Dumpling Template — Privacy Policy
Last updated 2026-11-02
This policy explains how Dumpling Software UG (haftungsbeschränkt), Kollwitzstrasse 76, 10435 Berlin, Germany (“we”) processes personal data when you use the mobile app Dumpling Template. We are the controller. Contact: rafal@dumpling.software.
1. No account, minimal data
The app works without an account. We do not ask for your name, email or location. The app uses a random, anonymous identifier generated on your device.
2. What we process
| Data | Purpose | Legal basis (GDPR) | Provider |
|---|---|---|---|
| Anonymous usage events (screens viewed, buttons tapped), app version, device model, OS | Improving the app, A/B tests | Consent (Art. 6(1)(a)) — off until you enable it in Settings; you can withdraw any time | PostHog Inc., EU data centre (Frankfurt) |
| Crash and error reports (stack traces, device model, OS, app version) | Keeping the app stable | Legitimate interest (Art. 6(1)(f)) | Functional Software Inc. (Sentry) |
| Purchase and subscription status, anonymous customer ID | Providing paid features, restoring purchases | Contract (Art. 6(1)(b)) | RevenueCat Inc.; payments are processed by Apple / Google, we never see your payment details |
| Technical request data (IP address, app runtime version) when the app checks for updates | Delivering app updates | Legitimate interest (Art. 6(1)(f)) | 650 Industries Inc. (Expo) |
3. Transfers outside the EU
Some providers are based in the USA. Transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses.
4. Retention
We keep data only as long as needed for the purposes above. Crash reports are deleted automatically by our provider after 90 days. Analytics events are deleted when they are no longer needed for analysing and improving the app; you can request deletion at any time. Purchase records are kept as long as required by tax and commercial law.
5. Your rights
You have the right to access, rectification, erasure, restriction, data portability and objection, and to withdraw consent. Because we only hold an anonymous ID, please include it (Settings in the app) when you contact us. You may also complain to a supervisory authority, e.g. the Berlin Commissioner for Data Protection and Freedom of Information.
6. Children
The app is not directed at children under 16.
7. Changes
We will update this page when the app's data processing changes.