Privacy Policy — distribot
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Privacy Policy

Last updated: 21 August 2026. This is the only privacy policy for distribot. It covers the distribot iPhone app (section 1) and the website distribot.de (sections 4 onwards) in one document — there is no separate app policy, and the app links to this page. The two are described separately because they behave completely differently: the app collects nothing, the website unavoidably processes some technical data.

1. The distribot app — the short version

The distribot app collects no personal data. None.

There is no distribot user account, no sign-in to us and no registration. There is no distribot server that the app talks to. Version 1.0, the version in the App Store today, connects to no outside service at all: it never asks you to authorise access to an account, and it stores no access tokens of any kind.

A future version 1.1 is planned to add an optional connection to TikTok. It has not been released, and the paragraphs below describe version 1.0 unless they say otherwise. What is planned for 1.1, and what it would and would not change, is set out further down under “The planned TikTok connection”. This policy will be updated before any version that processes data is released — not afterwards.

What the app stores, and where

Everything you do in the app is written to storage on your own device and stays there:

  • the weekly posting goal you chose,
  • which posts you checked off — including any you add back for an earlier day of the same week — and the streak that results from them,
  • the name you gave your penguin, and the state your penguin is in,
  • the furniture and the cosmetic items you have unlocked, and how you have placed them in the igloo and on the penguin,
  • the settings you choose in the app: your weekly goal, and the day and time of your weekly reminder if you switched one on.

None of this is transmitted to us, and none of it is transmitted to anybody else. We cannot see it, we cannot restore it and we cannot delete it for you — because it never reaches us.

Reminders

The app can remind you once a week, on a day and at a time you choose yourself in the profile. If you switch that reminder on, the app schedules it on your device itself. Nothing is sent from a server, because there is no server. iOS will ask you once whether the app may show you notifications; that permission is granted to the app on your iPhone and can be withdrawn at any time under Settings → Notifications. We are not told whether you granted it, and no information about a reminder reaches us.

Third parties, tracking and advertising in the app

The app contains no advertising network, no analytics or measurement tool, no crash reporting service and no third-party tracking SDK. It does not use the Advertising Identifier (IDFA) and does not ask for App Tracking Transparency permission, because there is nothing to track. This holds for version 1.0 without qualification, and we intend it to keep holding: the planned TikTok connection described below is a publishing function you switch on yourself, not a tracking or advertising component, and we do not plan to add advertising, analytics or tracking to the app.

In version 1.0 no data is collected, so no data is shared with any third party, and there is therefore no third party that would need to give it equal protection.

The planned TikTok connection (version 1.1)

This describes a version that has not been released. It is not in the App Store today. It may change or be dropped before release. We describe it now so that you can see where the app is going before it gets there.

Version 1.1 is planned to let you publish a post to your own TikTok account from inside the app, instead of switching to another app first. Connecting would be entirely optional: the app is planned to keep working fully without it, exactly as version 1.0 does.

If you chose to connect, this is what would happen to data:

  • You would sign in with TikTok, not with us. The sign-in would take place with TikTok directly. We never see your TikTok password, and there would still be no distribot account and no distribot server.
  • The access token would stay on your iPhone. It would be stored in your device's own secure storage, used only to talk to TikTok from the app while you are using it, and never transmitted to us. We would hold no copy, which also means we could not use it, lose it or hand it over.
  • A small amount of information would come back from TikTok — the account nickname and, where TikTok provides it, the profile picture and the settings your account allows for a post. This is needed so that the app can show you which account it is about to post to before you confirm. It would be held on your device, for display, and would go when you disconnect or delete the app.
  • Your post would go straight from your iPhone to TikTok. It would not pass through any system of ours, because we do not operate one. We would never receive the content you publish.
  • Nothing would be published without your confirmation in that moment. There would be no scheduling, no queue and no background publishing.
  • You could disconnect at any time, inside the app, without contacting us. Disconnecting would remove the token and the account information from your device. See our Data deletion page.

TikTok decides for itself what happens to data on its side. Once a post reaches TikTok, TikTok processes it under its own privacy policy and its own terms. We are not a joint controller with TikTok, we hold no copy, we have no access to your TikTok account, no ability to read your content there, and no way to delete anything from it — that is done in TikTok's own app or website.

Transfer outside the EU/EEA. TikTok is not a European company and personal data transferred to it may be processed outside the EU/EEA, including in countries whose data protection level is not equivalent to the EU's and where your enforcement options are weaker. That is a consequence of using TikTok itself, not of using distribot. Because the connection would be optional and started by you, the legal basis would be your consent under Art. 6(1)(a) GDPR, asked for in the app before anything is connected, and withdrawable at any time by disconnecting.

