Privacy Policy

Effective date: 2026-05-17 Last updated: 19 October 2026

1. Introduction and Scope

This Privacy Policy explains how Halora ("the App", "we", "us", "our") handles information when you use the Halora app on iPhone (iOS) or on Android and when you visit our website. The controller within the meaning of Art. 4(7) GDPR is:

Lennox Kornmann
Am Pachtersgrund 14
98617 Meiningen
Germany
Email: halorasupport@gmail.com

We respect your privacy and have designed Halora to collect as little information as possible. The core of the App runs entirely on your device. The only personal data we ever process is what you choose to provide by optionally signing in, and what is needed to validate your Halora Pro subscription or purchase.

This Privacy Policy covers two things: (a) your use of the Halora App, both the iOS App distributed via the Apple App Store and the Android App distributed via Google Play, and (b) your visit to our website at https://halora-app.pages.dev. Sections 2 to 5 concern the App on both platforms; where the iOS App and the Android App work differently, this policy says so. Section 5a concerns the website and section 5b concerns our advertising. It does not apply to any other third-party service or website that may be linked from the App or the website.

We have not appointed a Data Protection Officer, as we are not required to do so under Art. 37 GDPR or § 38 BDSG.

2. Data We Collect (and Do Not Collect)

Data we do NOT collect

Halora has been built around the principle of data minimisation. We do not:

• Require an account to use the App, Mirror mode and all core features work fully as a guest, with no sign-in
• Collect your phone number or any contact details
• Use analytics SDKs (no Mixpanel, no Amplitude, no Firebase Analytics, no Google Analytics)
• Use attribution or tracking SDKs (no AppsFlyer, no Adjust, no Branch)
• Upload your photos, videos or camera frames to any server
• Display third-party advertising
• Use crash-reporting SDKs (no Firebase Crashlytics, no Sentry)
• Track you across other apps or websites (on iOS we do not present an App Tracking Transparency prompt because we do not track you; the Android App does not access the Android advertising ID)
• Sell or rent any data about you

Data processed on your device only

The App processes the following information locally on your iPhone or Android device, without transmitting it anywhere:

• Camera frames used to render the live ring-light preview and to take photos or record videos. These frames are processed on-device only.
• Photos and videos you create with the App, saved only when you actively tap the shutter or recording control. On iOS the App keeps copies of your latest 50 captures in its own on-device gallery, where you can delete them. You can also save them to your Photos library if you grant the relevant permission. On Android they are saved through the system media store (MediaStore) into a "Halora" album (Pictures/Halora for photos, Movies/Halora for videos); this needs no storage permission.
• Microphone audio for videos. On Android, the App records sound only while a video recording is running and saves it only inside that video file.
• App settings (such as last-used mode, preferred brightness, preferred colour temperature) and small counters (such as how many photos you saved today in the free version), stored locally on your device: in iOS UserDefaults on iPhone and in Android DataStore on Android.
• In-app gallery list (Android): a small local database with references to the most recent captures made with the App (at most 50, each with its file reference and capture time), so the App can show them in its gallery. The Android App only lists and opens its own captures; it does not read your other photos or videos.
• Technical event log (Android): a small text file in the App's private storage that keeps the last 200 technical events, such as "camera started", "photo saved" or an error message, to help understand crashes. It contains no photos, videos, account data or contact data, it is never uploaded or shared, and it is deleted when you uninstall the App.

If you tap Share, your device's share sheet hands the photo or video you picked to the app you choose. Halora itself does not upload it; what the receiving app does with it is governed by that app's own privacy policy.

Account data (only if you choose to sign in)

Signing in is optional. You can use the entire App without an account. On iOS, you can use Sign in with Apple in Settings > Account to link only the Halora Pro unlock to an account so it can follow to another device. In the Android App, you can sign in with Sign in with Google in Settings > Account, handled by Android's Credential Manager. On both platforms your settings stay on the device. If you sign in, we collect:

• Your name and email address as provided by Apple or Google, and a user ID that identifies your account.
• With Sign in with Google, also the details Google passes on with the sign-in: your Google account ID, whether your email address is verified, and the link to your Google profile picture. The App does not load or show the picture itself.

