This Privacy Policy applies to all mobile applications (apps) developed and published by DCS Digital Code Solutions UG (haftungsbeschränkt), operating as Code Expert, on the Apple App Store and/or Google Play Store.
1. Data Controller
The data controller responsible for data processing under the General Data Protection Regulation (GDPR) is:
DCS Digital Code Solutions UG (haftungsbeschränkt)
Carl-von-Linde-Str. 27
65197 Wiesbaden
Germany
Email: [email protected]
2. Data Processing Principles
We adhere to the following principles under Art. 5 GDPR:
- Data Minimization (Art. 5 (1)(c) GDPR): We only collect data that is strictly necessary for the app functionality.
- Purpose Limitation (Art. 5 (1)(b) GDPR): Data is only used for the explicitly stated purpose.
- Transparency (Art. 5 (1)(a) GDPR): You are fully informed about any data collection before it occurs.
- Storage Limitation (Art. 5 (1)(e) GDPR): Data is kept no longer than necessary.
- Security (Art. 5 (1)(f) GDPR): We implement appropriate technical and organizational measures to protect your data.
- No Selling or Sharing: Your data is never sold or shared with third parties for advertising purposes.
3. Data Collection in Our Apps
3.1 Locally Stored Data
Most of our apps store data exclusively on your device. This data does not leave your device and is not transmitted to us or third parties. Examples include:
- Settings and preferences
- Game progress and scores
- User-created content
- Health and fitness data (only in relevant apps, stored locally only)
3.2 Apple HealthKit / Android Health Connect
Some of our apps may access health data (Apple HealthKit on iOS, Health Connect on Android) if you explicitly grant permission. This data is:
- Processed only locally on your device
- Never transmitted to our servers
- Never used for advertising purposes
- Never shared with third parties
You can revoke access at any time in your device settings: on iOS under Settings → Privacy & Security → Health, on Android in the Health Connect settings under App permissions.
Steppy (Android): reads steps, heart rate, blood oxygen, active calories, distance and floors climbed from Health Connect. If you allow it, Steppy also reads in the background and your earlier history, so its home screen widgets stay current. Steppy never writes to Health Connect.
3.3 Network Access
Some apps require internet access for specific features only:
- API Requests: To retrieve current data (e.g., prices, exchange rates) – no personal data is transmitted
- Cloud Sync: Only when you explicitly enable this feature (e.g., iCloud) – governed by Apple's privacy policy
- In-App Purchases: Processed entirely through Apple/Google payment systems – we do not receive payment data
3.4 Wear OS Companion Apps
Where an app has a Wear OS watch app (e.g. Steppy), the watch reads its own activity data through the watch's Health Services. Between your phone and your watch, only settings are synchronized (daily goals, unit system, streak count, number of unlocked badges), via the Google Play services Data Layer between your own devices. No health values are transferred, and we have no access to this data.
3.5 Data We Do NOT Collect
Our apps generally do not collect any of the following data:
- Name, email address, or any contact information
- Location data (GPS coordinates)
- Device identifiers used for cross-app tracking (for the advertising SDK in certain Android apps, see Section 4.3)
- Photos or media (except when required for core app functionality, stored locally only)
- Contacts, calendar, or messages
- Biometric data
4. Tracking and Advertising
4.1 No Tracking (Apple ATT)
Our apps do not use tracking as defined by Apple's App Tracking Transparency (ATT) framework. Specifically, we do not:
- Link user data with third-party data for advertising
- Share data with data brokers
- Create cross-device or cross-app profiles
- Use the Apple advertising identifier (IDFA) for tracking
On Android, certain free apps use Google AdMob, which can use the Android advertising ID for ad delivery – only as described in Section 4.3 and, for personalized ads, only with your consent.
4.2 Advertising in Free Apps
Some of our free apps may display advertisements. Unless Section 4.3 states otherwise for a specific app:
- Only non-personalized, contextual ads are shown
- No personal data is used for ad targeting
- You can remove ads permanently via an in-app purchase
4.3 Google AdMob in Android Apps (Steppy)
The free version of Steppy – Schrittzähler / Pedometer for Android shows ads through Google AdMob. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
- Data collected by the Google Mobile Ads SDK: IP address (from which an approximate location is derived), device identifiers including the Android advertising ID, interactions with ads, and diagnostic data
- Purposes: serving and measuring ads, analytics, and fraud prevention
- Consent: in the EEA, the UK and Switzerland, the app asks for your consent through Google's consent form before the first ad is requested (Art. 6 (1)(a) GDPR). Without consent, only non-personalized ads are shown.