When version 1.1 is released, this section will be rewritten in the present tense, the App Store privacy label will be updated to match, and the exact wording will be checked against what the released version actually does.

Retention and deletion in the app

Data stored on your device stays there for as long as the app is installed. Deleting the app deletes everything with it. No copy remains anywhere, because no copy was ever made. There is no account to close and no deletion request to send us — and equally, nothing we can recover once it is gone.

If your iPhone backup includes app data, a copy may exist in that backup. That backup belongs to you and is governed by your own iCloud or local backup settings, not by us.

If you have connected TikTok in a future version 1.1, disconnecting would remove the access token and the account information from your device immediately, and deleting the app would do the same. Neither would delete anything from your TikTok account — posts already published live on TikTok and are removed there. See our Data deletion page.

The one thing that can reach us — and it does not come from the app

For completeness, there is a single path by which something about the app can end up with us. It runs through Apple, not through the app. If you have switched on Settings → Privacy & Security → Analytics & Improvements → Share With App Developers on your iPhone, Apple may make crash reports and coarse usage statistics about the app available to us through App Store Connect.

That switch belongs to your iPhone, not to us: we cannot turn it on, we are not told whether it is on, and we can turn it off for nobody. What arrives is prepared by Apple, is not linked to a name, an email address or a device we could identify, and we use it for one thing — finding out that the app crashed and why. If you would rather we never see even that, turn the switch off; the app works exactly the same either way.

To be precise about who is doing what: Apple is the collector here, not us. The app transmits nothing. Under Apple’s own rules a developer “is not responsible for disclosing data collected by Apple”, and data processed only on the device is not treated as collected at all — which is why the App Store privacy label for distribot states that no data is collected. This section is here because we would rather name the one remaining path than let you discover it somewhere else.

Consent

Version 1.0 asks for no consent to data processing, because it carries out none. There is consequently no consent for you to withdraw.

The planned TikTok connection in version 1.1 would be different, and would be handled properly: nothing would be connected until you have been told what is about to happen and have agreed to it, the agreement would be asked for in the app and not buried in a document, and withdrawing it would be a single action — disconnecting — that is exactly as easy as giving it. This policy will be updated before that version is released, not afterwards.

Children

The app is not directed at children and, since version 1.0 collects no data from anybody, it collects no data from children either. Connecting a TikTok account in a future version would require a TikTok account, which TikTok itself makes subject to its own minimum age.

2. Controller

The controller responsible for the processing described in this policy within the meaning of Art. 4(7) GDPR is:

Aron Taner
Burgfriedstr. 15
83024 Rosenheim
Germany

Email: hello@distribot.de
Phone: +49 160 98123994

A data protection officer does not have to be appointed: under Art. 37 GDPR in conjunction with § 38 BDSG (German Federal Data Protection Act), the obligation begins at 20 people permanently engaged in the automated processing of personal data, and we are far below that. You can address all data protection matters directly to the contact details above.

3. Scope of this policy

There is one privacy policy for everything we run, and this is it. Section 1 covers the distribot iPhone app; sections 4 to 17 cover the pages served under distribot.de. The app links to this page rather than carrying a policy of its own, so that there is never a second version that can drift out of date. This policy does not cover websites we link to; those are the responsibility of their own operators, and we have no influence over how they handle your data. It also does not cover Apple's own processing when you download the app from the App Store — that is described in Apple's own privacy policy.

4. What this website does — and what it does not do

This website is an information page about the distribot app. It has no user account, no login, no payment, no sign-up of any kind and no form at all. There is nothing here for you to fill in and send to us.

It makes no connection to any account of yours, and it embeds no content from third-party services — no external fonts, no video players, no social plugins, no advertising network. When you open a page, your browser talks to our hosting provider and to nobody else, unless you have consented to analytics (section 8).

Consequently the only data that can arise about you here is: the technical connection data your browser has to transmit for the page to load at all (section 5), the record of your own cookie decision on your device (section 7), optional analytics data if you consented (section 8), and whatever you choose to write to us by email (section 9).

5. Hosting and server log files

This website is hosted and delivered by Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA (Cloudflare Pages and CDN). Cloudflare processes data on our behalf as a processor under Art. 28 GDPR; a data processing agreement is in place.

Every time a page is retrieved, your browser necessarily transmits data that is recorded in server log files:

  • your IP address,
  • date and time of the request,
  • the page or file requested and the amount of data transferred,
  • the HTTP status code (whether the request succeeded),
  • the referring URL, if your browser sent one,
  • browser type and version, and operating system.

This data is technically unavoidable: without your IP address the response cannot reach your device. We use it to deliver the website, to keep it available and secure (in particular to detect and fend off attacks and abuse) and to diagnose faults. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure, stable and error-free operation of the website. We do not merge this data with other data sources, we do not use it to identify you, and we do not build profiles from it.

