---
title: "Privacy Policy — Develak Apps & Website"
description: "How Develak (PRIOMAT LLC) protects your data on develak.com and in its iPhone, iPad and Mac apps: no tracking, no ads, data kept on your device and in iCloud."
url: https://develak.com/privacy-policy/
language: en
updated: 2026-10-04
source: Develak
translations:
  fr: https://develak.com/fr/politique-de-confidentialite.md
---

Canonical page: <https://develak.com/privacy-policy/>

# Privacy Policy

Last updated October 4, 2026

This Privacy Policy explains how Develak, the iOS app studio of PRIOMAT LLC, collects, uses and protects personal data when you visit develak.com or use any of our apps for iPhone, iPad and Mac. The short version: our apps are built to keep your data on your device and in your own iCloud account, our website has no advertising or analytics cookies, and we never sell your data.

## At a glance

- **No account with us.** None of our apps asks you to sign up or log in.
- **Your app data stays yours.** What you record in our apps is stored on your device and, if you turn on sync, in your own private iCloud account. We cannot see it.
- **Apple Health data is protected.** It is read or written only with your explicit permission, used only for the features you enable, never used for advertising or marketing, never sold and never stored on our servers.
- **No tracking, no ads.** Our apps contain no third-party advertising or tracking SDKs and do not track you across other companies’ apps or websites. Each app’s “App Privacy” label on the App Store currently reads “Data Not Collected”.
- **A quiet website.** develak.com uses no advertising or analytics cookies and no third-party trackers.
- **Payments are handled by Apple and Stripe.** In-app purchases and subscriptions are handled by Apple. The invoices of our client services are paid through Stripe. We never see your full card details.
- **You stay in control.** You can delete your data at any time and exercise your privacy rights by writing to [contact@develak.com](mailto:contact@develak.com).

## Who we are

Develak is a brand of **PRIOMAT LLC**, a limited liability company registered in the State of New Mexico, USA, whose registered office is at 2105 Vista Oeste St NW, Suite E-1324, Albuquerque, NM 87120, USA.

PRIOMAT LLC (“Develak”, “we”, “us”) is the controller of the personal data described in this policy, meaning we decide why and how it is processed. For any privacy question, write to [contact@develak.com](mailto:contact@develak.com). We have not appointed a data protection officer, as the law does not require one for our activities; privacy requests are handled directly by the people who build our apps.

## Scope of this policy

This policy applies to:

- our website, develak.com, in English and in French;
- every app published by Develak on the App Store, for iPhone, iPad and Mac, whether you use it for free or with an in-app purchase or subscription (the full list is on our [apps page](https://develak.com/apps/));
- the messages you send us by e-mail or through our contact form;
- the services we provide to our clients: quotes, contracts, invoices and payments (see Clients and payments).

It does not cover services run by other companies, even when our apps rely on them: the App Store, your Apple Account, iCloud, Apple Health and other Apple services are governed by the [Apple Privacy Policy](https://www.apple.com/legal/privacy/). Apps we build for our clients are published under their own name and their own privacy policy.

The “App Privacy” section of each app’s App Store page summarizes what that app collects. Where an app offers a specific feature described below (Apple Health, location, microphone…), the corresponding section of this policy applies to it.

## Visiting our website

You can browse develak.com without telling us who you are. To deliver and protect the site, some technical data is processed automatically:

- **Server logs.** Like any web server, ours records the IP address, date and time, requested page, referring page, browser type (user agent) and response status of each request. The site is hosted by OVHcloud on a server we manage.
- **Security.** Our security software, Wordfence, analyzes incoming requests (IP address, requested URL, user agent) to block attacks and records blocked requests and login attempts. Data about blocked attacks, including the IP address involved, may be shared with its publisher, Defiant, Inc. (USA), to improve protection across the sites it secures.
- **DNS.** Cloudflare, Inc. operates our domain name system and may process connection data, such as IP addresses, to route and protect traffic to the site.
- **Images hosted by Apple.** Our pages show official App Store badges and app screenshots served directly by Apple (from toolbox.marketingtools.apple.com and mzstatic.com). When your browser loads them, Apple receives your IP address and standard request data, as with any image hosted elsewhere.

