Privacy Policy

Vault9 — app and website
Effective date: 2026-11-10
Version: 1.1

This Privacy Policy explains what personal data we process when you use the Vault9 iOS app (“the App”), visit our website https://vault9app.com (“the Website”), or contact our support. It also explains your rights under the EU General Data Protection Regulation (GDPR).

1. Short summary

• We never see what is in your vault. The App does not send your unlock secret (pattern or passphrase) or your Secret Key to us or to anyone else. Your Emergency Kit contains your Secret Key. You save or print the kit yourself, and you decide where you keep it. Your photos, videos, documents and file names are encrypted on your device. They stay on your device and, if the App’s iCloud backup is on, in your own iCloud account (section 4.5), without the Secret Key. They are never sent to us. When you export a file, the App decrypts it and gives it to iOS. From then on, the App no longer protects that file.
• No account. You do not need to give us your name, email, or phone number to use the App.
• No ads, no tracking, no selling of data. We do not sell or share your data for advertising, and we do not track you across other companies’ apps or websites.
• Usage statistics. The App sends us usage statistics through PostHog, with a random install ID. They never hold your photos or your secrets. You can turn this off in Settings (section 4.1).
• Crash reports from Apple come to us only if you agreed to share them with app developers in your iPhone settings. The usage statistics also hold the type of a crash.
• Activity log: the App keeps a short log of what you and the App did, on your iPhone only. It holds no secrets and no file names. We receive it only if you send it to us (section 4.6).
• Support: if you email us, we use your email to answer you.
• Website: no cookies. Cloudflare Web Analytics counts visits and page load times, without cookies and without identifying you (section 4.7).

2. Who is responsible (data controller)

The data controller is Sinóros-Szabó Péter EV.. The contact details are in section 12.

We have not appointed a data protection officer, because the law does not require one for our processing.

3. Data that we do NOT collect

The App is designed so that we cannot access your private data. We do not collect, receive, or store:

• the photos, videos and documents in your vault, their thumbnails, names, dates, locations or other metadata;
• the iCloud backup of your vault (it is in your own iCloud account, and we cannot access it);
• your unlock secret (pattern or passphrase), your Secret Key, your Emergency Kit, or any encryption key;
• your Face ID or Touch ID data (iOS handles this; the App receives only a yes/no result);
• your contacts, location, advertising identifier (IDFA), or contents of your photo library;
• your name, email or phone number (unless you contact us).

The App processes your files only on your device, to encrypt them and show them to you. This processing happens under your control, and we have no access to it.

4. Data that we process

4.1. Usage statistics (App)

The App sends usage statistics to us. Our processor is PostHog (EU Cloud). We use them to see how people use the App, where they stop in the first screens, which errors happen, whether people come back, and how many people buy.

• What we receive: which screens and actions you use, for example that an import started, a vault was unlocked or an album was made; error codes, warning names and the type of a crash; numbers in groups, for example “2–10 items”; the type and the result of a purchase, and your Pro state; the version of the App and of iOS, the iPhone model, the language of the App, and whether your App Store country is in the region with a checkbox (not the country); and a random install ID.
• What we never receive: your files, thumbnails or file names, album names, dates or sizes of your items, your unlock secret, your Secret Key, your Emergency Kit, any key, the IDs of your vault or your items, a transaction ID or a receipt, your IDFA, or free text.
• The install ID is made by the App and is stored on your iPhone. It has no link to your Apple Account, your vault or your name. A new iPhone gets a new ID. Because of this ID, the data is pseudonymous, and we treat it as personal data.
• IP address: your iPhone connects to PostHog, so PostHog can see your IP address during the connection. The App asks PostHog not to use it for a location, and the project is set to discard it.
• Your choice in the EU, the EEA, the UK and Switzerland (and when the App cannot tell the App Store country): a checkbox “Share usage statistics” on the last screen of the setup. It is checked by default, and you can clear it. No ID is made and nothing is sent before you leave that screen with the box checked. If you clear it, nothing is sent.
• Your choice in other countries: the same screen says that the App sends usage statistics. The statistics of the setup screens are sent from the first screen, before that notice.
• Turn it off at any time: Settings → Privacy → “Share usage statistics”. The App then sends one last event that says you turned it off, and deletes the ID and the waiting events from your iPhone. If you turn it on again, the App makes a new ID, so we cannot connect the old and the new data.
• A new iPhone: if you use the iCloud backup, your choice is saved in your own iCloud account, and the App uses it when you open your vault from the iCloud backup on a new iPhone. You can change it in Settings.
• Legal basis: in the EU, the EEA, the UK and Switzerland, and when the App cannot tell the country: your consent (GDPR Article 6(1)(a); Hungarian Act C of 2003 §155(4); ePrivacy Directive Article 5(3)). In other countries: our legitimate interest in understanding and improving the App (GDPR Article 6(1)(f)).
• How long: PostHog keeps the events for 1 year. Events that wait on your iPhone are deleted after 7 days.

