Privacy Policy

for the app Refill Track (internal name “Rezeptalarm”)

1. Data Controller

The data controller within the meaning of the EU General Data Protection Regulation (GDPR) is:

2. Core principle: on-device processing only

Refill Track is an app that lets you track your medication inventory and reminders locally on your Apple device. We do not collect, store or transmit any personal data to our own servers. All information you enter in the app — including medication names, quantities, schedules, notes and images — stays exclusively on your device.

3. Data processed in detail

a) Medication and reminder data

The data you enter in Refill Track is stored locally on your device in an App Group container provided by Apple (group.org.wenzler.Rezeptalarm), backed by SwiftData/Core Data. This data never leaves your device.

Legal basis: Art. 6(1)(b) GDPR (performance of the user agreement).

Retention: Until you delete the data in the app or uninstall the app.

b) Local notifications

If you enable notifications, the app schedules reminders locally via Apple’s UNUserNotificationCenter. No push servers are involved; nothing is transmitted to third parties.

Legal basis: Art. 6(1)(a) GDPR (your explicit consent via the iOS system prompt). You can withdraw consent at any time in the iOS settings.

c) In-app purchases and subscriptions

Purchases and subscriptions are handled entirely by Apple’s StoreKit. We do not receive any payment information, Apple ID, name or billing address. Refill Track only checks the entitlement status (“active” / “inactive”) using the local StoreKit transaction cache on your device.

Apple acts as the controller for data processing in connection with your purchase. Apple’s privacy policy applies: https://www.apple.com/legal/privacy/.

Legal basis: Art. 6(1)(b) GDPR (contract performance).

d) Language preference

Your selected app language is stored locally on your device (UserDefaults). It is not transmitted to us or any third party.

e) iCloud Backup (optional, by Apple)

If you have enabled iCloud Backup for Refill Track in your iOS settings, Apple may include the app’s data in your personal iCloud backup. The app itself does not use CloudKit or iCloud sync. Apple is responsible for the backup under its own privacy policy.

4. No data sharing, no tracking

Refill Track uses no analytics tools, no tracking, no advertising identifiers, no third-party SDKs and no crash reporting. We do not transfer data to third countries.

5. Your rights

Because we do not collect any personal data from you, we generally cannot provide information about data stored by us. To the extent the GDPR applies, you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent (Art. 7(3) GDPR)

Deleting your data: You can delete your data at any time by removing individual entries within the app or by uninstalling the app.

6. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority for us is:

7. Changes to this policy

We may update this privacy policy to keep it in line with current legal requirements or to reflect changes to our service. The updated policy will apply from your next visit.

Last updated: June 2026