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Privacy Policy — GiftBell

Last updated: September 2026

1. Scope

This Privacy Policy describes how ByteGlo OÜ (“ByteGlo”, “we”, “us”, or “our”) handles information in connection with the iOS application GiftBell (the “App”), available on the Apple App Store.

This Policy applies only to GiftBell. It does not replace Apple’s policies, the App Store Licensed Application End User License Agreement (or any custom EULA that applies to the App), or the privacy policy for our website at byteglo.com.

By using the App, you acknowledge this Policy. If you do not agree, do not use the App.

2. Who we are (data controller)

  • Company: ByteGlo OÜ
  • Registry code: 17584494
  • Country: Estonia
  • Email:

For personal data we process as a controller (for example support emails you send us), ByteGlo OÜ is the controller under the EU General Data Protection Regulation (GDPR).

Birthday contacts and related App content that remain only on your device are processed on your device under your control. We do not operate a cloud account system that stores those contacts for us.

3. At a glance

  • GiftBell is designed as an offline-first birthday reminder App.
  • Your birthday contacts, photos, wishes, reminder schedules, and preferences are stored on your device (and, where needed, in an App Group shared with the GiftBell widget on the same device).
  • We do not create user accounts in the App.
  • We do not sync your birthday contacts to ByteGlo servers.
  • We do not sell personal information.
  • The App does not include third-party analytics, advertising, or tracking SDKs.
  • Optional wish / gift-idea features run on device after you download a model; contact details used for those features are not uploaded to ByteGlo for generation.
  • Payments are handled by Apple through StoreKit / In-App Purchase.

4. Information we do not collect

Through the App, ByteGlo does not collect or maintain on our systems:

  • an App user account profile or login;
  • a copy of your birthday contact database;
  • payment card numbers;
  • precise location for tracking;
  • advertising identifiers for ads;
  • analytics event streams from third-party analytics SDKs.

If this ever changes, we will update this Policy and, where required, App Store privacy disclosures before applying the change.

5. Information processed on your device

Depending on how you use the App, the following categories may be processed locally on your iPhone or iPad:

  • Birthday contact data you enter or import — for example name, birthday, relation, gender, language, interests, saved wish text, and custom reminder settings.
  • Photos — a photo you attach from your photo library, and/or a thumbnail that may be saved when you import from iOS Contacts.
  • iOS Contacts data (with permission) — birthday-related fields you choose to import. Import stays on this device for use in GiftBell.
  • Local notification data — schedules and notification content created through Apple’s local notification APIs. The App does not use remote push from ByteGlo servers.
  • Widget data — limited upcoming-birthday summaries shared with the GiftBell widget extension via an App Group on the same device.
  • App preferences — for example theme, language, notification preferences, and a local purchase-unlock cache.
  • Optional AI model files — if you download a language model, it is stored on your device. Prompts that include contact details for wishes or gift ideas are processed locally.
  • Backup files you create — JSON export/import via the system share sheet. Exports do not include contact photos. Any further sharing is under your control.
  • Purchase entitlement status — Apple StoreKit records whether Premium is unlocked on your Apple ID / device so the App can unlock Premium features.

6. How information is used (purposes)

On-device data is used only to provide and improve the App’s features for you, including to:

  • store and display birthday contacts and photos;
  • schedule and show local birthday reminders;
  • power widgets;
  • generate optional on-device wishes or gift ideas when you use those features;
  • import/export backups you request;
  • apply Premium entitlements purchased through Apple;
  • remember your settings.

If you contact us by email, we use your email address and message content only to respond and handle that inquiry.

If Apple provides optional crash or diagnostic reports that you have chosen to share with developers, we use them only to diagnose and improve reliability.

7. Legal bases (EEA / UK users)

Where the GDPR (or UK GDPR) applies to processing for which ByteGlo is controller, we rely on one or more of the following:

  • Contract / steps prior to contract — to provide the App features you request and to handle Premium entitlements in connection with your purchase.
  • Consent — where iOS requires permission (for example Contacts, Photos, or local notifications), or where you choose optional features such as downloading a model or exporting a backup.
  • Legitimate interests — for example responding to support emails and improving reliability using optional Apple diagnostics, balanced against your rights.
  • Legal obligation — where we must retain or disclose information to comply with law.

