Privacy policy

1. Scope, Operator Identity & Definitions

This Privacy Policy (“Policy”) explains how TengrX (“TengrX,” “we,” “us,” or “our”), the developer and operator of Octoshield, handles information in connection with:

• The Octoshield iOS Application (“App”): The mobile application distributed via the Apple App Store for iPhone and iOS devices, including its encrypted Photo & File Vault and Swipe-to-Clean photo organizer; and
• The Octoshield Website (“Website”): The public website located at https://octoshield.app, including its interactive product demonstrations, educational guides, comparisons, and client-side browser privacy tools (/tools).

Together, the App and the Website are referred to as the “Services.” For the purposes of applicable global data protection legislation—including the European Union General Data Protection Regulation (Regulation (EU) 2016/679, “EU GDPR”), the United Kingdom General Data Protection Regulation and Data Protection Act 2018 (“UK GDPR”), the Swiss Federal Act on Data Protection (“FADP”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), the Law on the Protection of Personal Data No. 6698 of the Republic of Türkiye (“KVKK”), the Brazilian General Data Protection Law No. 13.709/2018 (“LGPD”), and Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”)—TengrX acts as the data controller (or “business” / “veri sorumlusu”) Solely with respect to the limited, de-identified technical data described in this Policy. With respect to the private photos, videos, and documents you store or organize locally on your device, you remain the sole custodian and controller on your personal hardware.

2. What We Never Collect (Zero-Knowledge Architecture)

Octoshield is engineered so that we cannot access your private life even if we wanted to. Specifically, neither Octoshield nor TengrX ever collects, transmits, stores, or has access to:

• No User Accounts or Personal Identifiers: You never create an account, register an email address, provide a phone number, or sign in with Apple, Google, or social media to use Octoshield.
• No Vault Media, Documents, or Metadata: We never upload, view, scan, hash, or transmit the photos, videos, Live Photos, PDFs, ID scans, or arbitrary files you import into your vault or review in Cleaner. We never see your filenames, folder names, EXIF/GPS camera metadata, or thumbnail previews.
• No Unlock Secrets or Cryptographic Keys: We never receive, log, or escrow your vault PIN, alphanumeric passphrase, 3×3 pattern, rotary safe combination dial values, PBKDF2-SHA256 stretched keys, HKDF-SHA256 derived keys, or your device-bound iOS Keychain material.
• No Biometric Templates: We never access raw Face ID facial geometry or Touch ID fingerprint data.
• No Advertising Identifiers or Cross-App Tracking: We never access Apple’s Identifier for Advertisers (IDFA), never embed third-party ad networks, and never track your activity across other companies’ apps or websites.
• No Exact Geolocation or Contacts: We never request access to your iOS GPS location services, Contacts address book, Microphone, or HealthKit data.

3. Apple App Store Privacy Matrix (“Nutrition Label”)

In compliance with Apple App Store Review Guideline 5.1.1 and Apple’s App Privacy transparency standards, the table below maps every data category associated with the App and Website, whether it leaves your device, whether it is linked to your identity, and its legal basis:

4. Anonymous Product Analytics (Mixpanel Disclosure)

To understand whether features are working reliably, identify crashes or UI bottlenecks, and improve the product without compromising user privacy, we use Mixpanel (provided by Mixpanel, Inc.) strictly for anonymous, non-identifiable aggregate analytics.

4.1 What Anonymous Telemetry Includes

• High-Level Interaction Events: Aggregate, non-content application lifecycle events (for example, that the app was launched, an onboarding step was completed, or a high-level feature module such as Cleaner or Vault was opened).
• Technical & Diagnostic Context: App version number, iOS operating system version, general device model class (e.g., iPhone model family), screen dimensions, system language/locale code, and country/region derived transiently at the network edge without storing persistent personal IP profiles.

4.2 What Is Explicitly Excluded from Mixpanel

• Zero filenames, file extensions, photo/video contents, thumbnails, or EXIF metadata are ever included in any analytics payload.
• Zero PIN digits, passphrase characters, pattern coordinates, rotary dial numbers, or cryptographic parameters are ever logged.
• Zero cross-app identifiers (IDFA), third-party advertising cookies, email addresses, or personal user profiles are created or enriched.