This account data is stored on our behalf by Supabase (our authentication and database provider; see section 5), which acts as our data processor and hosts the data in the European Union. You can delete your account and all associated data at any time from Settings → Account → Delete account, in the iOS App and in the Android App alike, or request deletion by email. How that works and what is deleted is explained on the Delete your account page.

Android: In the Android App, signing in currently only creates and keeps your account record at Supabase. Your Halora Pro purchase is linked to your Google Play account and is restored through Google Play (Settings → Halora Pro → Restore purchases), not through your Halora account. While you are signed in, the sign-in session issued by Supabase stays stored on your device so that you remain signed in; the App removes it when you sign out or delete your account.

Data processed by Apple, Google and our purchase processor

When you start an iOS Halora Pro subscription, buy Lifetime, or make the Android one-time Halora Pro purchase, the following limited information is processed:

• An app user ID used to manage your purchase. For guest users this is a randomly generated, anonymous ID. If you are signed in on iOS, this ID is your account user ID, which is associated with the name and email from your sign-in. In the Android App this ID is always a randomly generated, anonymous ID, even when you are signed in, and it is not linked to your account.
• Purchase transaction information from Apple or, in the Android App, from Google Play (purchase, renewal and refund events on iOS, and purchase and refund events on Android) for the purpose of verifying your Halora Pro entitlement.

This information is processed by RevenueCat, Inc. as our data processor (see section 5).

For App Store privacy-label purposes, Halora declares "Purchases" as collected because RevenueCat processes purchase transaction data on our behalf to verify your Halora Pro entitlement. For guest users and in the Android App this is not linked to your real identity; for users signed in on iOS it is associated with your account ID.

Apple itself processes payment information when you make a purchase. Halora never sees or stores your payment details. Please refer to Apple's Privacy Policy for details: https://www.apple.com/legal/privacy/

In the Android App, Google processes payment information through Google Play Billing when you make a purchase. Here too, Halora never sees or stores your payment details. See Google's Privacy Policy: https://policies.google.com/privacy

3. Data We Share

We share data only as strictly necessary to operate the App:

No data from the App is shared with advertisers or data brokers, and we never sell personal information. The two website-only recipients above are listed for completeness: Cloudflare because it hosts the pages you are reading, and Meta only if you have actively consented to advertising measurement on the website (section 5b).

If you have explicitly enabled crash and analytics sharing in iOS Settings (Settings > Privacy & Security > Analytics & Improvements > Share With App Developers), Apple may share aggregated, anonymised crash reports with us. This is a setting you control entirely through iOS; Halora does not contain its own crash-reporting SDK.

The Android App does not contain a crash-reporting SDK either. If you have allowed your Android device to share usage and diagnostics data with Google, Google may show us aggregated, anonymised crash and stability statistics in the Google Play Console. You control this in your Android device settings. The local technical event log described in section 2 is not part of this and never leaves your device.

4. Permissions We Request

Halora requests the minimum permissions needed to function.

iOS App

• Camera (NSCameraUsageDescription), required so the App can show the live preview and capture photos or video, and, when you use Light Match, read the brightness of your room. Camera access is used only while the App is in the foreground and only for the features you actively use.
• Add to Photos (NSPhotoLibraryAddUsageDescription), required only so the App can save the photos and videos you capture to your Photos library. The App does not read your existing photo library; it only writes new media you have just captured, and only when you tap the save/shutter control.
• Microphone (NSMicrophoneUsageDescription), asked when you open Video mode and used only for the sound of your clips while recording. If you decline, clips are recorded without sound.
• Notifications, asked only for the optional evening reminder: a local notification at 7:30 pm on evenings you have not opened Halora, created on your device. Nothing is sent to a server.

You may revoke any of these permissions at any time in iOS Settings > Privacy & Security. Revoking camera access will disable the App's core functionality; revoking Photos access will prevent saving captured media.