Further information from Cloudflare: cloudflare.com/privacypolicy.

6. Fonts

The fonts “Fredoka” and “Nunito Sans” are stored on our own hosting and delivered together with the website. No connection is made to Google Fonts or to any other font service, and no data is transmitted to a third party in order to display type.

7. Cookies and storage on your device (§ 25 TDDDG)

Storing information on your device, or reading information already stored there, requires your consent under § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act, formerly TTDSG) — unless it is strictly necessary to provide a service you expressly requested.

Strictly necessary — no consent required

Your cookie decision itself is stored in your browser's local storage under the key db_cookie_consent_v1. It records only whether you allowed analytics and when you decided, and it never leaves your device. This is strictly necessary under § 25(2) no. 2 TDDDG, because its sole purpose is to remember your decision so that you are not asked again on every visit. Clearing it via the “Cookie Settings” button, or clearing your browser storage, removes it.

Optional — only with your consent

Website analytics (section 8) sets cookies and reads storage on your device. It is loaded only after you have actively agreed. If you decline, or simply ignore the banner, no analytics script is loaded at all.

Marketing

We do not use marketing or advertising cookies, and we do not run any advertising network, retargeting or cross-site tracking on this website.

On your first visit you are shown a banner where you can accept, decline, or open the settings and decide per category. You can change your decision at any time with effect for the future using the “Cookie Settings” button at the bottom left of every page. Withdrawing is exactly as easy as consenting.

None of this applies to the app. The app sets no cookies, shows no banner and asks for no consent, because it processes nothing.

8. Website analytics: Microsoft Clarity

Only if you have consented, we use Microsoft Clarity, a web analytics service of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, and its parent Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA.

Clarity records how the website is used — page views, clicks, mouse movement, scroll depth, and from these it builds session recordings and heatmaps — together with coarse technical information such as browser, operating system, approximate region and screen size. Text entered into input fields is masked automatically. We use it for one purpose: to see where the page is confusing or broken and to fix it. We do not use it to identify individual visitors, and we do not try to link the recordings to a named person.

Legal basis: your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may withdraw your consent at any time with effect for the future via the “Cookie Settings” button; the lawfulness of processing carried out before the withdrawal is unaffected.

Microsoft acts as a processor for this and is contractually bound to protect the data to the standard described in this policy. Further information: Microsoft Privacy Statement and Microsoft Clarity documentation.

9. Contact by email

If you write to us at hello@distribot.de, we process your email address, your message and any information you choose to include, in order to handle your enquiry. Legal basis: Art. 6(1)(b) GDPR where your message concerns a (prospective) contract, otherwise Art. 6(1)(f) GDPR on the basis of our legitimate interest in answering enquiries addressed to us.

Please note that ordinary email is transported unencrypted between mail servers and can, in principle, be read along the way. Do not send us sensitive information by email; if something is sensitive, say so and we will agree a different channel.

10. Recipients of your data

We do not sell your data, we do not rent it out, and we do not pass it to advertising networks or data brokers. Data is disclosed only to:

  • Cloudflare as our hosting provider (processor, Art. 28 GDPR) — unavoidably, since it delivers the site;
  • Microsoft for website analytics, and only if you consented (section 8);
  • our email provider, to the extent you write to us;
  • public authorities and courts, where we are legally obliged to disclose, or where disclosure is necessary to establish, exercise or defend legal claims.

All of these relate to the website only. Version 1.0 of the app has no recipients at all, because it sends nothing to anyone. The only thing that can move in the other direction is described in section 1 under Apple's own diagnostics, and there Apple is the sender, not the recipient.

If you connect TikTok in a future version 1.1, TikTok becomes a recipient of what you choose to publish through it — sent directly from your iPhone, not through us. TikTok processes that data under its own privacy policy and for its own account, and we hold no copy of what passes between you and it. We do not share any data with TikTok that you have not chosen to publish, and no data reaches TikTok unless you connect it and confirm a post.

Cloudflare and our email provider act as processors under Art. 28 GDPR: they are bound by contract and by the GDPR to protect the data to at least the standard described in this policy, and may not use it for their own purposes. TikTok, in a future version 1.1, would not be a processor of ours — it decides for itself what happens to data on its side and processes it under its own privacy policy, which we cannot bind to this one. That is why the connection would be optional and would require your agreement first.

11. Transfers to countries outside the EU/EEA

Cloudflare and Microsoft are US groups, so a transfer of personal data to the USA cannot be ruled out. Such transfers are safeguarded by the EU Standard Contractual Clauses under Art. 46(2)(c) GDPR together with additional technical and organisational measures, and, where the recipient is certified under the EU–U.S. Data Privacy Framework, by the European Commission's adequacy decision of 10 July 2023 under Art. 45 GDPR.

