wofoto

Privacy policy

Last updated: 14 October 2026

wofoto works without an account and without our own server. Your labels stay on your device. This policy explains which data the wofoto app and this website process, and which third parties are involved.

1. Controller

[TODO: full name or company with legal form]
[TODO: street and house number]
[TODO: postcode and city], Germany
Email: [TODO: privacy contact email]

[TODO: Data protection officer: name and contact if one is appointed – otherwise delete this sentence]

2. The wofoto app

Most data is processed only on your device. We, the provider, have no access to it and receive no copy.

No AI photo analysis. No face recognition. wofoto does not analyse what your photos and videos show. It uses no image recognition, no face recognition and no automatic tagging, either on your device or on a server. Titles and tags come only from you. The file fingerprints described in 2.1 are checksums of the file data. They are used only to match labels to the same file again and say nothing about the image content.

2.1 Labels stored on your device

Purpose
Giving photos and videos titles and tags, and finding them again.
Data
Titles, tags (place, person, topic), asset IDs, capture dates, file sizes, filenames, dimensions, video durations and file fingerprints (MD5).
Where
A local database on your device. Nothing is sent to us.
Legal basis
Art. 6 (1) (b) GDPR (providing the app you use).
Retention
Until you delete the labels or uninstall the app.

2.2 Access to your photo and video library

wofoto reads the photos and videos you allow, to show them and match them with your labels. It never copies, uploads or changes the originals. File fingerprints are calculated on your device by reading the original. Files that are only stored in the cloud are not downloaded for this. You can grant full or limited access.

2.3 Export and import

You can export your labels as a JSON or CSV file through the share menu of your device. The file contains only the metadata listed in 2.1, never photos or videos. You decide where it goes (for example a cloud drive, email or messenger). The provider of that destination is responsible for it under its own privacy terms. Importing reads a file you select and stays on your device.

2.4 Voice dictation

Purpose
Turning your speech into text for titles and tags.
Data
Audio while you dictate, and the resulting text.
Recipients
The speech service of your operating system: Apple (iOS) or Google (Android). Depending on your device and settings, audio may be processed on the device or by the provider’s servers. wofoto does not record or store audio.
Legal basis
Art. 6 (1) (b) GDPR. Dictation only starts when you tap the microphone, and you can always type instead.
Third-country transfer
Apple and Google may process data in the USA. See section 4.

2.5 Place suggestions (geocoding)

Purpose
Suggesting a place name for a photo.
Data
The GPS coordinates stored in the photo. Your current location is not recorded.
Recipients
The geocoding service of your operating system (Apple or Google), only when you ask for a place suggestion.
Legal basis
Art. 6 (1) (b) GDPR.
Third-country transfer
Possible to the USA. See section 4.

2.6 Purchases (wofoto Pro)

Purpose
Selling, unlocking and restoring wofoto Pro (monthly, annual or lifetime).
Payment
Payment is processed only by Apple (App Store) or Google (Google Play). We do not receive your payment details. Apple and Google act as separate controllers under their own privacy policies.
Purchase management
RevenueCat, Inc., USA, manages purchase status for us as a processor. It receives a pseudonymous customer ID, the purchased product, purchase and renewal status, and technical data such as the app version and device type. Photos, videos and labels are never sent to RevenueCat.
Legal basis
Art. 6 (1) (b) GDPR (performance of the purchase contract).
Retention
As long as needed for the purchase and for statutory retention duties. [TODO: check RevenueCat retention / data processing agreement]
Third-country transfer
USA, based on the EU-US Data Privacy Framework if the recipient is certified, otherwise on standard contractual clauses (Art. 46 (2) (c) GDPR). [TODO: verify RevenueCat DPF certification and DPA]

2.7 Permissions

You can grant or revoke every permission at any time in your device settings. Without a permission, only the related function is unavailable.

3. This website

3.1 Hosting and server log files

This website is hosted by ALL-INKL.COM – Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany, as our processor. [TODO: verify host details against the data processing agreement in KAS]

When you visit the site, the server automatically stores technical data in log files: IP address, date and time, the page requested, referrer URL, browser and operating system, and the amount of data sent. This is needed to deliver the site securely and to detect misuse. Legal basis: Art. 6 (1) (f) GDPR. The logs are deleted after [TODO: retention period of the host’s log files].

3.2 No cookies, no tracking

This website sets no cookies, uses no analytics or tracking tools, and loads no fonts, scripts or other content from third parties.

4. Transfers outside the EU

Some recipients named above (Apple, Google, RevenueCat) may process data in the USA. Transfers are based on the EU-US Data Privacy Framework (adequacy decision of the European Commission, Art. 45 GDPR) where the recipient is certified, or on standard contractual clauses (Art. 46 (2) (c) GDPR).

5. Your rights

You have the right to:

Data stored only on your device is under your control, and we cannot access it. You can view, export or delete it in the app at any time. See Delete your data.

You also have the right to lodge a complaint with a data protection supervisory authority, for example the one responsible for us: [TODO: name and address of the supervisory authority of the provider’s federal state].

6. Changes

We update this policy when the app or the law changes. The current version is always available at this address.