Android App

• Camera (android.permission.CAMERA), required so the App can show the live preview, capture photos or video and measure the ambient light for the light-match feature. The camera is used only while the App is open on screen.
• Microphone (android.permission.RECORD_AUDIO), used only to record the sound of videos you record in Video mode, and only while a recording is running. Android asks for it together with camera access when you set up the App. If you decline, the ring light, Mirror mode and photos keep working, but video recording is not available.
• Notifications (android.permission.POST_NOTIFICATIONS), listed in the App; however, the App currently sends no notifications and does not ask you for this permission.
• Vibration (android.permission.VIBRATE), used for short haptic feedback when you tap controls. It gives no access to any data and can be switched off in Settings → Haptics.
• Internet access (android.permission.INTERNET), used for the optional sign-in (Google, Supabase) and for purchases and purchase validation (Google Play, RevenueCat). Photos and videos are never transmitted.

The Android App requests no storage or media permission: it saves new captures into its own Halora album and cannot read your other photos or videos. Libraries built into the App also add technical permissions that Android grants automatically and that give no access to personal data: Google Play Billing (com.android.vending.BILLING) for purchases, network status, and the background-task permissions (wake lock, start after reboot, foreground service) used by Android's widget and task framework. The home screen widget, the Quick Settings tile and the cover screen widget for Samsung Galaxy Z Flip devices only show buttons that open the App in a chosen mode; they need no permission and process no personal data.

You can revoke camera and microphone access at any time in Android Settings > Apps > Halora > Permissions (the exact path can vary slightly by device manufacturer). Revoking camera access will disable the App's core functionality; without microphone access, video recording no longer works.

5. Third-Party Services

Supabase (optional account sign-in)

If you choose to sign in, we use Supabase to authenticate you (on iOS through Sign in with Apple, on Android through Sign in with Google) and to store your account record. On iOS this record links your Halora Pro unlock to your account so it can follow to another device; on Android, signing in currently only creates the account record (see section 2). Settings stay on the device. Under the GDPR, Supabase acts as our data processor (Auftragsverarbeiter). Supabase stores your name, email address and account user ID, with Google sign-in also your Google account ID and the link to your profile picture, and hosts this data in the European Union. For each sign-in session Supabase also stores the IP address, a technical identifier of the App (user agent) and the times of sign-in and refresh; this session data is deleted at the latest together with your account. See https://supabase.com/privacy. You can delete this data at any time via Settings → Account → Delete account, on iOS and on Android.

RevenueCat (purchase validation)

We use RevenueCat to validate purchases made through Apple In-App Purchase (iOS) and Google Play Billing (Android) and to process iOS subscription status and manage your Halora Pro entitlement. Under the GDPR, RevenueCat acts as our data processor (Auftragsverarbeiter) on the basis of a written data processing agreement.

We also use RevenueCat's aggregated reports on these purchase events and on how often the Halora Pro purchase screen is shown, for example how many free trials turn into subscriptions, to understand and improve Halora Pro. These reports contain no name, email address, photos or videos.

RevenueCat receives only:

• Your app user ID (a random anonymous ID for guests, or your account user ID if you are signed in on iOS; in the Android App always a random anonymous ID)
• Purchase transaction events from Apple (such as purchase, renewal and refund) or Google Play (such as purchase and refund)
• On iOS, a short note each time the Halora Pro purchase screen is shown, so we can count how often it appears

RevenueCat does not receive your name, email address, payment details, photos, or videos.

RevenueCat is based in the United States. See its privacy policy at https://www.revenuecat.com/privacy and its security and compliance information at https://www.revenuecat.com/security.

Apple In-App Purchase

All payments are processed by Apple. Halora never receives or stores your payment card or Apple ID credentials. See https://www.apple.com/legal/privacy/.

Google Play Billing (Android)

In the Android App, Halora Pro is a one-time purchase processed by Google through Google Play Billing. All payments, refunds and your purchase history are handled by Google Play. Halora never receives or stores your payment card details or your Google account credentials. See https://policies.google.com/privacy.