We use this data only to run the site, keep it secure and fix errors. We do not use analytics tools, advertising networks, social media plugins, embedded videos or externally hosted fonts, and we do not build visitor profiles.

## Cookies and local storage

develak.com uses no advertising or analytics cookies. That is why you will not see a cookie banner. Only strictly necessary technical storage is used:

- **Theme preference.** If you switch between light and dark mode, your choice is saved in your browser’s local storage (key `dvk-theme`). It stays on your device and is never sent to us. Clear your browser’s site data to remove it.
- **Administrator cookies.** WordPress and our security and caching tools set cookies only for the site administrators who log in, not for visitors.
- **Network security.** When Cloudflare’s protection is active, Cloudflare may set a strictly necessary security cookie (such as `__cf_bm`) to distinguish people from bots.

These strictly necessary items are exempt from consent under European rules. Because we do not track you, there is nothing to opt out of; we nevertheless treat a Global Privacy Control or Do Not Track signal from your browser as a valid request not to sell or share your data.

## Contacting us

When you use our contact form, we receive:

- your name, e-mail address, the topic of your message, the app concerned (if any), your company (optional) and your message;
- the language of the page and the date of sending;
- to fight spam and abuse, a one-way hash of your IP address (we do not store the address itself) and your browser’s user agent.

Your message is stored in our website’s database and forwarded to our mailbox, [contact@develak.com](mailto:contact@develak.com). The form protects itself with a hidden field, a timing check and a limit of a few messages per hour per connection. The same applies when you e-mail us directly: we receive your address, your message and anything you choose to attach.

**Google reCAPTCHA.** When our anti-spam protection is switched on, our forms also use Google reCAPTCHA v3. Its script is loaded only once you start filling in a form; it then sends Google information about your device and your interaction with the page (such as your IP address, browser data and cookies set by Google) so that Google can assess whether the form is being used by a person. Google Ireland Limited / Google LLC acts as our processor for this check, under its [Privacy Policy](https://policies.google.com/privacy) and [Terms of Service](https://policies.google.com/terms). We only receive a risk score; our legal basis is our legitimate interest in protecting the form from abuse (Art. 6(1)(f) GDPR).

We use this information only to answer you, provide the support or project follow-up you ask for, and keep the form free of spam. We never add you to a mailing list and never send you marketing e-mails without your explicit consent.

## Using our apps

Our apps are designed to work without us. They follow the same principles:

- **No account.** You never create an account with Develak and you never give us your name or e-mail address to use an app.
- **Data stored on your device.** Everything you enter (entries, notes, photos, measurements, settings) is stored in the app’s private storage on your device, protected by iOS data protection. We do not receive it and have no server that collects it.
- **Exports generated on your device.** PDF reports, CSV files and other exports are created on your device. You decide where to send them (Mail, AirDrop, Files…); once shared, the recipient’s own practices apply.
- **Reminders generated on your device.** Reminders and alerts are scheduled locally by iOS, based on the settings you choose in the app.
- **Widgets and Shortcuts.** When you use them, data moves only between the app and its extensions on your own devices.
- **Face ID and Touch ID.** Some apps let you lock them with Face ID or Touch ID. Authentication is performed by iOS; we never receive biometric data.

**Information about other people.** Some apps let you record information about someone else, for example a relative whose medication you manage, a child in your care or a dive buddy. That information stays on your device and in your iCloud, like the rest of your data. Please make sure you are entitled to record it and treat it with care.

## Apple Health (HealthKit)

Several of our apps can, if you allow it, read data from or write data to Apple Health: for example Pillio (medications), Contrastly (workouts, heart rate, sleep, resting heart rate and heart rate variability), Vialora, Ossly, Bottomtime (dive depth and duration), Cogbook (ride distance) and Feltbook (sleep). The permission screen shown by iOS lists exactly which data types each app asks for.

