paplo.
Legal · Data protection

Privacy Policy

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Part A — WebsiteControllerOverviewHosting & deliveryContacting usCookies & consentUsage measurementYour rightsChangesPart B — paplo AppIn shortYour notesPhoto libraryDiagnosticsNo trackingDownload & purchaseChildrenYour rights

Part A — Website (paplo.app)

1. Controller

Eike Merx, Frickestrasse 42, 20251 Hamburg, Germany.
Email: eike@paplo.app

2. Overview

This website sets no cookies, shows no advertising, and does not track you across other sites or build user profiles. Apart from what is technically necessary to deliver and secure the site, the only additional processing is a privacy-friendly, cookieless usage measurement that stores nothing on your device and does not identify you (see Section 6). Because nothing is stored on, or read from, your device, no cookie/consent banner is shown.

3. Hosting and delivery (Cloudflare)

This website is delivered through Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA), acting as our processor under Art. 28 GDPR. When you access the site, Cloudflare automatically processes connection data ("server log data"), including:

  • your IP address,
  • date and time of the request,
  • the requested URL / resource,
  • the referring URL, if any,
  • your browser type and operating system (user agent).

This data is required to transmit the content to your browser and to keep the service secure and stable. Legal basis: Art. 6 (1)(f) GDPR (our legitimate interest in a secure, functioning website).

A data processing agreement (DPA) is in place with Cloudflare. As Cloudflare is based in the USA, data may be transferred to a third country. The transfer is safeguarded by the EU Standard Contractual Clauses; Cloudflare is additionally certified under the EU–US Data Privacy Framework.

4. Contacting us

If you contact us — by email at eike@paplo.app or through the contact form on this site — we process the data you provide (your name, email address, the chosen topic, and the content of your message) solely to handle your request. Legal basis: Art. 6 (1)(b) GDPR where your request concerns a (pre-)contractual matter, otherwise Art. 6 (1)(f) GDPR (legitimate interest in responding). We delete this data once your request has been resolved and no statutory retention periods apply.

Messages sent through the contact form are processed and delivered on our behalf by Resend (Plus Five Five, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA) as our processor under a data processing agreement; the same legal basis and deletion rules apply. As Resend is based in the USA, data may be transferred to a third country; the transfer is safeguarded by the EU Standard Contractual Clauses.

5. Cookies and consent

This website sets no cookies and uses no marketing or advertising services. The usage measurement described in Section 6 stores nothing on your device. Because nothing is stored on, or read from, your device, no cookie/consent banner is displayed.

6. Usage measurement (privacy-friendly analytics)

To understand how the site is used, for example how often pages are viewed and how often the "Download on the App Store" button is clicked, we measure a small number of events and improve the site based on them. This is done via server-side tagging: your browser sends the event to our own endpoint, which forwards it to Google Analytics 4. Google acts as our processor under Art. 28 GDPR.

What is measured:

  • the page URL, page title, and the referring URL (if any),
  • an "App Store button clicked" event and its position on the page,
  • an approximate engagement time (how long the page was in the foreground),
  • technical information about your browser and device — browser type and version, operating system, and device type (for example mobile or desktop) — which Google Analytics derives from the User-Agent your browser transmits with every request,
  • an approximate, coarse location (at most the country and region, not your precise position), derived from your IP address at our tagging endpoint before the IP is redacted (see below).

What we do not do:

  • store anything on your device: no cookies, no local or session storage. A random identifier used only to group the events of a single page view is generated in memory and discarded when you leave the page, so your visits cannot be linked across pages or over time,
  • forward your IP address: it is redacted at our tagging endpoint and is not passed on to, or stored by, Google Analytics,
  • build user profiles, track you across other sites, or show advertising.

Legal basis: Art. 6 (1)(f) GDPR (our legitimate interest in understanding and improving the website). Because nothing is stored on, or read from, your device, no consent under § 25 TDDDG (formerly TTDSG) is required. Google is based in the USA, so data may be transferred to a third country; the transfer is safeguarded by the EU Standard Contractual Clauses, and Google is additionally certified under the EU–US Data Privacy Framework. Aggregated data is retained only for a limited period in line with our Google Analytics settings and then deleted automatically.

7. Your rights

Under the GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), and to object (Art. 21). To exercise any of these, contact us at eike@paplo.app.

You also have the right to lodge a complaint with a supervisory authority. The authority responsible for us is:
Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI), Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany.

8. Changes to this policy

We may update this policy to reflect changes to the website or legal requirements.

Part B — paplo App (iPad)

1. In short

paplo is a calm, private notebook. There is no account, no ads, no cookies, and no behavioral tracking, and your notes never leave your iPad. The only data that leaves your device is anonymous crash and error diagnostics that help keep the app stable — these never contain your notes and never identify you.

2. Your notes stay on your device

Everything you create in paplo is stored locally on your iPad:

  • handwriting and drawings,
  • typed text blocks,
  • imported or pasted images,
  • page titles and the order of your pages.

This content is saved on your device only. We have no server that receives it, no account system, and no cloud sync. We cannot see your notes, and we never transmit them anywhere.

Your note files are protected by iOS file-level encryption (Data Protection), so they are encrypted at rest on a passcode-protected device. Exporting a PDF or .zip archive never removes anything from paplo — your note stays where it is, and the exported file lives wherever you save or share it. paplo only clears the temporary copy it created in its own cache.

3. Photo library access

If you choose to import an image, paplo asks for permission to access your photo library. This is used only to let you pick the image you want to add to a page. Imported images are then stored locally in paplo, like the rest of your notes. paplo does not browse, upload, or otherwise process your photo library.

4. Crash and error diagnostics

To find and fix bugs and crashes, paplo uses Sentry, a third-party error-monitoring service, to collect anonymous diagnostic data when something goes wrong.

What is collected:

  • crash reports and error stack traces (where in the code an error occurred),
  • the operating system name and version (e.g. "iOS 18"),
  • the paplo app version.

What is not collected:

  • the content of your notes — titles, text, drawings, and images are removed before any report is sent,
  • your name, email address, or any account information (paplo has none),
  • your IP address (storage is disabled),
  • your location (any approximate location derived from your network is discarded),
  • your device model or other identifying device details,
  • advertising identifiers,
  • any behavioral or usage analytics.

These diagnostics are not linked to your identity and are not used for tracking or advertising. They are used solely to keep the app working — to reduce crashes and improve stability and performance. Diagnostics are collected only in the released App Store version and are disabled during development.

Sentry processes this data on our behalf as a processor under Art. 28 GDPR, and the data is handled in the European Union (Frankfurt, Germany) region. Legal basis: Art. 6 (1)(f) GDPR (our legitimate interest in a stable, reliable app). Sentry's privacy information is available at sentry.io/privacy. Diagnostic data is retained only for a limited period and then deleted automatically.

5. No tracking, no ads, no cookies

paplo shows no advertising, uses no cookies or similar technologies, and does not track you across other apps or websites. We do not sell or share data with data brokers.

6. App download and purchase (Apple)

When you download or purchase paplo, the transaction is handled by Apple through the App Store. Apple processes the associated data (e.g. your Apple Account, payment, and download history) as the responsible controller under its own privacy policy. We receive only aggregated, anonymized sales statistics, which do not let us identify individual users.

7. Children

paplo is not directed at children and does not knowingly collect personal data from children.

8. Your rights

Because the crash diagnostics we collect are anonymous and not tied to your identity, we generally cannot connect that data to a specific person. The GDPR rights listed in Part A, Section 7 still apply where relevant. For any privacy question or request, contact us at eike@paplo.app.

Last updated · July 2026

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