Privacy Policy

In short

Who is responsible

Willow is developed by Marco Lüthi, the controller responsible for data processing under the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).

Marco Lüthi
Gutstrasse 172
8055 Zürich
Switzerland
hi@luthi-mar.co

Permissions

Willow doesn't ask for any permission. It doesn't use the camera, your photo library, the microphone, your contacts or your location. On a foldable iPhone, it reads how far the device is folded to fold the book along with it; that angle is used in the moment and never stored.

Your progress

Which chapters you have read, the bones you earned and your settings (music, sounds, vibration) are stored on your device. They may be included in your device backups, depending on your own iCloud or computer backup settings. “Start the book over” in the settings erases your progress.

Scrapbook photos

When you finish a chapter, Willow takes a picture of the game on your screen and keeps it as that chapter's polaroid in the scrapbook. These pictures show only the game, are stored inside the app on your device and never leave it. “Start the book over” or deleting the app removes them.

Purchases

Part One is free. Opening the full book is an in-app purchase made through Apple's App Store, under Apple's terms and privacy policy (apple.com/legal/privacy). The developer receives no payment details and no personal information about you, only Apple's anonymous sales reports. The app remembers on your device that the book is unlocked and checks it with the App Store.

Legal basis

Where the GDPR applies, the processing described above happens on your device and is necessary to provide the app you use (Art. 6(1)(b) GDPR). Under the Swiss FADP, we process personal data only as described here and in line with its principles.

What the app does not do

• No account, sign-up or login.
• No connection to the developer: nothing you do in the book is sent to the developer or to any server of the developer.
• No advertising, analytics, crash-reporting or tracking SDKs.
• No tracking across apps or websites, and no selling or sharing of data with data brokers.

TestFlight beta

While Willow is in beta, it is distributed through Apple's TestFlight. If you join the beta, Apple shares information such as your email address (if you were invited by email), crash reports and feedback you choose to send with the developer, under the TestFlight terms and Apple's privacy policy. This is used only to fix bugs and improve the app. Purchases made in the beta are test purchases and cost nothing.

This website

This website is a static site without cookies, analytics or tracking. Fonts are served from this website itself, so your browser does not contact third-party font services. When you visit a page, the hosting provider Vercel Inc. (based in the United States, with data centres worldwide) automatically records technical access data in server logs: your IP address, date and time, the requested page, referrer and browser type. This is needed to deliver the site and keep it secure (legitimate interest, Art. 6(1)(f) GDPR). The logs are deleted after a short period. Links to the App Store take you to Apple, where Apple's privacy policy applies.

Your rights

You have the right to request access to your personal data and to have it corrected or deleted, to object to or restrict processing, and to data portability. Because the apps store your data on your device and do not identify you, the developer usually holds no personal data about you. Most of it you can delete yourself by deleting the app.

To exercise your rights, email hi@luthi-mar.co. You can also lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in the EU the data protection authority of your country.

International transfers

Apple may process data in the United States and other countries. Apple describes the safeguards it uses for these transfers, such as the Data Privacy Framework and standard contractual clauses, in its privacy policy. This website is hosted by Vercel Inc., based in the United States; its server logs are transferred under the same kind of safeguards.

Children

Willow is made for families, and children may play it. The app collects no personal data from anyone, children included. Before any purchase, a grown-up gate asks for three digits spelled out in words, so a purchase needs a grown-up.

Changes to this policy

If the app starts handling data differently, this page will be updated before the change ships, and the date at the top will change.