Our commitments for data from Apple Health:

- **Only with your explicit permission.** Access is optional, requested through Apple’s permission screen and granted data type by data type. You can refuse or revoke it at any time.
- **Only for the features you use.** Health data is used solely to provide the health and fitness features of the app, on your device, such as displaying your heart rate next to a session or saving a workout you have just timed.
- **Never for advertising or marketing.** It is never used to show you ads, to market products to you or for any form of data mining.
- **Never sold or shared.** It is never sold, rented or disclosed to third parties, including advertisers, data brokers and analytics providers.
- **Never on our servers.** It is not transmitted to us and not stored on our servers.
- **Accurate writing only.** Our apps write to Apple Health only the data you have recorded or confirmed yourself.

To change what an app can access, go to **Settings > Privacy & Security > Health** and select the app. Data an app has written to Apple Health stays in Apple Health, under your control, even after you delete the app (see how to delete your data).

## iCloud sync (CloudKit)

Many of our apps can sync and back up your data across your devices through iCloud. When sync is on, your data is stored in the private database of **your own iCloud account**, using Apple’s CloudKit service:

- it is visible only to you, on the devices signed in to your Apple Account; we, as developers, have no access to it;
- Apple stores and encrypts it under the [Apple Privacy Policy](https://www.apple.com/legal/privacy/) and uses your iCloud storage;
- you can turn sync off in the app (where it offers a switch) or in **Settings > [your name] > iCloud**, by switching the app off in the list of apps using iCloud.

## Device permissions and on-device features

Some features need access to a part of your device. iOS always asks for your permission first, and you can change your choice at any time in **Settings > Privacy & Security** or in the app’s own section of Settings.

- **Camera and photos** — to attach pictures to your entries, scan a barcode or read a wine label. Recognition runs on your device; photos stay in the app and, if sync is on, in your iCloud. With the iOS photo picker, the app only sees the photos you select.
- **Microphone** — used by Ratewell (watch timegrapher) and dB Meter Pro (sound level) to measure sound in real time. Audio is analyzed on your device and never sent to us.
- **Location** — used by ApexLap for lap timing and telemetry, and by Turfwise to fetch soil temperature and the weather forecast for your area. Location data stays on your device; for weather features, the location needed for the forecast is sent to Apple’s weather service (Apple Weather), never to us.
- **Bluetooth** — to connect accessories such as external GPS receivers and OBD-II adapters (ApexLap) or hygrometers (Cedary). The accessory communicates directly with your device.
- **Maps** — maps of your sites are displayed with Apple Maps; Apple receives the map areas your device requests.
- **Notifications** — to deliver the reminders you set up.

## Services you connect yourself

Our two Mac developer tools work with services you choose and configure with your own credentials:

- **Xlocalize** sends the strings you ask it to translate, with your API key, directly from your Mac to the AI provider you select: OpenAI, Anthropic or Google. We never receive your strings or your key, which is stored locally on your Mac. The provider processes your request under its own terms and privacy policy ([OpenAI](https://openai.com/policies/privacy-policy/), [Anthropic](https://www.anthropic.com/legal/privacy), [Google](https://policies.google.com/privacy)) and bills you directly for its usage.
- **Appviary** connects directly from your Mac to Apple’s App Store Connect API with the API key you provide, which is stored in your Mac’s Keychain. Your sales, downloads and reviews never pass through our servers.

## Analytics and crash reports

Our apps contain no third-party analytics, advertising or tracking SDK, and never ask for permission to track you (App Tracking Transparency), because they do not track you.

**Apple App Analytics.** If you have chosen to share analytics with app developers (**Settings > Privacy & Security > Analytics & Improvements > Share With App Developers**), Apple gives us aggregated usage statistics and crash reports for our apps. They do not identify you, and we use them only to fix bugs and improve our apps. You can turn this off at any time in the same place.

**If this ever changes.** Should we add a crash-reporting or analytics service to an app in the future (for example Google Firebase Crashlytics), we will update this policy and the app’s App Privacy label before releasing that version. Such a service would be limited to technical data (device model, system and app version, crash traces, anonymous usage events), would not be linked to your identity and would never be used for advertising or tracking.

## Purchases and subscriptions

Our apps are free to download. Optional in-app purchases and subscriptions are sold and billed by Apple through the App Store, under Apple’s terms.

