art. 7 (1) GDPR.
Storage: in an access-protected file on our hosting server. No disclosure to third parties takes place apart from the technical email delivery (see section 14).
Retention and withdrawal: until the launch notification, at the latest until you withdraw. Every waitlist email contains an unsubscribe link; alternatively, an informal message to our support address is sufficient. After unsubscribing, your address is deleted from the list. Withdrawal does not affect the lawfulness of processing carried out up to that point.
The app embeds no crash-reporting SDK: crash reports are sent neither to us nor to third parties. The anonymous usage statistics described in section 8 are independent of this and record no crash or diagnostic data — with one exception: if an export fails, the kind of error is recorded as a keyword, without file names and without content. Independently of this, iOS may generate its own crash reports and offer to send them to Apple; this is outside our control and is governed by Apple's own privacy notices. The aggregated reports Apple makes available to us are described in section 7.
The app uses no push notifications, no location services, no address book, no microphone and no camera.
When you access this website, our hosting provider processes technically necessary server logs (including IP address, timestamp, URL accessed, volume of data transferred and status code) in order to deliver and secure the site. Legal basis: Art. 6 (1) (f) GDPR; our legitimate interest lies in the stable and secure operation of the website. These logs are not combined with other data and are deleted regularly after a short period.
Hosting provider: operation of the website, storage of support cases and the waitlist, and processing of server logs. Processing agreement pursuant to Art. 28 GDPR.
Email delivery service: sending support and waitlist emails. Processing agreement pursuant to Art. 28 GDPR.
PostHog: processing of the anonymous in-app usage statistics described in section 8. The data is stored in the European Union. Processing agreement pursuant to Art. 28 GDPR. The provider is PostHog, Inc., established in the USA; on the third-country aspect see section 15.
Apple (App Store): handling of purchases and subscriptions and provision of the aggregated statistics described in section 7. Apple acts as an independent controller and not as our processor; Apple's own privacy policy applies.
Prepared but inactive: Supabase (accounts and cloud backup) — see section 4. RevenueCat is no longer intended and is not contained in the published app.
Beyond this we do not disclose personal data. Transmission to public authorities occurs only where we are legally obliged to do so.
Your content — handwritings, documents and folders — is not transferred to third countries; it remains local on your device. Hosting and email delivery for this website take place within the European Union.
The anonymous in-app usage statistics described in section 8 are stored on servers within the European Union. The provider, however, is PostHog, Inc., established in the USA, which may access those systems in the course of support and maintenance; access from a third country is therefore not excluded. We base this processing on the data processing agreement concluded with PostHog, including the European Commission's standard contractual clauses pursuant to Art. 46 (2) (c) GDPR.
Where processing by Apple in the course of handling purchases takes place outside the EU, it does so under Apple's own responsibility; according to Apple, such transfers are based on the European Commission's standard contractual clauses pursuant to Art. 46 (2) (c) GDPR.
Local app data: until you delete it or uninstall the app.
In-app usage statistics events: our processor's plan provides a retention window of twelve months; older events are no longer analysed. We delete individual events on request — see Data Deletion. Events your device has not yet transmitted are discarded immediately on withdrawal.
Support cases including attachments and original emails: until handling is complete, at the latest three years after the last contact; statutory retention obligations remain unaffected.
Waitlist: until the launch notification or until you withdraw.
Website statistics events: automatically deleted after 90 days at the latest.
Server logs: deleted regularly after a short period by the hosting provider.
Under the GDPR you have the following rights at any time:
You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is carried out on the basis of legitimate interests pursuant to Art. 6 (1) (f) GDPR. Here this concerns in particular the server logs, the spam protection measures and the handling of support requests outside a contractual relationship.
If you object, we will no longer process the data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims. An informal message to the contact address named above is sufficient to object.
Because all app content is stored locally on your device, you can obtain, correct and delete that content directly in the app — we have no access to it and can neither view nor restore it for you. For enquiries about support messages or the waitlist, see the Data Deletion page.
Providing your data is neither legally nor contractually required. The app can be used in full without giving us any personal data. Without an email address, however, we cannot answer a support request or inform you about the launch.
No automated decision-making, including profiling, within the meaning of Art. 22 (1) and (4) GDPR takes place. Your content is not used to train AI models — neither by us nor by third parties.
Writely is aimed among others at pupils and students. Neither the app nor the support form asks for an age or collects data beyond what is described above. Paid features are purchased through the Apple App Store; Apple's age and consent requirements apply, including Family Sharing.
This website is delivered exclusively over a TLS-encrypted connection (HTTPS). Support cases and the waitlist are held in access-protected areas that only authorised persons can reach. App content resides in the protected app container on your device and is therefore subject to the protection mechanisms of iOS, including the device passcode and device encryption.
We will amend this policy as soon as the actual processing changes — in particular when accounts or cloud backup are activated. The version published on this page is authoritative; the date of the last change is shown above.
