Privacy Policy
Last updated: September 2026
This policy applies to the DocDuck iOS application and the docduck.app website, both published by Shirokamolab.
1. Who we are
Shirokamolab is operated by Artur Bielunov, a sole proprietor established in Germany.
Contact for privacy matters: privacy@docduck.app
2. What data we process and why
2.1 Crash reporting — Sentry
Purpose: Identifying and fixing software bugs to maintain app stability. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — a stable, error-free app is in the interest of all users. Processor: Functional Software, Inc. (Sentry) — data is hosted in the EU region (ingest.de.sentry.io) and stored within the European Union.
What is collected:
- Stack traces and crash reports
- Device model, iOS version, app version, and free memory at time of crash
- A sequence of anonymised in-app events leading up to the crash (no document content, no filenames, no personal information)
- A random, anonymous Sentry install ID that is not linked to any identity
What is not collected:
- IP addresses (
sendDefaultPII = false) - User names, emails, or any contact information
- Document content or filenames
- Performance traces (
tracesSampleRate = 0)
2.2 Analytics — PostHog
Purpose: Understanding how the app is used so we can improve it. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — product improvement benefits all users. Processor: PostHog, Inc. — data is hosted on PostHog EU Cloud (eu.posthog.com) and stored within the European Union.
What is collected:
- A random anonymous device ID (UUID generated on first install — no name, email, or account attached)
- Event names and timestamps: onboarding steps, paywall views, subscription events, document import actions
- App version, iOS version, and device model class (e.g. “iPhone”)
- Session start/end and app open/background events
- IP address, anonymised immediately on ingestion (IP anonymisation is enabled in PostHog project settings)
What is not collected:
- Document contents, filenames, or any document metadata
- Email addresses or any contact information
- iCloud account details
- Photos, scans, or any personal files
- Precise location
- Any text entered by the user
Opt-out: You can disable analytics at any time in Settings → Privacy → Share analytics. When opted out, no events are sent and no device ID is created or persisted.
2.3 Document storage — iCloud
Purpose: Syncing your documents across your devices. Legal basis: Contract performance (Art. 6(1)(b) GDPR) — delivering the iCloud vault feature you have chosen to use. Processor: Apple Inc. — governed by Apple’s Privacy Policy.
When you create an iCloud vault, your documents are stored in your personal iCloud Drive. DocDuck does not have access to a copy of your iCloud data; files are never routed through Shirokamolab servers. This applies only if you choose to use an iCloud vault — local and in-app vaults never involve iCloud.
2.4 On-device AI features
Automatic summarisation and automatic masking features run entirely on your device using Apple’s on-device AI frameworks (Apple Foundation Models). No document content is sent to any server, including Shirokamolab’s or any third-party AI provider, for these features.
2.5 In-app purchases
Purpose: Processing subscriptions and one-time purchases for paid features. Legal basis: Contract performance (Art. 6(1)(b) GDPR). Processor: Apple Inc. (StoreKit / App Store) — governed by Apple’s Privacy Policy.
DocDuck does not process payment data directly. All purchases are handled by the Apple App Store. We do not store or have access to your payment card details. Purchase receipts are verified on-device via StoreKit.
2.6 Contact and support
If you contact us by email, we retain that correspondence solely to respond to your enquiry. We do not add you to any mailing list or share your email with third parties.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
2.7 The docduck.app website
The website is a static site with no accounts, no forms, and no login. It sets no cookies, uses no local storage, and runs no tracking or fingerprinting in its own code. Fonts are served from the website itself, not from a third-party font provider.
Hosting — Cloudflare Pages. Purpose: Serving and securing the website. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — making the site available and protecting it against abuse. Processor: Cloudflare, Inc. When your browser requests a page, Cloudflare processes technical connection data in server logs — your IP address, user-agent string, the URL requested, referrer, and a timestamp. Cloudflare is based in the United States; transfers are covered by the EU Standard Contractual Clauses and Cloudflare’s certification under the EU–US Data Privacy Framework. See Cloudflare’s privacy policy.