4.3 Processor Governance

Mixpanel, Inc. acts strictly as our bound data processor / service provider and is contractually prohibited from selling, retaining, using, or disclosing de-identified telemetry for any purpose other than providing aggregate analytics to TengrX. You can review Mixpanel’s security and privacy practices in the Mixpanel Privacy Policy ↗.

Website App Store click analytics

On this website, we measure clicks on links to Octoshield’s App Store listing using Supabase. Each event records the server time, page path, link placement, referring domain, device category, and campaign tags (utm_source, utm_medium, utm_campaign) present on the current page. We do not send the full page URL, referrer path, IP address, or browser user-agent in the stored event, and we do not set analytics cookies or persistent visitor identifiers. Our hosting and database providers may process connection metadata to operate their services.

We use these events to understand which pages and campaigns lead to App Store visits. They do not tell us whether you install the app. The website respects browser Do Not Track and Global Privacy Control signals for this measurement. Access to event data is restricted to authorized administrators. This website measurement is separate from the app telemetry described above.

5. On-Device Encryption, Keychain & Biometrics

All sensitive operations in Octoshield happen exclusively on your iPhone’s local processor and storage:

• Cryptographic Storage: Imported photos, videos, documents, preview thumbnails, and the vault catalog index are encrypted at rest inside the App’s local iOS container using AES-256-GCM authenticated encryption in 512 KB chunks. Per-item keys are derived from a random 256-bit master key using HKDF-SHA256.
• Hardware Keychain Binding: Your chosen secret (PIN, passphrase, 3×3 pattern, or combination dial) is stretched via PBKDF2-SHA256 and combined with a random device-bound key stored in the iPhone’s hardware-backed iOS Keychain using non-migrating device-only accessibility attributes.
• Biometric Unlock (Face ID / Touch ID): If you enable optional biometric unlock, authentication is performed entirely by iOS via Apple’s LocalAuthentication framework and Secure Enclave hardware. The App receives only a boolean cryptographic key release from the iOS Keychain upon successful verification; it never accesses, sees, or stores biometric images, facial depth maps, or fingerprint templates. If your device’s biometric enrollment changes, the biometric Keychain slot is automatically invalidated for your protection.
• Ephemeral Previews & Exports: Videos stream through an in-memory decryptor. Certain document formats require a temporary decrypted scratch file for native iOS rendering; the App automatically overwrites/deletes scratch files when the preview closes or the vault locks. If you choose to export or share an item outside Octoshield, the exported copy leaves vault protection and is governed by the destination app or service you select.

6. iOS Permissions (Photos, Files, Camera & iCloud)

Octoshield requests iOS system permissions only when needed to perform an action you initiate:

• Photo Library Access: The Cleaner module requests Photo Library permission so it can display your camera-roll cards locally, record which cards you chose to keep, and request deletion of queued items via Apple’s official PhotoKit confirmation sheet. For direct vault imports, you may also use Apple’s system photo picker (PHPickerViewController), which grants the App access only to the specific photos or videos you select.
• Files & Document Picker: Importing PDFs or documents uses iOS’s native document picker. Importing creates an independent encrypted copy inside the vault and does not alter or delete the source file in the iOS Files app unless you remove the source yourself.
• iCloud Photos Interaction: Octoshield does not connect to iCloud to back up your vault. However, if you use Apple’s Optimize iPhone Storage setting, iOS itself may download the full-resolution original of a photo or video from your iCloud Photos library to your iPhone when you view or import it in Octoshield.
• Revoking Permissions: You can modify or revoke Photo Library or Face ID permissions at any time in iOS Settings → Apps → Octoshield. Revoking Photo Library access does not affect files already encrypted inside your local vault.

7. Apple App Store, StoreKit & Purchases

The App is distributed exclusively through the Apple App Store. Any in-app purchases, premium upgrades, or subscriptions (if offered now or in future versions) are processed directly by Apple Inc. through Apple’s StoreKit framework using your Apple Account:

• TengrX never receives, processes, or stores your credit card numbers, bank account details, billing address, or Apple Account password.
• The App verifies purchase entitlements locally on your device using Apple’s cryptographically signed StoreKit transaction receipts.
• Apple’s processing of your download and payment data is governed by the Apple Privacy Policy ↗.

