ArtsApp: Arts & Live Paintings — Privacy Policy
Effective date: 24 August 2026 Last updated: 24 August 2026
This Privacy Policy explains what happens to information when you use the ArtsApp: Arts & Live Paintings mobile application for iPhone, iPad and Apple Watch, including its widgets (the “App”).
1. Who is responsible for your data
The controller of your personal data is:
| Name | Anton Razguliaev, Individual Entrepreneur (Անհատ ձեռնարկատեր) |
| Country of registration | Republic of Armenia |
| State registration number | 286.1580989 |
| Taxpayer identification number (ՀՎՀՀ) | 20286933 |
| Registered address | N. ZARYAN ST. BLD. 22A, YEREVAN 0051, Armenia |
| Email for all privacy matters | antonr8.apps@outlook.com |
We are a one-person developer. There is no data protection officer, because the scale of processing does not require one; write to the email above and the message reaches the person who makes the decisions.
2. The short version
- The App has no accounts. You never create a login, and we never ask for your name, phone number, address or date of birth.
- All artworks, texts and videos are stored inside the App. Reading an article or looking at a painting produces no network request, so no server anywhere records what you read.
- Your favourites, your reminder time, your chosen language and your reading state never leave your device.
- We do process data in three situations: when you buy or restore a subscription, when you tap the binoculars button to see a museum’s surroundings, and when you write to support.
- The App contains no advertising. Nothing is shown to you and no ad network serves anything inside the App.
- We do not sell personal data.
3. What we process, why, and on what legal basis
3.1 Data that stays on your device only
| Data | Where it is kept | Why |
|---|---|---|
| List of favourite artists, paintings, genres and collections | UserDefaults on your device |
To show your Favourites tab |
| Daily reminder on/off and the time you chose | UserDefaults on your device |
To schedule a local notification |
| Interface language you selected | UserDefaults on your device |
To show the App in that language |
| Whether you have seen the onboarding, and a counter of how many times the App was opened | UserDefaults on your device |
Not to show onboarding twice, and to ask for an App Store rating no more than once every few launches |
| Cached “painting of the day” (title, artist, image) | Shared App Group container on your device | To render the widget and the Apple Watch complication without opening the App |
This information is not transmitted to us or to anyone else. It is removed together with the App when you delete it from your device. If you use iCloud backups, Apple may include this data in your own encrypted backup under Apple’s privacy policy.
3.2 Subscription purchases
Payments are processed by Apple. We never receive your card number, your Apple Account credentials or your billing address. Apple’s handling of that data is governed by Apple’s own privacy policy.
To validate purchases, keep your subscription working across your devices, and let you restore purchases after reinstalling, the App uses Adapty (https://adapty.io) as a subscription infrastructure provider acting on our behalf. When you open the purchase screen or complete a purchase, the following is processed:
| Data | Purpose |
|---|---|
| Identifier for Vendor (IDFV) and a pseudonymous Adapty profile ID | To attach a subscription to a device without an account |
| App Store transaction identifiers and transaction data, subscription status, renewal and cancellation events | To grant, renew, restore and revoke access to paid content; to detect fraudulent or duplicate purchases |
| Device model, iOS version, App version, device language, App Store storefront country | To show the correct prices and to diagnose purchase failures |
Legal basis (GDPR): performance of a contract with you, Art. 6(1)(b) — without this processing a paid subscription cannot technically work; and our legitimate interest in preventing payment fraud and in understanding aggregate subscription performance, Art. 6(1)(f).
3.3 “Look Around” — seeing a museum’s surroundings
Some screens have a binoculars button that opens Apple’s Look Around street imagery for the place where a museum, a studio or an artist’s home stands.
- The App sends the coordinates of that landmark to Apple Maps. Those coordinates are stored inside the App and are the same for every user.
- The App never asks for your location and never reads it. There is no location permission, and your own position is not involved in any way.
- Apple receives the request as the operator of the Maps service and handles it under Apple’s privacy policy.
This is the only feature of the App that reaches the network while you are simply browsing, and it happens only when you tap the button.
Legal basis (GDPR): performance of a contract with you, Art. 6(1)(b) — delivering the feature you asked for by tapping the button.
3.4 Notifications
The daily “painting of the day” reminder is a local notification scheduled by your own device. There is no push server, no device token is sent anywhere, and we do not learn whether you opened the notification. Turning notifications off in the App or in iOS Settings stops it immediately.
3.5 Apple’s own analytics and crash reports
Apple may provide us with App Analytics and crash reports in aggregated form, and only if you have enabled *Share iPhone & Watch Analytics → Share With App Developers* in iOS Settings. That data reaches us as statistics — installs, sessions, retention, crash traces — and does not identify you personally.
Legal basis (GDPR): legitimate interest in maintaining and improving the App, Art. 6(1)(f), based on data Apple has already aggregated and pseudonymised.
