At a Glance
- You can store documents locally without requesting an AI analysis. OCR runs on your device.
- Local analysis uses Apple's on-device model on supported devices. It does not send document text to our server or an external AI provider.
- Pro analysis sends extracted text to our server and the selected AI provider, not the original image or PDF file.
- Completed Pro results are available from our server for a maximum of 24 hours after completion. Your saved local copy remains in your archive.
- Optional Cloud Sync synchronises archive content through your private iCloud database.
- No advertising tracking. We do not sell personal data.
1. Controller
ExplainThisDoc
Julian Heger
Cumberlandstr. 40
1140 Vienna
Austria
Contact: [email protected]
2. Local Documents, OCR, and Local Analysis
The archive stores imported or scanned originals and, where available, extracted text, analysis results, notes, annotations, and document edits on your device. You can keep a document in the archive without AI analysis. OCR and text extraction take place locally. Access to the camera, selected photos, or selected files is used for the import you request and is subject to iOS permissions.
Local analysis uses Apple's Foundation Models on the device. It requires a supported device and operating system, enabled Apple Intelligence, an available model, and a supported language. The app does not silently replace an unavailable local analysis with a Pro request. Separate functions, such as iCloud sync, account services, and map previews, can use the network as described below.
Legal basis for providing the requested app functions: Article 6(1)(b) GDPR.
3. Data Used by Online Functions
3.1 Pro Analysis
When you request Pro analysis, extracted document text and necessary request information, such as the selected analysis provider and output language, are sent to our backend. The selected external AI provider processes this text to produce an explanation. Supported providers include OpenAI, Mistral AI, and Qwen / Alibaba Cloud Model Studio; the app shows the available choices. Original image files, PDF files, and camera images are not sent to our backend or AI providers for this analysis.
The text may be stored temporarily while the request is queued or processed, including when the app is in the background. It is cleared from the processing job when the request succeeds or finally fails. Completed results are temporarily retained for retrieval, as explained in section 6. Results can contain quotations and other personal information from the source document.
Document text is not automatically anonymous. It may contain names, addresses, financial details, health information, or information about other people. Special categories of personal data, such as health data, require an applicable condition under Article 9 GDPR in addition to an Article 6 legal basis; requesting a service does not by itself satisfy that requirement. Consider whether the content needs to be sent for Pro analysis. Keeping the document locally or using available local analysis avoids this transfer of its text.
Legal basis for the requested Pro service: Article 6(1)(b) GDPR, subject to any additional requirements applicable to the content.
3.2 Account, Credits, and Optional Apple Link
We process app-generated device and account identifiers, authentication credentials, credit balances, and transaction references to identify your account, deliver Pro requests, manage credits, and prevent misuse. These identifiers are pseudonymous, not anonymous.
If you choose to link the account with Apple for account and credit recovery, Apple verifies the sign-in and we retain a derived identifier linking that Apple sign-in to your app account. This flow does not request your name or email address. The Apple account link is separate from iCloud archive synchronisation and does not itself upload your documents.
Legal basis: Article 6(1)(b) GDPR.
3.3 Technical and Security Data
We process connection information, including IP addresses, request times, request and account references, language settings, error codes, usage counts, and credit or purchase records to operate the service, limit abuse, investigate failures, and account for usage. Some diagnostic identifiers are hashed or redacted; this does not make all technical records anonymous. Technical logs are separate from the temporary Pro result store.
Legal basis: Article 6(1)(b) GDPR and Article 6(1)(f) GDPR for service integrity, troubleshooting, and abuse prevention.
3.4 In-App Purchases
Apple handles App Store payments. We do not receive payment card information. We receive purchase and verification information, such as transaction and product identifiers, needed to assign credits, verify purchases, and handle refunds or revocations. Apple processes payment data under its own privacy terms.
Legal basis: Article 6(1)(b) GDPR, Article 6(1)(c) GDPR where retention is legally required, and Article 6(1)(f) GDPR for fraud prevention.
3.5 Support Communications
When you contact us, we process your contact details and message to answer your request. Send only the information needed for support. Do not send passwords, authentication tokens, or unnecessary document contents.
Legal basis: Article 6(1)(b) GDPR and/or Article 6(1)(f) GDPR; Article 6(1)(c) GDPR when handling a statutory request.
3.6 Optional Cloud Sync
If you activate Cloud Sync, Apple CloudKit synchronises archive data through your private iCloud database across your own devices using the same Apple account. Depending on the saved entry, this includes originals, extracted text, analysis results, notes, annotations and edits, metadata, and deletion changes. This separate transfer can include document files even though Pro analysis sends only text.
Pausing Cloud Sync stops synchronisation without deleting the existing iCloud data. Disabling Cloud Sync starts deletion of the synchronised iCloud data in the background and keeps your local archive, app account, and credits. Deletion and synchronisation need a working connection and can take time. A private iCloud database is not, by itself, a promise of end-to-end encryption for all its data.
Apple operates iCloud and CloudKit under its own terms. See the Apple Privacy Policy and iCloud data security overview.
Legal basis for providing the optional sync function you activate: Article 6(1)(b) GDPR.
3.7 Maps, Calendar, and Sharing
Displaying a map preview can send a document's place or address information and technical request data to Apple's map services for search, geocoding, and map loading. Where server-side address verification is enabled for Pro analysis, relevant place or address queries can also be sent to Google Places or Geocoding. These services do not need the complete original document for that lookup.