Sign in with Google (Android)

If you choose Sign in with Google in the Android App (Settings → Account), Android's Credential Manager shows you your Google accounts to choose from. After you pick one, Google gives the App a sign-in token that confirms your Google account, including your name, email address and profile picture link; the App passes it to Supabase to create your session. Halora never receives your Google password. Google's processing is governed by https://policies.google.com/privacy. You can see and manage which apps are connected to your Google account at https://myaccount.google.com/connections.

5a. Our Website (halora-app.pages.dev)

This section applies only when you visit our website. It does not describe the App.

Hosting and server logs

The website is a set of static pages hosted by Cloudflare, Inc. on Cloudflare Pages. When you open a page, your browser necessarily transmits technical information to Cloudflare's servers, which is processed to deliver the page and to keep the service secure and available:

• your IP address,
• the date and time of the request,
• the page or file requested and the HTTP status returned,
• the referring URL, if your browser sends one,
• your browser type, version and operating system.

We do not run our own web analytics on this data, we do not build visitor profiles from it, and we do not combine it with any App data. Cloudflare processes it as our data processor (Auftragsverarbeiter) under a data processing agreement and under the EU Standard Contractual Clauses. See https://www.cloudflare.com/privacypolicy/. The legal basis is our legitimate interest in operating a secure and functioning website (Art. 6(1)(f) GDPR).

Cookies and local storage

The website sets no cookies at all unless you have given consent for advertising measurement as described in section 5b. If you make a choice in the consent banner, that choice alone is stored in your browser's local storage (key halora-consent-v1) so that we do not ask you again. That entry stays in your browser, is never transmitted to us, and can be removed at any time by clearing your browser's site data.

No contact form, no newsletter

The website has no contact form, no comment function, no newsletter sign-up and no user accounts. If you email us at the address above, we process your message and your email address solely to answer you (Art. 6(1)(b) and (f) GDPR) and delete the correspondence once it is no longer needed and no retention obligation applies.

External links

Links to the App Store lead to Apple's servers, and links to Google Play lead to Google's servers. Once you follow such a link, the privacy policy of Apple or Google applies; we receive no information about what you do there. See https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy.

5b. Advertising and Measurement

We advertise Halora. This section explains exactly what that does and does not mean for your data.

The App itself contains no advertising or tracking technology

Advertising happens outside the App. The Halora App, on iOS and on Android, contains no advertising SDK, no attribution SDK and no analytics SDK (see section 2), shows no ads, and does not track you across other apps or websites. This remains true regardless of which advertising channels we use.

Advertising platforms (Meta, Apple)

We may run ads for Halora on platforms including Meta Platforms Ireland Ltd. (Facebook, Instagram) and Apple Search Ads. When we do, the platform itself decides which of its users are shown our ad and reports back only aggregated, statistical results, for example, how many people saw or clicked an ad. We do not receive, and do not ask for, any information that identifies you personally as a viewer of an ad.

The platform's own processing of your data as its user is governed by its own privacy policy and is outside our control: Meta at https://www.facebook.com/privacy/policy/ and Apple at https://www.apple.com/legal/privacy/. Apple Search Ads attribution operates through Apple's privacy-preserving framework and does not identify individual users to us.

Meta pixel on this website, only with your consent

To measure whether our ads actually work, we may use the Meta pixel on this website. If it is active, it is loaded only after you have explicitly agreed in the consent banner. Until you agree, and if you decline, or simply ignore the banner, no Meta script is loaded, no cookie is set and no data is transmitted to Meta.

If you do consent, the pixel transmits to Meta: your IP address, information about your browser and device, the page you are on, and the fact that you clicked through to the App Store. Meta uses this to report campaign performance to us and may link it to your Facebook or Instagram account if you have one. In this respect we and Meta act as joint controllers within the meaning of Art. 26 GDPR for the collection and transmission of the data; the joint-controller arrangement is available at https://www.facebook.com/legal/controller_addendum. Meta's onward processing is carried out by Meta on its own responsibility.

• Legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG.
• Withdrawing consent: you can withdraw at any time with effect for the future, clear this site's data in your browser (which deletes the stored consent entry and makes the banner reappear so you can decline), or email us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Third-country transfer: Meta Platforms Ireland Ltd. is the controller for users in the EU/EEA, but data may be transferred to Meta Platforms, Inc. in the United States. The transfer is based on the EU-U.S. Data Privacy Framework, under which Meta is certified, and additionally on the European Commission's Standard Contractual Clauses. Despite these safeguards, it cannot be entirely excluded that U.S. authorities may access such data.

