Shackles.io

Privacy Policy

For the app "Shackles.io: LOLER Log" and the website shackles.io · Effective: 20 July 2026

The short version: the app keeps all of your data on your device. We run no servers for it, we have no accounts, and we cannot see, access, recover or restore your records. This page explains that in full, plus the few places where we do process personal data: support email, purchases (handled by Apple and Google), and this website's hosting.

1. Who is responsible (controller)

The controller for the processing described in this policy is:

ML Upskill Agents UG (haftungsbeschränkt)
Hohe Straße 13
92249 Vilseck
Germany
Email: info@upskillagents.com
Phone: +49 156 79602536

Full company details are in the Legal Notice (Impressum).

2. Your records in the app: stored on your device only

Everything you record in the app — your kit register, examination and check records, defect log, reminders, generated reports and settings — is stored in a local database on your device. It is not transmitted to us or to anyone else. Specifically, the app has:

Because nothing is collected, this matches the App Store privacy label "Data Not Collected" and the Google Play Data safety declaration that no data is collected or shared.

We are not a controller or processor of the records you keep in the app: we perform no processing of them and determine neither the purposes nor the means of your record-keeping. You alone control that data on your device.

Retention and deletion: your records stay on your device until you delete them. Deleting a record in the app deletes it; deleting the app deletes the app's entire database. Backup or export files you created remain wherever you saved them, under your control — delete those separately if you no longer want them. We could not delete your data for you even on request, because we never have it; there is also no consent held by us to withdraw for app data, since we process none.

3. Exports and backups

The app can generate PDF reports and CSV exports and create a local backup file. These leave your device only when you actively share or save them (for example by email, a messaging app or a cloud drive you choose). Where you send them — and which third-party service then processes them — is entirely under your control and subject to that service's own privacy terms.

4. Reminders and notifications

Reminders are scheduled locally on your device using the operating system's local-notification feature. There are no push notifications, no notification servers, and nothing about your reminders leaves the device.

5. Purchases

All purchases (the monthly subscription and the lifetime unlock) are made through Apple's App Store or Google Play, never through us. Apple and Google process your payment, billing and account data as independent controllers under their own privacy policies:

We do not receive your name, payment details or other personal purchase data from the stores. We see only pseudonymous or aggregated reporting (for example sales figures by country) which we cannot link to you. The app verifies your entitlement (trial, subscription or lifetime unlock) on the device through the store's own mechanisms.

6. Support email

If you contact us (for example at the address on our support page), we process your email address, the contents of your message and any details you choose to include, solely to handle your request. The legal basis is Art. 6(1)(b) GDPR where your request relates to a purchase or to the app you use (performance of a contract or pre-contractual steps), and otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering enquiries). Support requests never require you to send us your records — please don't include personal data you don't need to.

Retention: we keep support correspondence only as long as needed to resolve your request and for a reasonable period afterwards in case of follow-ups, then delete it — except where German commercial-law retention duties (§ 257 HGB, § 147 AO) require us to keep business correspondence for up to six years. You can ask us to delete your correspondence at any time (see section 8); we will delete it unless a statutory retention duty requires otherwise.

7. This website

shackles.io is a static website hosted on GitHub Pages, a service of GitHub, Inc. When you visit it, GitHub processes technically necessary server logs (for example your IP address, the time of access and browser information) to deliver the site and keep it secure and stable. The legal basis is Art. 6(1)(f) GDPR — the legitimate interest in the secure and stable operation of the website. We do not receive and cannot access these logs. See GitHub's Privacy Statement. GitHub, Inc. is based in the USA and participates in the EU-U.S. Data Privacy Framework (including the UK Extension), which safeguards transfers connected with this hosting.

This site sets no cookies, stores nothing in your browser, and uses no analytics, tracking or third-party embeds. There are no contact forms; the only way to reach us from this site is email.

8. Your rights

For the processing we actually perform (support email, and the website chain described above), you have the rights under the EU GDPR and the UK GDPR to:

To exercise any of these rights, email info@upskillagents.com. Where processing is based on consent (we currently ask for none), you could withdraw it at any time with effect for the future.

You also have the right to complain to a supervisory authority. Our lead authority is the Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA, lda.bayern.de). If you are in the UK, you can complain to the Information Commissioner's Office (ICO, ico.org.uk).

9. Changes to this policy

If we make material changes — for example if a future version of the app ever adds optional online features — we will update this page and change the effective date at the top before those changes apply.