Website analytics — Cloudflare Web Analytics. Purpose: Understanding how much the site is visited and where visitors come from, so we can improve it. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Processor: Cloudflare, Inc., acting on our behalf; Shirokamolab is the controller.
We use Cloudflare Web Analytics to measure traffic on this website. It is cookieless — it does not set cookies or use local storage to identify you. It collects aggregated, non-personal metrics only: page views, visits, referrers, approximate country (derived from your IP at Cloudflare’s edge and not stored), device type, and browser. It does not track individuals across websites and does not build user profiles. No personal data is sold, shared with third parties for advertising, or used for targeted marketing. The measurement script is loaded from static.cloudflareinsights.com.
Because no cookies are set and no personal data is collected, a consent banner is not required under the ePrivacy Directive and the GDPR; we disclose this use here for transparency.
Outbound links and redirects. The Download links redirect to the DocDuck listing on the Apple App Store, and the footer links to shirokamolab.com. Once you follow those links, the destination’s own privacy policy applies.
3. Data we do not collect
We do not collect, process, or sell your personal information beyond what is described above. We have no access to the documents, files, or content you store in DocDuck. All document processing (masking, summarisation, tagging) happens on your device.
4. Data retention
| Data | Retention period |
|---|---|
| Crash reports (Sentry) | 90 days |
| Analytics events (PostHog) | 2 years |
| Website server logs (Cloudflare) | Per Cloudflare’s retention for Pages access logs |
| Analytics opt-out preference | Until app is deleted |
| Support emails | Until the matter is resolved, then deleted |
5. Data transfers outside the EU
- Sentry: Data is processed and stored in the EU (ingest.de.sentry.io). ✓
- PostHog: Data is processed and stored in the EU (eu.posthog.com). ✓
- iCloud: Apple may store data across multiple regions per their own data transfer addendum.
- Cloudflare (website hosting and optional web analytics): Cloudflare, Inc. is US-based; transfers are covered by the EU Standard Contractual Clauses and its EU–US Data Privacy Framework certification.
- No other third-party services receive data from our apps or website.
6. Your rights under GDPR
If you are in the European Economic Area, you have the following rights:
- Right of access (Art. 15) — Request a copy of the data we hold about you.
- Right to rectification (Art. 16) — Request correction of inaccurate data.
- Right to erasure (Art. 17) — Request deletion of your data.
- Right to restriction (Art. 18) — Request that we limit how we use your data.
- Right to object (Art. 21) — Object to processing based on legitimate interests. For analytics, use the opt-out toggle in Settings at any time.
- Right to data portability (Art. 20) — Request your data in a structured, machine-readable format.
- Right to lodge a complaint — You have the right to complain to the supervisory authority in your member state. In Germany, the competent authority depends on your federal state (Bundesland). The federal authority is the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI): www.bfdi.bund.de.
To exercise any of these rights, contact us at privacy@docduck.app.
Because analytics data is collected anonymously (no name or email attached to the device UUID), the most effective way to stop future collection is the opt-out toggle in Settings → Privacy → Share analytics. For deletion of historical records, you can find your anonymous analytics ID in Settings → Privacy → Analytics ID — include it in your deletion request so we can locate your records precisely in PostHog.
7. Children’s privacy
DocDuck is not directed at children under the age of 16 (EU) or 13 (US). We do not knowingly collect personal data from minors. If you believe a minor has provided data, please contact us and we will delete it promptly.
8. California residents (CCPA)
We do not sell your personal information. We do not share personal information with third parties for cross-context behavioural advertising. California residents have the right to know what personal information is collected, to request deletion, and to opt out of sale — sale does not occur here so no further action is needed.
9. Changes to this policy
We may update this policy from time to time. Material changes will be announced via an in-app notice or App Store update notes. The “Last updated” date at the top of this page always reflects the current version.