Privacy Policy

Last updated: November 4, 2026

1. Introduction

This Privacy Policy explains how Spiral ("the App") handles information when you use our mobile application.

The App is designed with privacy in mind. We aim to collect as little personal information as possible and keep information on your device wherever feasible.

Data Controller

Nicole Saleh
Email: nicolemsaleh@gmail.com

2. Information we collect

The App requires users to enter a town or city name to provide location-relevant nature experiences, activities and content.

Town or city name

You must enter a town or city name to use the App. This information is used to provide location-relevant content and experiences.

The App does not access your device's GPS, precise location or location services. Your location is not automatically tracked.

Photos

You can take or select photographs to complete daily adventures and document your personal nature experiences.

Photographs are stored locally on your device. You can also choose to save them to your device's photo library.

Photographs are not uploaded to our servers or shared with us.

Technical information

The App does not use third-party analytics, advertising or tracking services. We do not intentionally collect usage analytics or personal information through third-party SDKs.

3. How your information is stored

The information you enter and the content you create within the App are stored locally on your device.

We do not operate a cloud-based user account system or store your personal app data on our own servers.

Your information remains on your device unless you choose to share or export it using functionality provided by your device or operating system.

Please note that device-level backups, such as iCloud backups, may include App data depending on your device settings.

4. Camera and photo library permissions

The App may request access to your camera or photo library when you choose to take or select photographs.

You control these permissions through your device settings. You can manage access or withdraw permissions at any time.

The App only uses camera and photo library access to support its photo-related features.

5. Legal basis for processing

Where the GDPR applies, we rely on the following legal bases:

  • Contract (Article 6(1)(b)): Processing the town or city name and other necessary information to provide the App's functionality.

  • Consent (Article 6(1)(a)): Access to camera or photo library features where consent or device permission is required.

6. Sharing of information

We do not sell, rent or share your personal information with third parties for advertising or marketing purposes.

The App does not include user accounts, public profiles or community photo-sharing features.

We do not transmit the town name or photographs to external analytics or advertising services.

7. Data retention and deletion

Your information remains stored locally on your device for as long as you use the App.

You can delete photographs and other locally stored information through the App where functionality is provided, or by deleting the App and its associated data from your device.

Information included in device backups may remain available according to your device backup settings.

8. Your rights under the GDPR

Where the GDPR applies, you may have rights including:

  • The right to access your personal data.

  • The right to correct inaccurate personal data.

  • The right to request deletion of personal data.

  • The right to restrict processing.

  • The right to object to certain processing.

  • The right to data portability, where applicable.

To exercise your rights or ask questions about privacy, contact us at:

nicolemsaleh@gmail.com

You also have the right to lodge a complaint with a competent data protection supervisory authority.

9. Children's privacy

The App is suitable for all ages.

10. Security

We take reasonable measures to protect information handled by the App.

Because information is stored locally, the security of your device, including its passcode and backup settings, also plays a role in protecting your information.

11. Changes to this Privacy Policy

We may update this Privacy Policy if the App's functionality or data processing practices change.

12. Contact

For questions about this Privacy Policy or the handling of personal information, contact:

Nicole Saleh
nicolemsaleh@gmail.com