Privacy Policy

Effective October 30, 2026

Who we are

PencilLight (the "App") is provided by the data controller:

"We", "us" and "our" in this policy mean samko labs, s. r. o.

Data the App processes on your device

• Camera. With your permission, the App shows the live camera image so you can see your paper. Camera frames are processed in memory to display the overlay, take a photo of your drawing when you tap Capture, or build a time-lapse when you record one. Nothing is sent off your device.
• Photos you choose. When you pick a photo, the App gets only that photo through the system photo picker. It does not get access to the rest of your library.
• Saving to Photos. If you tap Save, the App asks for permission to add the photo or video to your library. It cannot read your library with this permission.
• Outlines. Sketch outlines and subject detection use Apple frameworks (Core Image and Vision) that run entirely on your device.
• Local storage. Recently used images, your captures and your settings (for example whether you finished onboarding) are stored in the App's private storage on your device. They are deleted when you delete the App.

We have no access to any of this data.

Data we collect

The App itself does not collect personal data. It contains no advertising, no tracking and no third-party analytics SDKs, and it does not use your data to track you across apps or websites. The only records we hold are the purchase notifications Apple sends us, described below.

Purchases

Subscriptions and the lifetime purchase are sold and processed by Apple through the App Store. Apple handles your payment details under its own privacy policy. The App checks on your device, through Apple's StoreKit, whether you have an active purchase.

To keep our accounting and handle refunds, Apple sends our server a notification each time a purchase, renewal, cancellation or refund happens (App Store Server Notifications). Each notification contains Apple's transaction identifiers, the product, the price and currency, the App Store country and the relevant dates. It does not contain your name, email address, Apple ID or any information from your device, and the App itself never sends us anything. We store these records on Cloudflare servers in the EU and keep them for as long as accounting and tax law requires (in Slovakia, 10 years). The legal basis is our legal obligation to keep accounting records (Art. 6(1)(c) GDPR) and our legitimate interest in managing subscriptions (Art. 6(1)(f) GDPR).

Crash reports

If you have chosen in iOS Settings to share analytics with app developers, Apple may send us anonymous crash and performance reports. These do not identify you, and you can turn them off at any time in Settings › Privacy & Security › Analytics & Improvements.

When you contact us

If you email us, we process your email address and the content of your message to answer you. The legal basis is our legitimate interest in providing support (Art. 6(1)(f) GDPR) or taking steps at your request (Art. 6(1)(b) GDPR). We keep this correspondence only as long as needed to resolve your request, and at most three years, unless the law requires longer.

This website

This website is hosted by Cloudflare, which processes technical data such as IP addresses and browser information to deliver and protect the site. The site sets no cookies and uses no analytics or trackers. Fonts are served by Google Fonts, which receives your IP address when your browser loads them.

Children

PencilLight is suitable for all ages and does not collect personal data from anyone, including children. Purchases are made through Apple, so parents can use Ask to Buy and Screen Time to control them.

Your rights

Under the GDPR you have the right to access, correct and delete your personal data, to restrict or object to its processing, and to data portability. As the App collects no personal data, there is usually nothing for us to provide or delete. To use any of these rights for data we hold (for example a support email), contact us at the address above.

You can also file a complaint with the Slovak data protection authority: Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava, dataprotection.gov.sk, or with the authority in your own EU country.

Changes

If we change how the App handles data, for example by adding optional analytics, we will update this policy and its effective date before the change takes effect, and say so in the App's release notes.

Contact

Questions about privacy: samo@vrablik.eu