- Changing your choice: at any time in the app under Settings → Privacy → Manage Ad Preferences
- Advertising ID: you can reset or delete it in your Android settings (Settings → Privacy → Ads)
- No ads: Steppy Premium removes all advertising
Health data is never used for advertising and is never passed to the ad SDK. More information: How Google uses information from apps that use its services.
5. Third-Party Services
Our apps may integrate the following third-party services, each governed by their own privacy policies:
5.1 Apple App Store / Google Play Store
5.2 iCloud (Apple) / Google Drive
If you enable cloud synchronization within an app, your data is stored according to Apple iCloud or Google's terms of service. We have no access to this synced data.
5.3 StoreKit / Google Play Billing
In-app purchases are processed entirely by Apple or Google. We do not receive or store any payment information – the app only learns whether a purchase or subscription is active.
5.4 Google AdMob (Android)
Used for advertising in certain free Android apps, see Section 4.3. Google Privacy Policy
6. Legal Basis for Data Processing (GDPR)
Where any data processing occurs, the legal basis is one of the following:
- Art. 6 (1)(a) GDPR – Consent: Where you have given explicit consent (e.g., enabling HealthKit or Health Connect access, or agreeing to personalized ads)
- Art. 6 (1)(b) GDPR – Contract Performance: Where processing is necessary to provide the app functionality you requested
- Art. 6 (1)(f) GDPR – Legitimate Interests: For security and fraud prevention measures
7. Your Rights Under GDPR (Art. 15–21)
As a user in the European Economic Area, you have the following rights:
- Right of Access (Art. 15 GDPR): Request information about data stored about you
- Right to Rectification (Art. 16 GDPR): Request correction of inaccurate data
- Right to Erasure (Art. 17 GDPR): Request deletion of your data ("right to be forgotten")
- Right to Restriction (Art. 18 GDPR): Request restriction of processing
- Right to Data Portability (Art. 20 GDPR): Receive your data in a machine-readable format
- Right to Object (Art. 21 GDPR): Object to processing based on legitimate interests
- Right to Withdraw Consent (Art. 7 (3) GDPR): Withdraw consent at any time without affecting prior processing
Since our apps generally do not collect personal data, most of these rights are not applicable in practice. For questions, please contact us at the address below.
Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority. The competent authority for Hesse, Germany, is:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Postfach 3163, 65021 Wiesbaden
www.datenschutz.hessen.de
8. Data Deletion
You can delete all locally stored app data at any time by:
- Uninstalling the app from your device
- Deleting app data in your device settings (iOS: Settings → General → iPhone Storage; Android: Settings → Apps → [App] → Storage → Clear storage)
- Using the in-app delete/reset function (where available)
9. Data Security
We implement appropriate technical and organizational security measures including:
- Encrypted data transmission (HTTPS/TLS 1.2+) for any network requests
- Secure local storage of sensitive data (Apple Keychain / Android Keystore)
- Regular security reviews and updates
- Strict data minimization – if data is not needed, it is not collected
10. Children's Privacy (COPPA / GDPR-K)
Our apps are not specifically targeted at children under the age of 13 (or 16 in applicable EU member states). We do not knowingly collect personal data from minors. If you believe that a child has provided personal data through our app, please contact us immediately and we will delete such data promptly.
11. Scope of This Policy
This Privacy Policy applies to all apps developed and published by DCS Digital Code Solutions UG (Code Expert), including but not limited to:
- Health and fitness apps
- Productivity and utility apps
- Widget apps
- Games
- Finance and crypto tools
Individual apps may have supplementary privacy notices within the app if they collect specific data. Those notices take precedence for the specific app.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our apps or applicable law. Material changes will be communicated via an app update notice or by posting the updated policy at this URL. The date of the last update is shown at the top of this page. Continued use of an app after changes constitutes acceptance of the updated policy.
Contact for Privacy Inquiries
For any questions about how your data is handled in our apps, please contact us:
DCS Digital Code Solutions UG (haftungsbeschränkt)
Carl-von-Linde-Str. 27, 65197 Wiesbaden, Germany
Email: [email protected]
Last updated: May 2026 | DCS Digital Code Solutions UG (haftungsbeschränkt) · This policy is available in German at Datenschutzerklärung