If no consent banner appears on this website, the pixel is not configured and nothing described in this subsection is taking place.

6. Children's Privacy

Halora is rated 4+ in the App Store. The App, on iOS and on Android, is suitable for general audiences and does not contain content directed at children.

We do not knowingly collect personal information from children under the age of 16 (or the applicable age in your jurisdiction). Because Halora can be used fully without an account, most users provide no personal data at all.

On iOS, in-app purchases require either the user's Apple ID password or a parent's approval through Apple's Family Sharing and Ask to Buy features. Parents are encouraged to use Apple's parental control and Screen Time settings to manage in-app purchases on a child's device. On Android, purchases go through Google Play, where parents can require approval or authentication for purchases, for example with Google Family Link.

If you believe that a child has provided personal data to us, please contact halorasupport@gmail.com and we will take reasonable steps to delete it.

7. Your Rights

Under the EU General Data Protection Regulation (GDPR) and similar laws (including the UK GDPR, the Swiss FADP, Brazil's LGPD, and the California Consumer Privacy Act/CPRA), you have the following rights regarding your personal data:

• Right of access, to know what personal data we hold about you
• Right to rectification, to correct inaccurate data
• Right to erasure ("right to be forgotten"), to have your data deleted
• Right to restriction of processing, to limit how we use your data
• Right to data portability, to receive your data in a portable format
• Right to object, to object to certain processing
• Right to withdraw consent at any time, where processing is based on consent
• Right to lodge a complaint with a supervisory authority

If you signed in, you can exercise your right to erasure directly in the App, on iOS and on Android, via Settings → Account → Delete account, which immediately deletes your account and associated data from Supabase. You can also request deletion by email to halorasupport@gmail.com, for example if the App is no longer installed; we answer within 30 days. What is deleted and what is kept is explained on the Delete your account page. You can also email halorasupport@gmail.com for any other request, including resetting or deleting the purchase app user ID held by RevenueCat.

California residents (CCPA/CPRA)

If you are a California resident, you also have the right to:

• Know what personal information is collected about you
• Request deletion of personal information collected about you
• Opt out of the sale or sharing of personal information (we do not sell or share personal information in the meaning of the CCPA)
• Not be discriminated against for exercising your rights

To exercise any of these rights, contact halorasupport@gmail.com. We will respond within the timeframes required by applicable law.

Supervisory authority

EU/EEA residents have the right to lodge a complaint with their local data protection supervisory authority. The competent authority for the operator is:

Thüringer Landesbeauftragter für den Datenschutz und die Informationsfreiheit (TLfDI)
Häßlerstraße 8
99096 Erfurt, Germany
Telephone: +49 361 57 3112900
Email: poststelle@datenschutz.thueringen.de
Web: https://www.tlfdi.de

You may also lodge a complaint with the supervisory authority of your own place of residence or workplace.

8. International Data Transfers

Your optional account data is stored with Supabase in the European Union, so account sign-in does not, by itself, involve a transfer outside the EU/EEA.

RevenueCat, Inc. is established in the United States. When we transmit app user IDs and purchase transaction information to RevenueCat, this constitutes a transfer of data to a third country in the meaning of GDPR Articles 44 et seq. We rely on the following safeguards for this transfer:

• The EU-U.S. Data Privacy Framework (DPF) where applicable, and
• The European Commission's Standard Contractual Clauses (SCCs) as supplemental safeguards

For details, see RevenueCat's processing terms at https://www.revenuecat.com/dpa and its privacy notice at https://www.revenuecat.com/privacy.

Apple processes data globally under its own legal framework; see https://www.apple.com/legal/privacy/. The same applies to Google for Google Play, Google Play Billing and Sign in with Google; see https://policies.google.com/privacy.