8. Website, Client-Side Browser Tools & Cookies

• 100% Client-Side Browser Privacy Tools: All interactive utilities hosted under octoshield.app/tools(including the Photo EXIF Metadata Remover, Face & License Plate Blur Tool, Passport Photo Maker, Passphrase Entropy Calculator, Private QR Generator, and Image Resizer/Compressor/Format Converters) execute entirely inside your web browser’s local memory using standard HTML5 Canvas, FileReader, and Web Crypto APIs. Files selected in these tools are never uploaded to any TengrX server.
• Interactive App Preview: The interactive phone demo on the Website uses pre-loaded sample illustrations and simulated UI states. Any PIN, pattern, dial, or passphrase entered into the Website’s demo is discarded in browser memory and never stored.
• No Advertising Cookies & GPC Compliance: We do not use third-party advertising cookies, retargeting pixels, or cross-site tracking beacons. Our Website honors Global Privacy Control (GPC) and browser Do Not Track (DNT) signals by default.
• Standard Web Hosting & Security Logs: Like all internet websites, our web hosting and Content Delivery Network (CDN) infrastructure automatically processes standard HTTP request metadata—such as your IP address, browser user-agent string, referring URL, and timestamp—strictly as necessary to deliver static assets, mitigate Distributed Denial of Service (DDoS) attacks, and maintain infrastructure security.

9. Data Retention, Backup Exclusion & Deletion

• On-Device Vault Retention: Your encrypted vault files, thumbnails, catalog index, and local preferences remain on your iPhone solely under your control until you delete individual items inside the App, trigger the optional Erase After 10 Failed Attempts security rule, or uninstall the App from your iPhone.
• Strict Exclusion from Backups: Octoshield configures its vault storage directory with iOS’s isExcludedFromBackup resource attribute and binds its encryption keys to device-only Keychain items. Vault contents are not copied to iCloud Backup, iCloud Drive, or Finder/iTunes computer backups.
• Permanent Deletion: Deleting an item from inside your Octoshield vault immediately removes its encrypted chunks, thumbnail, and index entry from local app storage. Uninstalling the App causes iOS to purge the entire local app sandbox. Because we operate no cloud server, deleted vault items cannot be recovered.
• Anonymous Telemetry Retention: De-identified, aggregate analytical events processed via Mixpanel contain no personally identifiable information and are retained only for as long as necessary to analyze historical product stability and version performance, after which they are automatically aggregated or purged in accordance with our processor retention schedules.

10. International Data Transfers & Safeguards

Your local vault files never leave your physical iPhone and therefore never undergo any cross-border transfer. With respect to the limited, de-identified technical telemetry processed by Mixpanel and standard web delivery requests processed by our global CDN infrastructure, such technical data may be processed on servers located in the United States, the European Economic Area (EEA), or other countries depending on network routing.

Where applicable data protection laws (including the EU GDPR, UK GDPR, Swiss FADP, Turkish KVKK, or Brazilian LGPD) regulate cross-border transfers of technical data, we ensure appropriate safeguards are in place, including:

• Strict technical de-identification and data minimization prior to transmission so that telemetry payloads cannot identify a natural person;
• The European Commission’s Standard Contractual Clauses (SCCs) (Commission Implementing Decision (EU) 2021/914), the UK International Data Transfer Addendum (IDTA), and Swiss FADP adequacy adjustments incorporated into our processor agreements; and
• Reliance on certified adequacy frameworks where applicable, such as the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF for certified U.S. service providers.

11. EEA, United Kingdom & Switzerland (GDPR / UK GDPR / FADP)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the following additional disclosures apply:

11.1 Legal Bases for Processing (GDPR Art. 6)

• Performance of a Contract (Art. 6(1)(b) GDPR): Providing the local App software, StoreKit entitlement checks, and Website tools you request.
• Legitimate Interests (Art. 6(1)(f) GDPR): Processing strictly de-identified, non-intrusive aggregate telemetry to detect crashes and maintain software reliability, as well as securing our Website against malicious network traffic. Our legitimate interest assessment confirms that this processing poses no risk to your fundamental rights and freedoms because no personal identifiers or private content are collected.
• Consent (Art. 6(1)(a) GDPR): Where you explicitly grant OS-level permissions (such as Photo Library access or Face ID) via native iOS prompts, which you may withdraw at any time in iOS Settings.