A residual risk remains: despite these safeguards, it cannot be entirely excluded that US authorities gain access to data held by US providers, and your enforcement options there are weaker than in the EU. Analytics, which is the only transfer that is not technically unavoidable, therefore never runs without your consent.

12. Storage periods

We delete personal data as soon as the purpose for which it was collected no longer applies and no statutory retention period requires us to keep it.

  • App data: stays on your device until you delete the app. We never hold a copy.
  • Crash reports via Apple (only if you enabled “Share With App Developers”): held in App Store Connect under Apple's own retention rules, which we cannot shorten. We stop looking at a report once the fault is understood and keep no copy of our own.
  • Server log files at Cloudflare: deleted according to Cloudflare's standard retention, typically within a few days.
  • Your cookie decision: stays on your device until you clear it; it is never transmitted to us.
  • Analytics data: stored by Microsoft under its own retention rules. Withdrawing consent stops further collection immediately.
  • Email correspondence: kept for as long as needed to deal with your enquiry and any follow-up questions, then deleted — unless commercial or tax law requires longer retention (generally 6 or 10 years under § 257 HGB, § 147 AO).

13. Your rights

You have the following rights in relation to the personal data we hold about you, free of charge:

  • Access (Art. 15 GDPR) — what we process about you, and why.
  • Rectification (Art. 16 GDPR) — correction of inaccurate data.
  • Erasure (Art. 17 GDPR) — see Data Deletion.
  • Restriction of processing (Art. 18 GDPR).
  • Data portability (Art. 20 GDPR) — your data in a structured, commonly used, machine-readable format.
  • Withdrawal of consent (Art. 7(3) GDPR) — at any time, with effect for the future, without affecting the lawfulness of what happened before.
  • Complaint to a supervisory authority (Art. 77 GDPR) — see section 14.

Right to object (Art. 21 GDPR)

Where we process your data on the basis of a legitimate interest (Art. 6(1)(f) GDPR — on this website that is the hosting and server logs described in section 5), you have the right to object at any time on grounds relating to your particular situation. We will then stop processing that data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or unless the processing serves to establish, exercise or defend legal claims. An objection to direct marketing is always effective and needs no reason; we do not currently carry out any direct marketing.

To exercise any of these rights, an informal email to hello@distribot.de is enough. We reply without undue delay and in any event within one month of receipt (Art. 12(3) GDPR); if a request is exceptionally complex we may extend that period by up to two further months and will tell you why within the first month. We may ask one question to verify your identity, so that nobody can obtain or delete another person's data.

For app data these rights have an unusual answer: there is nothing for us to give you access to, correct, restrict, port or erase, because we hold nothing. Deleting the app is the complete and immediate exercise of your right to erasure over it.

14. Right to lodge a complaint

If you believe that our processing of your data infringes data protection law, you can lodge a complaint with a supervisory authority — in the Member State of your residence, place of work, or of the alleged infringement. The authority competent for us is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany
lda.bayern.de

15. Data security, minors, automated decisions

Security

This website is delivered exclusively over an encrypted TLS connection (HTTPS), which you can recognise by the lock symbol in your browser. We apply a strict content security policy: by default no content from third-party servers can be loaded into the page, and the only exception is the analytics script described in section 8, which loads solely after you have consented. Beyond that we take appropriate technical and organisational measures under Art. 32 GDPR to protect data against loss, manipulation and unauthorised access, and we review them as our systems change. The app's data is written to your device's own storage, where it is protected by iOS's own app sandbox and by your device encryption — and it is never sent anywhere, which removes the whole class of risks that come with transmission and server storage.

No automated decision-making

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR).

Minors

Neither the website nor the app is directed at children. We do not knowingly collect data from children; if you believe a child has provided us with data through this website, please write to us and we will delete it. The app collects nothing from anybody.

Is providing data required?

You are neither legally nor contractually obliged to provide us with any data. Apart from the technical connection data that is unavoidable for any website to load, everything on this page is voluntary, and declining has no consequence for you. The app works fully without you providing anything to us at all.

16. Changes to this policy

We will update this policy when the app or the website changes, or when the legal situation changes. The current version always applies and is always available at this address; the date at the top tells you which version you are reading. If a future version of the app ever begins to process personal data, this policy will be updated before that version is released, and where consent is needed we will ask for it rather than rely on an old one.

17. Contact

Questions about this policy, or about your data in general: hello@distribot.de. How to reach us for anything else is on our Support page; postal address and further details are in the Imprint (Legal notice).