- We never receive your name, e-mail address, payment card, bank details or billing address.
- To unlock paid features and let you restore purchases, the app checks on your device the transaction information signed by Apple (product, purchase and expiry dates, transaction identifier, store country).
- Apple provides us with sales reports (units, proceeds, country, dates) that do not identify you. We keep them for accounting and tax purposes.
- Refunds and billing questions are handled by Apple (see our [Terms of Use](https://develak.com/terms-of-use/#refunds)).

## Clients and payments

When you hire Develak for a project, as described in our [Terms of Sale](https://develak.com/terms-of-sale/), we process the information needed to prepare the quote, carry out the project and invoice it:

- **Client details.** Your name, company, role, e-mail address, billing address and, where applicable, tax or VAT number.
- **Project records.** Quotes, contracts, our correspondence about the project, and the access you give us to your accounts and tools (such as App Store Connect or a code repository), which we use only for the project.
- **Invoices and payments.** Invoice amounts and dates, payment status, payment method type and, for card payments, the card brand, its last four digits, expiry date and country.

**Stripe.** Invoices are paid through the secure payment pages of Stripe, Inc. (USA) and its affiliates, such as Stripe Payments Europe, Limited (Ireland) for clients in Europe. Your card or bank details are entered directly with Stripe: we never receive your full card number or your card’s security code. Stripe processes payment data on our behalf to collect the payment and, as an independent controller, for its own purposes such as fraud prevention and its legal obligations, as explained in the [Stripe Privacy Policy](https://stripe.com/privacy). No payment is made on develak.com, and the website loads no Stripe script.

We use this information only to run our client relationship: quotes, project follow-up, invoicing, payment collection, refunds and accounting. We never use it for advertising.

## Support, reviews and beta testing

- **Support e-mails from an app.** When you contact us from within an app, the pre-filled e-mail may include the app version, device model and iOS version to help us diagnose the problem. You can review or remove this information before sending.
- **App Store reviews.** Ratings and reviews are published by Apple. We can read them and reply publicly through Apple’s tools, without learning who you are.
- **Beta testing.** If you join a beta through Apple’s TestFlight, Apple shares with us the information needed to run the test (your name and e-mail address if we invited you by e-mail, your device and system version) and the feedback, screenshots and crash reports you choose to send. We use them only to improve the beta.

## Who we share data with

**We do not sell, rent or trade your personal data, and we do not share it for targeted advertising.** We disclose it only in the following cases:

- **Technical providers** that help us run the website, acting on our instructions: OVHcloud (hosting of the website, its database and our e-mail), Cloudflare (DNS and network protection) and Defiant (Wordfence security). They may only use the data to provide their service to us.
- **Apple**, which distributes our apps and operates the App Store, iCloud, Apple Health, TestFlight and App Analytics, as described above, under its own privacy policy.
- **Stripe**, which processes the payment of our clients’ invoices, as described in Clients and payments.
- **Authorities**, when the law requires it, to respond to a valid legal request, or to protect the rights, safety and security of our users, the public or Develak.
- **A successor**, if PRIOMAT LLC or some of our apps were sold or merged. The data we hold would remain protected by this policy, and we would inform you beforehand.

## Legal bases for processing

If you are in the European Economic Area, the United Kingdom or Switzerland, we rely on the following legal bases under Article 6 (and, for health data, Article 9) of the General Data Protection Regulation (GDPR) and the equivalent UK and Swiss laws:

| Purpose | Legal basis |
| --- | --- |
| Running and securing the website (server and security logs) | Our legitimate interest in keeping the site available and safe — Art. 6(1)(f) |
| Answering your messages and support requests | Steps taken at your request before a contract, or performance of a contract — Art. 6(1)(b); our legitimate interest in answering general questions — Art. 6(1)(f) |
| Preparing quotes, carrying out client projects, invoicing, collecting payments and issuing refunds | Performance of a contract, or steps taken at your request before one — Art. 6(1)(b) |
| Preventing spam and abuse of the contact form | Our legitimate interest in protecting our services — Art. 6(1)(f) |
| Providing the app features you use, including purchases and restores | Performance of the license agreement for the app — Art. 6(1)(b) |
| Reading or writing Apple Health data | Your explicit consent, which you can withdraw at any time — Art. 6(1)(a) and 9(2)(a) |
| iCloud sync and Apple App Analytics | Your choice in the app and in your Apple settings, which you can change at any time — Art. 6(1)(a) |
| Keeping accounting and tax records; answering authorities | Compliance with a legal obligation — Art. 6(1)(c) |
| Establishing, exercising or defending legal claims | Our legitimate interest — Art. 6(1)(f) |

Where we rely on legitimate interests, we have checked that they are not overridden by your rights, and you can object at any time (see your rights). We make no decisions about you based solely on automated processing.

## How long we keep data

| Data | Retention |
| --- | --- |
| Contact form messages and e-mails (with the hashed IP address and user agent) | 24 months after our last exchange, then deleted. Longer only if they relate to a contract we have signed with you, for the duration of the contract and the applicable limitation periods, or if needed to establish or defend a legal claim. |
| Hashed IP address used to limit the number of messages | 1 hour |
| Server and security logs | A short period, as a rule no longer than 90 days, unless needed to investigate a specific security incident |
| Theme preference in your browser | Until you clear your browser’s site data |
| Data in our apps, on your device | Until you delete it or delete the app |
| Data synced to your iCloud | Until you delete it from iCloud; managed by Apple |
| Apple Health data | Kept in Apple Health, under your control |
| Client details and project records | For the duration of the project or plan, then for the applicable limitation periods |
| Invoices and payment records | As long as tax and accounting laws require |
| Sales reports provided by Apple | As long as tax and accounting laws require |

## International data transfers

PRIOMAT LLC is a company based in the United States, while our website, its database and our mailbox are hosted by OVHcloud in the European Union. Personal data may therefore be accessed from the United States or processed there by some of our providers (such as Apple, Stripe, Cloudflare and Defiant).

When personal data leaves the European Economic Area, the United Kingdom or Switzerland for a country without an adequacy decision, we rely on appropriate safeguards: the [EU-U.S. Data Privacy Framework](https://www.dataprivacyframework.gov/) (and its UK and Swiss extensions) when the recipient is certified, or the Standard Contractual Clauses adopted by the European Commission (with the UK Addendum), together with data minimization — for example, we store a hash rather than your IP address with your messages. You can ask us for more information about these safeguards.

## How we protect data

- The website is served exclusively over encrypted HTTPS connections.
- Access to the server and to your messages is restricted to the people who need it, and our software is kept up to date and protected by a firewall.
- We collect as little as possible: no accounts, no app data on our side, hashed IP addresses.
- In the apps, your data benefits from iOS and macOS sandboxing and data protection, the API keys you enter in our Mac tools stay on your Mac, some apps can be locked with Face ID, and iCloud data is encrypted by Apple.

No method of transmission or storage is completely secure. If a data breach were likely to put your rights at risk, we would notify the competent authorities and, where required, inform you without undue delay.

## Your privacy rights

We honor the requests below from anyone, wherever you live, whether or not a law requires us to.

### Europe, the United Kingdom and Switzerland

Under the GDPR, the UK GDPR and the Swiss data protection act, you have the right to:

- access your personal data and receive a copy of it;
- have inaccurate data corrected;
- have your data erased;
- restrict how we process it;
- receive the data you provided in a portable format;
- object to processing based on our legitimate interests;
- withdraw your consent at any time, without affecting processing carried out before;
- if you live in France, give instructions on what should happen to your data after your death;
- lodge a complaint with a supervisory authority, such as the CNIL in France ([cnil.fr](https://www.cnil.fr/)), the ICO in the United Kingdom ([ico.org.uk](https://ico.org.uk/)) or the authority of the country where you live or work.