3.6 When you write to support
If you email antonr8.apps@outlook.com, we receive your email address, whatever you write, and — if you use the “Contact support” button in the App — a short technical block that the App puts into the draft: App version and build, iOS version, device model identifier and interface language. You can delete that block before sending; the message will still reach us.
Support mail is stored in the Outlook mailbox operated by Microsoft and is kept for up to 24 months after the conversation ends, so that we can recognise a recurring problem.
Legal basis (GDPR): legitimate interest in answering user requests, Art. 6(1)(f); for correspondence about a subscription, performance of a contract, Art. 6(1)(b).
4. Who else receives data
| Recipient | Role | What it gets | Their terms |
|---|---|---|---|
| Apple Inc. and its regional subsidiaries | Independent controller — App Store distribution, payment processing, subscription management, Maps and Look Around | Purchase and subscription data, aggregated analytics, landmark coordinates you request (§3.3) | https://www.apple.com/legal/privacy/ |
| Adapty | Processor acting on our instructions | Data listed in §3.2 | https://adapty.io/privacy/ |
| Microsoft | Processor — email hosting for the support mailbox | The content of the emails you send us | https://privacy.microsoft.com/privacystatement |
We do not use data brokers, and we do not display advertising inside the App. We do not disclose your data to anyone else, except where we are legally obliged to do so by a lawful request from a competent authority, or where it is necessary to establish or defend a legal claim.
5. International transfers
We are established in the Republic of Armenia. Apple, Adapty and Microsoft operate infrastructure in several countries, including the United States, so data described above may be processed outside your country of residence.
Where data is transferred from the European Economic Area, the United Kingdom or Switzerland, the transfer relies on the European Commission’s Standard Contractual Clauses, on an adequacy decision, or on another transfer mechanism recognised by Art. 46 GDPR, as set out in the agreements with those providers. You may request further information about the safeguards by writing to us.
6. How long data is kept
| Data | Retention |
|---|---|
| Everything in §3.1 (favourites, reminder, language, widget cache) | Until you delete the App or clear it in the App |
| Subscription records at Adapty | For the life of the subscription plus the period required to handle refunds, chargebacks and disputes, and to comply with accounting and tax obligations of the Republic of Armenia |
| Support correspondence | Up to 24 months (§3.6) |
7. Your rights
Depending on where you live, you have the following rights. We answer every request within 30 days and never charge for the first request.
If the GDPR or the UK GDPR applies to you — the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection to processing based on legitimate interest (Art. 21), and the right to withdraw consent at any time without affecting the lawfulness of processing before the withdrawal (Art. 7(3)). You also have the right to lodge a complaint with your national supervisory authority.
If you are a California resident — the right to know, to delete, to correct, and to opt out of the sale or sharing of personal information (CCPA/CPRA). We do not sell personal information, and we do not share it for cross-context behavioural advertising. There is therefore nothing to opt out of and no request to send us, and we will never discriminate against you for exercising a right.
If you are in Armenia — the rights provided by the Law of the Republic of Armenia “On Protection of Personal Data”, including access, correction and deletion.
To exercise any of these rights, write to antonr8.apps@outlook.com. Because the App has no accounts, we may need the App Store transaction identifier of your purchase to find records that relate to you — without some identifier we may be unable to locate any data, and we will tell you so honestly instead of guessing.
8. Deleting your data
- Data on the device: delete the App. Everything in §3.1 goes with it.
- Subscription records: email us and we will ask Adapty to erase the records connected to your device, except what we must keep for tax and accounting law. Deleting these records does not cancel your subscription — cancel it in iOS Settings → your name → Subscriptions, otherwise Apple keeps billing you.
- Support correspondence: ask, and we delete the thread.
9. Age of users
The App carries a 13+ age rating on the App Store. It is not directed to children, and we do not knowingly process personal data of anyone under that age. The App requires no registration and asks for no personal details. If you believe a child has used the App and provided personal data to us, write to us and we will delete it.
The rating reflects the content: the App is an encyclopaedia of fine art and reproduces classical works that include nudity in an artistic context, as well as depictions of wine and drinking in the App’s own illustrations.
10. Security
Content is bundled with the App and needs no network access. Data on the device is protected by iOS itself and by the device passcode and encryption. Communication with Apple and Adapty runs over TLS. No system is perfectly secure, so we do not promise absolute protection; we do promise to notify you and the competent supervisory authority as required by law if a breach occurs that is likely to affect your rights.
11. Changes to this Policy
If we change what data is processed or why, we will update this document, change the date at the top, and — for material changes — show a notice inside the App or in the App Store release notes before the change takes effect. Continuing to use the App after that means the updated Policy applies.
12. Contact
antonr8.apps@outlook.com
Anton Razguliaev, Individual Entrepreneur N. ZARYAN ST. BLD. 22A, YEREVAN 0051, Armenia State registration number 286.1580989