1.  Scope and Responsible Party

This Privacy Policy applies to the following iOS/iPadOS/macOS applications:

• PageWave — eBook and Audiobook Player
• Vigilance-Test — Reaction Time and Vigilance Measurement App

Both apps are provided by the same developer (hereinafter “Developer”). Contact details are available on the App Store page of each app and on the official app website.

2.  Core Principle: No Collection of Personal Data

Both apps are built according to the principle of Privacy by Design. The Developer does not collect, store, process, or transmit any personal data of its users.

Specifically, for both apps:

• No user accounts or registration required
• No usage statistics or telemetry sent to the Developer; crash reports are sent exclusively to Apple (only with the user’s explicit consent) and are subject to Apple’s Privacy Policy
• No tracking, advertising, or analytics SDKs
• No processing of location, contact, or other device data
• No sharing of data with third parties by the Developer
• No servers operated by the Developer

3.  PageWave — App-Specific Provisions

3.1  Locally Stored Data

Imported eBooks, audiobooks, reading progress, bookmarks, and app settings are stored exclusively on the user’s device. The Developer has no access to this data at any time.

3.2  iCloud Synchronisation

PageWave uses Apple’s iCloud (CloudKit / iCloud Drive) to optionally sync app data between the same user’s Apple devices. The following data is synced:

• Imported media files (eBooks, audiobooks)
• Reading progress and bookmarks

The Developer has no access to data stored in iCloud. iCloud sync is optional and can be disabled at any time in System Settings under the Apple ID account. Data processing by iCloud is governed exclusively by Apple’s own Privacy Policy (apple.com/legal/privacy).

3.3  MagicMetadata — iTunes Search API

PageWave includes a feature called “MagicMetadata”. When importing a file, the app can automatically fill in missing metadata (e.g. title, author, description, cover image) by sending a search request to Apple’s public iTunes Search API.

The following applies:

• Requests contain only book metadata (e.g. title, author) — no personal user data
• The iTunes Search API is a public service operated by Apple
• Apple may log these requests on its servers; this is subject to Apple’s own Privacy Policy
• The MagicMetadata feature is optional; users can import files without triggering a metadata lookup
• No search queries or results are stored or forwarded by the Developer

Legal basis for EU users: As no personal data is transmitted, no legal basis under Art. 6 GDPR is required. The data involved consists solely of technical metadata necessary for the feature’s functionality, sent exclusively to an Apple-operated service.

3.4  Imported Content

Users import their own DRM-free files into the app. These files remain exclusively on the user’s device or in their personal iCloud account. The Developer has no access to these files. Users are solely responsible for ensuring that imported content has been lawfully acquired and that they hold the right to use it.

4.  Vigilance-Test — App-Specific Provisions

4.1 Measurement data and test results

Vigilance-Test measures reaction times over several minutes and generates an evaluation of current vigilance. Test results are optionally stored locally on the user’s device to enable features such as personalized long-term charts.

4.2 iCloud Synchronization

Vigilance-Test uses Apple’s iCloud (CloudKit / iCloud Drive) for optional synchronization of app data between the same user’s Apple devices. The following data is synchronized:

• Testresults

The provider has no access to data stored in iCloud. iCloud usage is optional and can be deactivated at any time in the system settings under Apple account settings. Data processing by iCloud is governed exclusively by Apple’s own privacy policy (apple.com/legal/privacy). The following applies to all measurement data:

4.1  Measurement Data and Test Results

Vigilance-Test measures reaction speeds over several minutes and generates a summary of the user’s current vigilance. Test results can optionally be saved locally on the user’s device to enable features such as personal long-term charts.

The following applies to all measurement data:

• All data is stored exclusively on the user’s device
• No data is transmitted to the Developer, external servers, or third parties
• Saved results can be permanently deleted by the user at any time
• The app does not read from or write to the Apple Health app

4.2  Classification of Measured Data

Vigilance-Test is categorised as a Utility in the App Store. The app measures reaction times as a technical performance metric — comparable to a stopwatch tool. No medical diagnosis or health assessment is made or claimed.

As no data leaves the device and no profiling or tracking takes place, there are no data protection risks associated with the processing of sensitive data categories.

5.  Third-Party Services

Neither app integrates any analytics, advertising, or social media services from third parties, and neither uses any corresponding SDKs.

The following Apple-operated services may be used:

• iCloud (PageWave): sync between the user’s own devices — Apple’s Privacy Policy applies
• iTunes Search API (PageWave, MagicMetadata): public metadata lookup — Apple’s Privacy Policy applies

None of these connections include personal user data transmitted by the Developer.

6.  User Rights

6.1  Swiss Federal Act on Data Protection (revFADP)

Under the revised Swiss Federal Act on Data Protection (revFADP, in force since 1 September 2023), data subjects have the right to access, rectification, portability, and deletion of their data. As the Developer does not process any personal data, these rights have no practical effect in relation to the Developer.

6.2  EU General Data Protection Regulation (GDPR)

The GDPR (EU 2016/679) grants EU citizens extensive data protection rights. As neither app processes personal data, no legal basis under Art. 6 GDPR is required. The Developer acts solely as an app distributor without any data processing of its own.

6.3  Other Jurisdictions (USA, Global)

Both apps comply with the requirements of the California Consumer Privacy Act (CCPA) and comparable data protection laws in other jurisdictions, as no personal data is collected or sold.

7.  Data Security

As no user data leaves the user’s device, no server-side security measures by the Developer are required. The security of locally stored data depends on the security settings of the user’s device (device passcode, Face ID / Touch ID, device encryption via iOS/macOS).

8.  Minors

Neither app is specifically directed at children under 13 (USA: COPPA) or under 16 (EU: Art. 8 GDPR). As no user data is collected, no particular risks arise in this regard.

9.  Apple App Store

Both apps are distributed exclusively through Apple’s App Store. Apple may collect data in connection with the purchase and download of apps; this is governed solely by Apple’s Privacy Policy. The App Store pages of both apps include an “App Privacy” label as required by Apple, confirming that no user data is collected.

10.  Changes to This Privacy Policy

The developer reserves the right to update this privacy policy as needed. The date of the last update is shown below. Significant changes will be announced through an updated version in the App Store.

11.  Contact

For questions regarding this Privacy Policy, please contact the Developer:

Email: papayas-tahini-2u@icloud.com

We aim to respond to all enquiries within 30 days.

12.  Disclaimer

12.1  General

Our apps are developed and maintained with great care. However, we cannot guarantee that data will be available, complete, or error-free at all times. Use of the apps is at the user’s own risk.

All apps are provided “as is”, without warranty of continued availability, specific functionality, or fitness for a particular purpose. The Developer reserves the right to modify, restrict, or discontinue features at any time.

12.2  Imported Content (PageWave)

PageWave enables the import and playback of DRM-free eBooks and audiobooks. Users are solely responsible for ensuring that they are entitled to use the content they import. The Developer accepts no liability for infringement of copyright or other third-party rights through imported content.

12.3  No Medical Validity (Vigilance-Test)

Vigilance-Test measures reaction times as a technical performance metric. The results and analyses provided by the app do not constitute a medical diagnosis, clinical assessment, or substitute for professional medical advice. The app is not intended for medical or therapeutic use and has not been approved as a medical device.

If you have health concerns — in particular regarding concentration, reaction ability, or fatigue — please consult a qualified medical professional.

12.4  Limitation of Liability

To the extent permitted by applicable law, the Developer excludes all liability for direct or indirect damages arising from or in connection with the use or inability to use the apps. This includes in particular data loss, device damage, or loss of profit.