You can withdraw device permissions in iOS Settings at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

8. Permissions

  • Contacts — to import birthday-related contact details you select onto this device.
  • Photo Library — so you can add a contact photo.
  • Local Notifications — to schedule birthday reminders on your device.

The App does not require camera, microphone, precise location, or App Tracking Transparency tracking for advertising.

You may deny or later revoke permissions in iOS Settings. Some features will not work without the related permission.

9. Third parties and network use

ByteGlo does not sell, rent, or trade your personal information.

Limited network activity may occur with independent third parties when you use certain features:

  • Apple — App Store distribution, StoreKit product loading, purchase, restore, and related App Store / Apple ID processing. Apple acts under its own terms and privacy policy. We do not receive your payment card details.
  • Model host (currently Hugging Face) — only if you choose to download an optional on-device AI model. That request downloads a model file. Birthday contact content is not uploaded by GiftBell to that host for wish generation.
  • System share sheet / browser — if you export a backup, share wish text, or open a web link, the destination is chosen by you and governed by that destination’s practices.

Those third parties are independent controllers or providers for their own services. Review their policies before use. Model hosting or CDN infrastructure may be located outside your country (including outside the EEA). For optional model download, any related technical connection is initiated by you; GiftBell does not upload your contact database as part of that download.

We may disclose information if required by law, legal process, or to protect rights, safety, and security where permitted.

10. Analytics, advertising, and tracking

The App does not include third-party advertising networks, marketing pixels, or external analytics / tracking SDKs.

We do not use the App to track you across other companies’ apps and websites for advertising.

11. Purchases

Premium features may be offered as a one-time In-App Purchase through Apple StoreKit. Apple processes payment. For billing, invoices, refunds, and Family Sharing questions, contact Apple Support. Apple’s privacy policy applies to payment data Apple processes.

12. Retention

  • On-device App data remains on your device until you delete it or uninstall the App (subject to how iOS handles leftover files, App Groups, and notification schedules).
  • Support emails are kept only as long as needed to handle the inquiry, or longer if the law requires.
  • Optional Apple diagnostics are retained only as needed to investigate reliability issues.

13. Security

We take reasonable technical and organizational measures appropriate to an on-device App that does not upload your birthday contact database to ByteGlo servers. No method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

You are responsible for controlling physical access to your device, your Apple ID security, iOS permission settings, and anything you choose to share through system share sheets or exports.

14. Children’s privacy

The App is not directed at children under 13, and we do not knowingly collect personal information from children under 13 on our systems. If you believe a child has provided personal information to us (for example by email), contact us and we will take appropriate steps to delete it where required.

Parents and guardians are responsible for supervising use of birthday contact data entered into the App on a device.

15. Your privacy rights

EEA / UK (and similar laws). Subject to legal limits, you may have rights to access, rectify, erase, restrict, or object to certain processing, and to data portability, and to lodge a complaint with a supervisory authority (in Estonia, the Data Protection Inspectorate — Andmekaitse Inspektsioon). Where processing is based on consent, you may withdraw consent.

Because most GiftBell data stays on your device, you can usually exercise control directly by editing or deleting contacts, revoking iOS permissions, deleting a downloaded model, clearing exports you created, or uninstalling the App.

For personal data we hold from email you sent us, contact us using the control below. We may need to verify your request.

California / “sale” of personal information. We do not sell personal information as that concept is commonly understood under the CCPA/CPRA, and we do not share App contact data for cross-context behavioral advertising.

Contact for privacy requests: .

16. International users

The App may be used from outside Estonia. ByteGlo is established in Estonia (EU). Where you contact us, your message may be processed in the EU. Optional third-party services you choose (for example Apple or a model host) may process technical data in other countries under their own terms.

17. Links and other services

The App or this page may link to third-party sites or services we do not control. Their privacy practices are their own. This Policy does not cover those services.

18. Changes

We may update this Policy from time to time. The “Last updated” date at the top will change when we do. Material changes will be posted on this page. Continued use of the App after an update means you acknowledge the revised Policy, except where applicable law requires additional consent.

If our data practices change in a way that requires updated App Store privacy labels, we will update those disclosures as required by Apple.

19. Contact

ByteGlo OÜ · Registry code 17584494 · Estonia

Email:

Governing law for this Policy, to the extent permitted and without prejudice to mandatory consumer protections that cannot be waived, is the law of Estonia.