When you open navigation, the chosen map app receives the destination. Calendar actions prepare details such as a title, date, location, and notes in the system event editor; you decide whether to save the event and to which calendar. Sharing or exporting sends the selected content to the app, location, or recipient you choose. Those services may apply their own sync and retention rules.
Legal basis: Article 6(1)(b) GDPR for the requested functions. See the Apple Maps privacy information and Google Privacy Policy.
3.8 Website Access
Our public website uses Cloudflare Pages. Cloudflare may process connection and log data, such as IP addresses, browser information, and request metadata, to deliver and protect it. We do not set our own analytics, marketing, or tracking cookies. Hosting and security services may use technically necessary cookies or comparable security mechanisms.
Legal basis: Article 6(1)(f) GDPR for secure website delivery.
4. Infrastructure and Recipients
Our application backend is hosted in Germany, within the European Union. This does not determine where external AI providers, Apple, Google, or Cloudflare process data. We use hosting and service providers to deliver the functions described above, with processor agreements where applicable. Apple's App Store, iCloud, map services, and other services you select may also process data under their own terms and responsibilities.
5. AI Providers and International Transfers
Pro text and results may be processed outside the European Economic Area, depending on the selected provider, service region, and its infrastructure. This can include the United States and, for Alibaba Cloud services, Singapore, China, or other supported regions. A provider's European headquarters or an EU label does not guarantee that all processing, support, or subprocessors stay within the EEA. Other services described in this policy can also involve transfers.
Where required, international transfers must use an applicable GDPR transfer mechanism, such as an adequacy decision or Standard Contractual Clauses and supplementary safeguards. You can contact us for information about the safeguards applicable to your request. Provider-side retention, abuse monitoring, caching, and use of data are governed by the relevant service arrangements; our 24-hour result limit does not set their retention periods.
- OpenAI: API data controls and retention, Privacy Policy, and Data Processing Addendum.
- Mistral AI: Privacy Policy and Data Processing Addendum.
- Qwen / Alibaba Cloud Model Studio: Privacy Notice and data retention information.
- Cloudflare: Privacy Policy.
6. Storage, Retention, and Deletion
- Local archive: saved originals, text, results, and notes remain on your device until you delete them or remove the app data. Device backups and copies you export are subject to their own storage settings. Deleting an archive entry does not remove copies already shared or saved elsewhere.
- Pro input text: temporarily retained while the request is queued or processed, then cleared from the job after success or final failure.
- Pro results: available for retrieval from our server for a maximum of 24 hours after completion. After that deadline, retrieval is blocked and automatic deletion removes the result and intermediate analysis content. Cleanup resumes after service interruptions. A result already saved in your local archive is unaffected.
- Account and operational records: account links, balances, purchase records, status and timing information, and accounting or deletion receipts are separate from document content. They can remain as necessary for the account, legal obligations, security, or handling disputes; they do not all expire after 24 hours.
- iCloud: synchronised content remains until deleted through the archive, Cloud Sync controls, or Apple's available controls. Pausing alone does not delete it. Disabling Cloud Sync starts removal of the synchronised cloud data while preserving local data.
- Support and providers: support messages are retained as needed to resolve the request and meet applicable obligations. External providers apply the service-specific retention arrangements described in their linked information.
For a request concerning server-side personal data or your account, contact us. Removing a local document or uninstalling the app does not by itself erase account, purchase, or technical records held separately.
7. AI Output and Decisions
ExplainThisDoc provides explanations and proposed actions. It does not make decisions producing legal or similarly significant effects about you within the meaning of Article 22 GDPR. You decide what to do with the output. Check important details against the original; AI output can be inaccurate and is not professional legal, financial, or medical advice.
8. Data Security
We use technical and organisational measures, including encrypted transmission and access controls, to protect data. Protect access to your device and any exported files. An app lock limits access to the app interface; it does not remove data already shared with other apps or services.
9. Your Rights
Subject to the GDPR's conditions, you can request access, correction, erasure, restriction, and portability of your personal data, and object to processing based on legitimate interests. Where processing relies on consent, you can withdraw it without affecting the lawfulness of earlier processing. Contact us using the details above. We may ask for information reasonably needed to locate your account and verify the request; do not send passwords or authentication tokens.
10. Choices and Required Data
You can keep documents locally without requesting Pro analysis or enabling Cloud Sync. Local analysis is available when the device requirements are met. Pro needs the submitted text and account information to provide the requested result; Cloud Sync needs the archive data selected by that function. If you do not enable or use those functions, these transfers do not occur. Separate account, purchase, map, and website requests can still involve the data described above.
11. Legitimate Interests
Where Article 6(1)(f) GDPR applies, our interests are secure service delivery, fraud and abuse prevention, troubleshooting, and protecting the integrity of account and credit records. These interests must be balanced against your rights and freedoms.
12. Supervisory Authority
You can complain to a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or the alleged infringement. The controller is based in Austria; information is available from the Austrian Data Protection Authority.
13. Children
The app is not directed to children under 16. We do not knowingly collect data from children without the authorisation required by applicable law.
14. Changes
We update this policy when the app's data processing or applicable requirements change. The current version and its update date are available on this page and through the app's privacy link.