### United States (California and other states)

Under the California Consumer Privacy Act as amended by the CPRA, and similar laws in other states (such as Colorado, Connecticut, Oregon, Texas, Utah and Virginia), you have the right to:

- know what personal information we collect, use and disclose, and access it;
- delete it and correct it;
- receive it in a portable format;
- opt out of the sale or sharing of your personal information, targeted advertising and profiling — we do none of these;
- limit the use of sensitive personal information — health data from our apps never reaches us, and any sensitive information you choose to send us is used only to answer you;
- not be discriminated against for exercising these rights;
- appeal our decision if we decline your request, by replying to our answer; if we maintain it, you may contact your state Attorney General.

In the past 12 months, the only categories of personal information we collected were identifiers (such as your name, e-mail address and a hashed IP address), internet activity (server and security logs), the content of the messages you sent us and, for our clients, commercial information (quotes, invoices and payment records), for the purposes described in this policy. We have not sold or shared personal information, including that of consumers under 16. You may use an authorized agent to make a request on your behalf.

## How to delete your data

Because your app data is stored on your devices and in your iCloud, you can delete it yourself, at any time, without asking us:

1. **Inside the app.** Where available, use the option to delete all data in the app’s settings. It erases the data on your device and, if sync is on, in your iCloud.
2. **Delete the app.** Touch and hold the app icon, tap **Remove App**, then **Delete App**. This removes the data stored on that device.
3. **Delete the iCloud copy.** Go to **Settings > [your name] > iCloud > Manage Account Storage**, select the app, then delete its data. On a Mac: **System Settings > [your name] > iCloud > Manage**.
4. **Delete Apple Health data.** Go to **Settings > Health > Data Access & Devices**, select the app, then **Delete All Data**. You can also delete individual entries in the Health app.
5. **Delete your messages to us.** E-mail [contact@develak.com](mailto:contact@develak.com) and we will erase your messages and contact details.

For data held by Apple (your Apple Account, purchase history, App Store reviews), use Apple’s [Data and Privacy](https://privacy.apple.com/) page.

## How to exercise your rights

- Write to [contact@develak.com](mailto:contact@develak.com) with the subject “Privacy request”, tell us which right you want to exercise and, if possible, the e-mail address you used to contact us.
- We may ask for information to confirm your identity, limited to what is necessary, so that we never hand your data to someone else.
- We respond within 30 days. If a request is complex, we may extend this period as the law allows, and we will tell you why.
- Exercising your rights is free, unless a request is manifestly unfounded or excessive.

We do not hold the data stored in your apps and your iCloud, so we cannot access or erase it for you, but we will gladly explain how to do it.

## Children

Our website and apps are not directed to children under 13, or under 16 in the European Economic Area unless local law sets a lower age. We do not knowingly collect personal data from children. An app’s age rating on the App Store describes whether its content is suitable, not the audience it is intended for.

Parents and carers may use some of our apps to keep records about a child in their care; those records stay on their own device and iCloud. If you believe a child has sent us personal data, contact us and we will delete it.

## Links to other websites

Our website and apps contain links to other services, such as the App Store. We are not responsible for their privacy practices; please read their own policies.

## Changes to this policy

We may update this policy, for example when we add a feature or when the law changes. The date at the top of this page shows the latest version. If a change significantly affects how we handle your data, we will announce it clearly on this website and, where appropriate, in the apps or their release notes. Previous versions are available on request.

## Contact us

For any question about this policy or your personal data:

- E-mail: [contact@develak.com](mailto:contact@develak.com)
- Contact form: [develak.com/#contact](https://develak.com/#contact)
- Mail: PRIOMAT LLC (Develak), 2105 Vista Oeste St NW, Suite E-1324, Albuquerque, NM 87120, USA

See also our [Terms of Use](https://develak.com/terms-of-use/) and our [Legal Notice](https://develak.com/legal-notice/).

Each of our apps also has its own privacy page, linked from its page in the app catalogue. [Browse the apps](https://develak.com/apps/)

## Questions about this page?

Write to us: we read every message and reply personally.

[contact@develak.com](mailto:contact@develak.com)

---

*Markdown version of <https://develak.com/privacy-policy/> for AI assistants, published by Develak. Links lead to the web pages; add .md to a page URL for its Markdown version. Site index: <https://develak.com/llms.txt>.*