Website-side transfers

Cloudflare, Inc. (website hosting, section 5a) operates a global network, so server log data may be processed outside the EU/EEA. The transfer is covered by the European Commission's Standard Contractual Clauses in Cloudflare's data processing addendum, and Cloudflare is certified under the EU-U.S. Data Privacy Framework.

Meta (advertising measurement, section 5b), only if you have consented. Meta Platforms Ireland Ltd. is the EU-facing controller, but data may reach Meta Platforms, Inc. in the United States under the EU-U.S. Data Privacy Framework and the Standard Contractual Clauses. If you do not consent, no such transfer takes place.

9. Retention

• On-device data (app settings, on iOS the in-app gallery with copies of your latest 50 captures, and on Android the in-app gallery list and technical event log) remains on your device until you delete it in the App or delete the App. Photos and videos you saved (in your Photos library on iOS, in the Halora album on Android) stay until you remove them yourself. We have no access to any of it. The Android App excludes its local data from Android's automatic cloud backup.
• Account data (name, email, account user ID, with Google also the Google account ID and profile picture link, plus session data) held by Supabase is retained until you delete your account (Settings → Account → Delete account, on iOS and on Android) or request deletion by email. We carry out a deletion requested by email within 30 days.
• App user ID and purchase state held by RevenueCat are retained for as long as needed to administer your Halora Pro entitlement and to comply with applicable tax and accounting obligations (typically up to 10 years under German law for financial records associated with purchases).
• Apple-held and Google-held transaction records are governed by Apple's and Google's own retention policies.

Website data

• Server log data held by Cloudflare is retained only for the short period needed for delivery, security and abuse prevention, in line with Cloudflare's own retention practice, and is not archived by us.
• Your consent choice is stored in your own browser until you clear your site data. We hold no copy of it.
• Meta pixel data (only if you consented) is retained by Meta under its own retention policy; we only ever see aggregated campaign reports.

10. Security

We apply reasonable technical and organisational measures to protect any data we process:

• All network communications use TLS encryption in transit; the Android App technically blocks unencrypted connections.
• Optional account data is stored by Supabase (EU) behind authentication and row-level access controls; we do not run our own additional servers.
• RevenueCat and Supabase maintain industry-standard security practices; see https://www.revenuecat.com/security and https://supabase.com/security.
• Halora never uploads captured photos or videos; they only leave your device if you share them yourself.

No security measure can be guaranteed to be perfect; however, given how little personal data we process, the practical risk from a Halora-side breach is limited.

11. Legal Bases for Processing (GDPR)

Where the GDPR applies, our legal bases for processing are:

• Performance of a contract (Art. 6(1)(b) GDPR), for validating your Halora Pro purchase via RevenueCat and Apple or Google Play, and for providing the optional account sign-in and linking your iOS Halora Pro unlock to your account at your request
• Consent (Art. 6(1)(a) GDPR), when you choose to sign in (providing your name and email) and when you grant Camera or Photos permissions (iOS) or Camera or Microphone permissions (Android)
• Legitimate interests (Art. 6(1)(f) GDPR), for basic purchase validation, fraud prevention and aggregated purchase statistics
• Legal obligation (Art. 6(1)(c) GDPR), for retention of financial records under German tax law
• Legitimate interests (Art. 6(1)(f) GDPR), website: delivering the pages you request and keeping the site secure and available (section 5a)
• Consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG), website: the Meta pixel for advertising measurement, which runs only if you agree in the consent banner (section 5b)

You may withdraw consent at any time with effect for the future: delete your account, revoke the relevant permission in iOS Settings or Android Settings, or, for the website, clear this site's data in your browser so the consent banner reappears and you can decline. Withdrawal does not affect the lawfulness of processing carried out beforehand.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this document indicates when the policy was last revised. Material changes will be communicated within the App or by updating the policy at https://halora-app.pages.dev/privacy.

Continued use of the App or the website after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. Where we rely on your consent, we will ask for it again rather than relying on a policy update.

13. Contact

If you have any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact:

Lennox Kornmann
Email: halorasupport@gmail.com
Web: https://halora-app.pages.dev

We will respond to verifiable requests within the timeframes required by applicable law (typically within one month under GDPR).