Privacy Policy
App Name: PhotoManager
Effective Date: March 3, 2026
Last Updated: March 3, 2026
Key Point: PhotoManager is a 100% on-device photo management app. Your photos never leave your device. We don't collect, store, or transmit your photo content or personal data.
1. Information We Collect
1.1 Photo and Video Content
We do NOT collect, store, or upload your photos or videos. All photo analysis, organization, and cleanup suggestions are performed entirely on your device using on-device machine learning and system frameworks.
1.2 Metadata Analysis
The app accesses photo metadata (such as creation date, file size, media type, and smart album classifications provided by iOS PhotoKit) to generate cleanup suggestions. This metadata:
- Is processed locally on your device only
- Is never transmitted to our servers or third parties
- Is not stored persistently beyond your current session
1.3 Personal Data
We do not collect any personal information from you. The app does not require account creation, and we do not collect:
- Name, email address, or contact information
- Device identifiers or advertising IDs
- Location data
- Usage analytics or crash reports (unless you explicitly enable them in iOS Settings)
2. Photo Library Permission
PhotoManager requires access to your photo library to function. Here's what this permission allows:
2.1 Why We Need This Permission
The app needs to analyze your photos to:
- Identify potential duplicates, screenshots, and low-quality images
- Generate intelligent cleanup suggestions
- Organize photos by smart categories (People, Places, etc.)
- Execute actions you confirm (save to album, archive, delete)
2.2 Your Control
- Limited Access (iOS 14+): You can grant access to selected photos only. Note: This may limit scanning coverage.
- Full Access: Recommended for complete library analysis.
- Permission Revocation: You can revoke photo access anytime in iOS Settings. The app will stop functioning but will not retain any data.
2.3 On-Device Processing
All analysis happens locally using:
- iOS PhotoKit and Vision frameworks
- Core ML models running on your device's Neural Engine
- Custom rule engine with local configuration files
No photo data is transmitted to external servers.
3. How We Use Your Data
The limited metadata accessed is used solely for:
- Generating cleanup suggestions based on rules you configure
- Displaying photo organization insights (counts by category)
- Executing actions you explicitly confirm (delete, archive, save to album)
4. Data Retention
- Session Data: Temporary analysis results are cleared when you close the app or start a new scan.
- User Preferences: Settings like scan range, policy mode, and keep-albums are stored locally using iOS AppStorage.
- No Cloud Sync: We do not sync any data to cloud servers.
5. Third-Party Services
5.1 Current Status
PhotoManager does not integrate any third-party analytics, advertising, or data collection SDKs.
5.2 Apple Ecosystem
The app uses standard iOS system frameworks:
- PhotoKit: For photo library access and metadata
- Vision: For on-device image analysis (face detection, text recognition)
- Core Image: For quality metrics (blur, exposure)
- AVFoundation: For video analysis
5.3 Future Changes
If we introduce any feature requiring network access or third-party integration, we will:
- Update this privacy policy
- Request explicit user consent
- Provide an opt-out option
6. Subscriptions and Payments
If the app offers in-app purchases or subscriptions:
- All payments are processed by Apple App Store
- We do not receive or store your payment information
- Subscription management and refunds are handled through Apple
- Apple's privacy policy applies to payment data
7. Children's Privacy
PhotoManager does not knowingly collect data from children under 13. The app is designed for general audiences and does not target children.
8. GDPR Compliance (European Users)
If you are located in the European Economic Area (EEA), you have the following rights:
- Right to Access: Since we don't collect personal data, there is no data to access.
- Right to Rectification: Not applicable as no personal data is stored.
- Right to Erasure: Delete the app to remove all local data.
- Right to Data Portability: Not applicable.
- Right to Object: The app processes data only with your explicit permission.
Legal Basis for Processing: Your consent when granting photo library access.
9. CCPA Compliance (California Users)
Under the California Consumer Privacy Act:
- We do not sell your personal information
- We do not disclose personal information to third parties
- Your rights under CCPA are preserved
10. Security
Since all data stays on your device, security is largely handled by iOS system protections:
- Photos are protected by iOS sandboxing
- App data is encrypted when device encryption is enabled
- No network transmission means no interception risk
11. International Data Transfers
No data leaves your device, so there are no international data transfers.
12. Changes to This Privacy Policy
We may update this privacy policy from time to time. If we make material changes:
- We will update the "Last Updated" date
- For significant changes, we will notify you through the app
- Continued use after changes constitutes acceptance
13. App Privacy Labels (Apple App Store)
Per Apple's App Store requirements, our privacy labels are:
- Data Used to Track You: None
- Data Linked to You: None
- Data Not Linked to You: None
14. Contact Us
If you have any questions about this privacy policy or our data practices:
We typically respond to privacy inquiries within 5 business days.
15. Data Protection Officer
As a small independent developer, we do not have a designated Data Protection Officer (DPO). Privacy-related inquiries should be directed to the contact email above.
This privacy policy was generated for PhotoManager, an on-device photo management application.
For questions or concerns, please contact us before leaving a review - we're here to help.