4.2. Crash reports and App Store statistics (through Apple)

If you agreed in your iPhone settings (Settings → Privacy & Security → Analytics & Improvements → “Share With App Developers”), Apple sends us crash reports and some usage statistics for the App. Apple removes direct identifiers before it shares them with us. Apple also gives us aggregated statistics about downloads and sales in App Store Connect.

• Why: to find and fix errors that could damage the App or your data.
• Legal basis: our legitimate interest in a stable and safe App (GDPR Article 6(1)(f)). Apple asks for your consent before it shares this data.
• How long: Apple decides how long it makes this data available to us. We keep no separate copy, except a crash report that we download to fix an error. We delete that copy when the error is fixed.
• Apple’s processing is described in Apple’s privacy policy: https://www.apple.com/legal/privacy/

4.3. Support emails

What	Your email address, your name if you give it, your message, attachments you send, the activity log if you send it (section 4.6), and any information you choose to include (for example, App version or device model).
Why	To answer your question and to handle your complaint. The activity log also helps us to find what happened, and is a record if there is a dispute about the App.
Legal basis	Our legitimate interest in answering you, and in establishing, exercising or defending legal claims (GDPR Article 6(1)(f)); for complaints, our legal obligations under Hungarian consumer protection law (GDPR Article 6(1)(c)).
Provider	Google Ireland Limited (Google Workspace) as our data processor.
How long	Up to 6 months after your request is closed. Records of consumer complaints: 3 years, as Hungarian consumer protection law requires. An activity log that you sent: up to 5 years after your request is closed (the general limitation period in Hungary), or until a dispute ends.

Do not send us your unlock secret, Secret Key, Emergency Kit, or private files. We do not need them, and we cannot use them to help you.

4.4. Purchases (Vault9 Pro)

Apple processes all payments. We do not receive your payment card or Apple ID details. The App checks your purchase on your iPhone with Apple’s StoreKit. It never sends a transaction or a receipt. The usage statistics hold only the type and the result of a purchase (section 4.1). We receive from Apple only aggregated sales and financial reports in App Store Connect. Legal basis: performance of the contract (GDPR Article 6(1)(b)) and our tax and accounting obligations (GDPR Article 6(1)(c)).

4.5. iCloud backup (App)

What	The encrypted vault (the same encrypted files as on your iPhone, never the Secret Key), a random device ID that the App makes, the model of the iPhone that uses the iCloud backup, and the date of the last complete upload.
Where	In the App’s private database in your own iCloud account (Apple CloudKit). Apple stores it under its iCloud terms and privacy policy: https://www.apple.com/legal/privacy/
Who can access it	You, through your Apple Account. Apple stores it. We cannot access your private iCloud database. The files are encrypted. To decrypt them, your Secret Key and your unlock secret are needed.
Your choice	The App uses the iCloud backup when iCloud works. You can delete it in the App, or in your iPhone settings for iCloud.

We do not receive this data, so we do not keep it and we cannot give it to anyone.

4.6. Activity log (App)

What	One short line for each action of you or the App, with the date and time: for example the creation, unlock and lock of the vault, a wrong unlock try, an import, view, edit, export or delete of an item, a change of a setting, the Emergency Kit steps, warnings and errors that the App showed, and iCloud backup events. The lines hold random IDs (for example 8d2a5d6e-…), the App and iOS versions and the iPhone model.
What it never holds	Your unlock secret, your Secret Key, any key, your files, thumbnails, file names, album tags or other text that you typed. For an imported item, it holds a content ID that only your unlocked vault can calculate again.
Where	Only on your iPhone, in the App’s storage. It is not in the iCloud backup and not in the iPhone backup. It is not encrypted, because the App writes some lines before you unlock the vault.
Protection against changes	The App signs the log with a key that stays in your iPhone’s security chip. Apple’s App Attest service confirms that this key belongs to the App. For this, your iPhone sends a request to Apple one time per log. Apple does not receive the log.
Who can access it	You can read it in the App (Settings → Support → Activity log → Show logs). We receive it only when you send it to us. “Send to support” uploads all parts of the log to our iCloud storage at Apple (CloudKit), with the App and iOS versions, the iPhone model, a random reference code, and an ID of your iCloud account that Apple makes only for our App. Only we can read an upload. If you use another app (for example email), section 4.3 applies. The App never sends the log on its own.
How long	On your iPhone, the App keeps up to 300 MB and then removes the oldest part. You cannot delete single lines, so that the log stays complete. If you delete the App, the log is deleted. We keep a log that you sent for 5 years, and an incomplete upload for 7 days.
Legal basis	The log stays on your device under your control, and we do not process it there. When you send it: section 4.3.

