Privacy Policy
Last updated: 10 May 2026 · Version 1.0
This Privacy Policy describes how UDT s.r.o. ("we", "us", "our") collects, uses, and protects your information when you use the Vellumo mobile application (the "App"). Vellumo is designed with a privacy-first approach: your documents stay on your device and in your personal Apple iCloud account.
1. Data Controller
The data controller is UDT s.r.o., a company registered in the Czech Republic (D-U-N-S 88057446). Contact: support@udt.cz.
2. What Data We Collect
We do not operate any server that stores, transmits, or has access to your documents. On infrastructure we control, we do not collect, transmit, store, or process any of the following:
- Documents, scans, photographs, or PDFs you create or import
- OCR text extracted from your documents
- Personal identifiers, advertising IDs, or device fingerprints
- Crash reports or diagnostic logs beyond Apple's standard, anonymized Xcode Organizer reporting
Anonymous usage analytics. We use Aptabase, a privacy-first analytics service hosted in the European Union (eu.aptabase.com), to understand anonymous, aggregate feature usage — for example, how many scans were performed or which features are used — so we can improve the App. Aptabase events:
- Never include your documents, scans, OCR text, or any content you create
- Do not use device identifiers, cookies, advertising IDs, or persistent tracking
- Cannot be linked back to you as an individual — Aptabase's methodology is described at aptabase.com/legal/privacy
3. Where Your Data Lives
On your device: All documents you create or import are stored locally on your device in the App's private container. OCR processing is performed entirely on-device using Apple's Vision framework — no images or text leave your device for OCR.
In your iCloud account (optional): If you enable iCloud sync in iOS Settings, your documents are synchronized to your personal Apple iCloud account via Apple CloudKit. This data is encrypted in transit and at rest by Apple. We have no access to it. Apple acts as a sub-processor under its own privacy policy and Data Processing Agreement (apple.com/legal/privacy).
4. In-App Purchases
Vellumo offers in-app purchases (Yearly Pro subscription and Lifetime Pro one-time purchase) processed by Apple Inc. via the App Store and StoreKit. We do not receive, store, or have access to your payment information, credit card numbers, or Apple ID. Apple provides us only with anonymized purchase receipts to validate entitlements. Apple's privacy policy applies to all payment processing.
5. Legal Basis (GDPR)
For users in the European Economic Area, the United Kingdom, and Switzerland, our legal basis under the GDPR for the limited processing described above is:
- Contract performance (Art. 6(1)(b) GDPR) — for processing your in-app purchase to deliver the Pro entitlement.
- Legitimate interest (Art. 6(1)(f) GDPR) — for ensuring the App functions correctly on your device, and for understanding anonymous, aggregate feature usage through Aptabase to improve the App.
We do not rely on consent for analytics because Aptabase processes only anonymous, aggregated data that cannot be linked back to your identity — see Section 2.
6. Your Rights
Under GDPR and similar laws (including the California Consumer Privacy Act), you have the right to access, rectify, erase, restrict, port, and object to the processing of your personal data. Because we do not hold any personal data on our servers, most of these rights are exercised directly through your device:
- Erase your data: Delete the App or remove documents within the App.
- Erase iCloud data: iOS Settings → Apple ID → iCloud → Manage Storage → Vellumo → Delete Data.
- Manage subscriptions: iOS Settings → Apple ID → Subscriptions.
- Contact us: For any other request, write to support@udt.cz. You also have the right to lodge a complaint with your local supervisory authority (in the Czech Republic: Úřad pro ochranu osobních údajů, uoou.cz).
7. Children
Vellumo is not directed to children under 13. We do not knowingly collect personal data from children. As we collect no personal data on our servers at all, this restriction is satisfied by design.
8. International Transfers
We do not operate servers that collect your documents, so no international transfer of your content occurs on our part. Anonymous analytics data (via Aptabase) is processed within the European Union. If you use iCloud sync, Apple may store your encrypted data in data centers located outside your country, subject to Apple's privacy policy and Standard Contractual Clauses.
9. Changes to this Policy
We may update this Privacy Policy. The current version will always be available at apps.udt.cz/Vellumo. Material changes will be announced in App Store release notes.
10. Contact
Questions about this Privacy Policy: support@udt.cz.