11.2 GDPR Article 11 Notice (Processing Which Does Not Require Identification)

Under Article 11 of the GDPR, where the purposes for which a controller processes data do not or no longer require the identification of a data subject by the controller, the controller is not obliged to maintain, acquire, or process additional information in order to identify the data subject for the sole purpose of complying with GDPR rights requests. Because TengrX operates no user accounts and collects no names, email addresses, or device serial numbers, we cannot associate any local vault or anonymous telemetry event with an identified individual unless you voluntarily provide verifiable technical context.

11.3 Your Statutory Data Subject Rights (GDPR Arts. 15–22)

Subject to Article 11 GDPR and applicable law, you have the right to: (a) request access to any personal data we hold about you; (b) request rectification of inaccurate data; (c) request erasure (“right to be forgotten”); (d) request restriction of processing; (e) request data portability; and (f) object to processing based on legitimate interests. Because all vault data resides on your iPhone, you can exercise immediate and total access, portability (via Export), and erasure (via Vault Delete or uninstalling the App) directly on your device at any time. You also have the right to lodge a complaint with your local supervisory authority (such as an EU Data Protection Authority, the UK Information Commissioner’s Office (ICO), or the Swiss Federal Data Protection and Information Commissioner (FDPIC)).

12. United States Privacy Rights (CCPA/CPRA & US State Laws)

This section provides mandatory disclosures for residents of California (under the CCPA/CPRA, Cal. Civ. Code § 1798.100 et seq.), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPA), Oregon (OCPA), Montana, Delaware, Iowa, New Jersey, Tennessee, Indiana, and all other U.S. states with comprehensive consumer privacy laws:

• No Sale or Sharing of Personal Information: TengrX does not sell your personal information (as “sell” is defined under CCPA/CPRA and state laws) and does not share your personal information for cross-context behavioral advertising. We have not sold or shared any personal information in the preceding twelve (12) months.
• Sensitive Personal Information: We do not collect, infer, or process “Sensitive Personal Information” on our servers. All private photos, documents, unlock secrets, and biometric checks remain strictly on your local iPhone under your sole control.
• De-identified Information Commitment: To the extent we process de-identified telemetry via Mixpanel, we maintain and use such information strictly in de-identified form and will never attempt to re-identify the information.
• Your U.S. State Privacy Rights: Depending on your state of residence, you have the right to: (1) know/confirm whether we process your personal information and access it; (2) request deletion of personal information; (3) request correction of inaccurate personal information; (4) opt out of the sale, sharing, or targeted advertising of personal information (which we do not engage in); and (5) be free from unlawful discrimination or retaliation for exercising your privacy rights.
• California “Shine the Light” (Cal. Civ. Code § 1798.83): We never disclose personal information to third parties for their direct marketing purposes.

13. Global Regional Disclosures (KVKK, LGPD, PIPEDA, APAC & RoW)

In addition to EEA/UK and U.S. laws, Octoshield is designed to comply with privacy and data protection statutes across all countries and regions where the App Store operates:

14. Children’s Privacy (COPPA, GDPR-K & Global Standards)

The Services are general-audience utilities and are not directed to children under the age of 13 (or under the age of 16 in the EEA, UK, or other jurisdictions with a higher digital age of consent). In compliance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), GDPR Article 8, and equivalent global minor protection laws, we do not knowingly collect, solicit, or store any personal information from children. Because Octoshield does not feature user registration, chat, or personal data collection, no personal profile of any child is ever created. If you are a parent or guardian and believe a child has voluntarily submitted personal information to us via a support inquiry, please contact us so we can promptly delete that communication.

15. Law Enforcement Requests & Technical Impossibility

16. Policy Updates, Language & Contact Information

Changes to This Policy:We may update this Privacy Policy from time to time to reflect changes in our App features, Website tools, or global legal requirements. When we make material updates, we will revise the “Effective & Last Updated” date at the top of this page. Your continued use of the App or Website following any update constitutes acknowledgment of the updated Policy.

Governing Language: This Policy is drafted in English. If this Policy is translated into any other language for convenience, the English version shall prevail to the maximum extent permitted by applicable local law.

Contacting the Developer / Data Protection Inquiries: If you have any questions about this Privacy Policy, our anonymous Mixpanel telemetry, or your statutory privacy rights in your country or state, you may contact TengrX through:

• Developer Studio Website: https://tengrx.com ↗
• Apple App Store Support Channel: The official App Support / Developer Contact link on the Octoshield App Store listing ↗