4.7. Website

• Hosting: the Website is hosted by Cloudflare, Inc. To deliver the pages, the provider processes your IP address and technical request data (browser type, time, requested page). Legal basis: our legitimate interest in a secure, working website (GDPR Article 6(1)(f)). Cloudflare decides how long it keeps these logs. We keep no copy of them.
• Website statistics (Cloudflare Web Analytics): when a page loads, a small script from Cloudflare (static.cloudflareinsights.com) runs in your browser. It sends to Cloudflare the address of the page, the address of the page that linked to it (referrer), your browser’s user agent (browser, operating system and device type) and technical timing data of the page load (for example how fast the page appeared). Cloudflare also receives your IP address with the request and uses it to find your country. The script does not set cookies and does not store anything on your device. Cloudflare says that it does not use this data to identify or follow you, also not by fingerprinting. We see only aggregated numbers, for example visits and page views per page, referring websites, countries, device types, browsers and page load times. We cannot see single visitors. Cloudflare keeps the detailed data for 7 days, and after that only a sample of about 10% for the aggregated numbers. Cloudflare acts as our data processor.
• Server statistics: the Cloudflare dashboard also shows aggregated numbers that are made on the server from the requests (hosting, above), for example the number of requests per page. We do not store your IP address for this.
• Legal basis for the statistics: our legitimate interest in understanding how the Website is used and how fast it loads (GDPR Article 6(1)(f)). You can object at any time (section 7). The simplest way: block static.cloudflareinsights.com in your browser, for example with a content blocker. All pages work without the script.
• Cookies: the Website does not set cookies and does not store anything on your device. Therefore it shows no cookie banner. If we add cookies or other technologies that need your consent, we will ask for your consent first.

5. Who receives data

We do not sell your data. We share data only with:

• our data processors listed above (email provider, website host, PostHog), who act only on our instructions and under a data processing agreement;
• Apple, as the distributor of the App, as the provider of your iCloud storage (section 4.5), of App Attest and of our iCloud storage for the activity logs that you send (section 4.6), under Apple’s own privacy policy;
• authorities, only if the law requires it. Even then, we cannot give anyone the content of your vault, because we do not have it and cannot decrypt it.

6. Transfers outside the EU

Some providers (for example Cloudflare, Google, PostHog and Apple) may process data in the United States or other countries outside the European Economic Area. When this happens, the transfer is protected by an adequacy decision of the European Commission (such as the EU‑U.S. Data Privacy Framework, for certified companies) or by Standard Contractual Clauses approved by the European Commission. You can ask us for a copy of these safeguards.

7. Your rights

Under the GDPR you have the right to:

• access your personal data and get a copy (Article 15);
• correct inaccurate data (Article 16);
• delete your data (Article 17);
• restrict processing (Article 18);
• data portability (Article 20);
• object to processing based on our legitimate interest (Article 21);
• withdraw consent at any time, where we rely on consent (Article 7(3)).

To use your rights, email support@vault9app.com. We answer within one month. For crash reports from Apple, we usually cannot find data about you, because we cannot link them to you (GDPR Article 11). The same holds for usage statistics: the App does not show the install ID, and we cannot link it to you. To stop them, use the switch in Settings.

You can also complain to a supervisory authority. In Hungary this is:

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
Address: 1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address: 1363 Budapest, Pf. 9.
Website: https://naih.hu
Email: ugyfelszolgalat@naih.hu

You can also complain to the authority in your EU country of residence, or go to court.

8. Security

We protect the data we process with appropriate technical and organisational measures. The App itself encrypts your vault on your device with AES‑256‑GCM, with keys derived from your unlock secret and your Secret Key. Our security design is described at https://vault9app.com/how-it-works.

9. Children

The App is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has sent us personal data, contact us and we will delete it.

10. No automated decisions

We do not make decisions about you based solely on automated processing, and we do not create profiles of you.

11. Changes to this Privacy Policy

We may update this Privacy Policy, for example when we add a feature or a provider. We show the new effective date at the top. For important changes we inform you in the App before they apply. If a change needs your consent, we ask for it.

12. Contact

Sinóros-Szabó Péter EV.
Email for privacy questions: support@vault9app.com
Address, phone, registration and tax numbers: see section 16 of the Terms of Use, https://vault9app.com/terms/#16-service-provider-and-contact