Name: AXIFY
Author: Narelio

1. Introduction

Welcome to AXIFY ("App"). AXIFY is a sports motion analysis application developed and operated by Narelio, a sole proprietorship based in Japan ("Developer," "we," "us," or "our").

We are committed to protecting your privacy and ensuring full transparency about how your information is handled. This Privacy Policy explains what data the App collects, how it is used, and your rights under applicable data protection laws, including:

General Data Protection Regulation (GDPR) — European Union
UK General Data Protection Regulation (UK GDPR) — United Kingdom
California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) — California, USA
Act on the Protection of Personal Information (APPI / 個人情報保護法) — Japan

By using AXIFY, you acknowledge and agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the App.

2. On-Device AI Processing — Your Videos Never Leave Your Device

This is the cornerstone of AXIFY's privacy design.

AXIFY uses Apple's built-in Vision framework to perform human body pose estimation and motion analysis. This processing occurs entirely on your device using Apple's Neural Engine and local hardware. Specifically:

No videos or photos are uploaded to any external server, cloud service, or third-party AI provider.
No pose data, skeleton data, or joint measurements are transmitted outside your device.
No cloud-based AI APIs (e.g., Google Cloud Vision, AWS Rekognition, OpenAI) are used.
All angle measurements, pose overlays, and analysis results are computed and stored locally on your device.

Your media files remain under your sole control at all times. This is not a policy choice — it is an architectural guarantee built into the App's code.

3. Information We Collect

3.1 Information You Provide Directly

Projects — Project names, tags, and creation dates. Stored on-device (SwiftData) and in iCloud (if enabled).

Videos — Video files imported from your Photo Library or Files app. Stored in the on-device Documents directory and iCloud Documents (if enabled).

Annotations — Drawings, lines, angles, and text overlays you create on videos. Stored on-device (SwiftData) and in iCloud (if enabled).

Preferences — App language, haptic feedback setting, video layout preference, selected sport, and skill level. Stored on-device (UserDefaults).

3.2 Information Collected Automatically

Anonymous Usage Analytics — Anonymized, aggregated product events (e.g., features used, screens viewed). See Section 4.1 for details. Purpose: Product improvement and understanding feature adoption. Legal basis: Legitimate Interest (GDPR Art. 6(1)(f)) / Anonymized data.

Crash & Performance Data — Crash reports, performance traces, app hang detection, and diagnostic data. See Section 4.2 for details. Purpose: Identifying and fixing software defects, ensuring app stability. Legal basis: Legitimate Interest (GDPR Art. 6(1)(f)).

Subscription Status — Whether you are a free or Pro subscriber. Managed by RevenueCat to unlock features. Legal basis: Contract Performance (GDPR Art. 6(1)(b)).

Purchase Events — Transaction records for in-app purchases. Processed by Apple App Store and RevenueCat. Legal basis: Contract Performance (GDPR Art. 6(1)(b)).

Video Metadata — Technical properties of imported videos (resolution, frame rate, duration). Extracted locally for display and analysis purposes only. Not transmitted externally.

3.3 Information We Do NOT Collect

We explicitly do not collect:

Your name, email address, phone number, or any contact information
Location data or GPS coordinates
Health or biometric data
Advertising identifiers (IDFA) or vendor identifiers (IDFV)
Browsing history or activity on other apps
Video content, photos, or any user-created media
Pose estimation results, skeleton data, or joint angle measurements
Any data that could directly identify you as an individual

4. Third-Party Services

AXIFY integrates with the following services. Below is an exhaustive and transparent list of every third-party SDK included in the App:

4.1 TelemetryDeck — Anonymous Product Analytics

Purpose: Understanding how features are used to improve the App. TelemetryDeck is a privacy-first analytics service that does not track individual users.
Data Processing Location: European Union (Germany)
Data Collected: Anonymized event signals such as feature usage (e.g., "skeleton enabled," "export completed"), aggregated numeric values (e.g., average video duration), and technical context automatically collected by the SDK:
App version and build number
Operating system name and version
Device model category (e.g., "iPhone," "Mac")
System locale and region
Connection type (Wi-Fi or cellular)
Display settings (dark mode, accessibility features)
Platform (iOS/macOS)
How Anonymization Works: TelemetryDeck uses a cryptographic hash to generate anonymous session identifiers. These hashes cannot be reversed to identify individual users. No IP addresses are stored. No persistent user profile is created. TelemetryDeck's architecture is designed so that neither we nor TelemetryDeck can identify individual users.
Custom Parameters Sent: Subscription status (free/Pro), selected sport category, skill level, onboarding completion status. These are sent as aggregated, anonymous values and cannot be linked to any individual.
Data NOT Collected by TelemetryDeck: IP addresses, device identifiers (IDFA/IDFV), email addresses, names, location data, or any user-created content.
Your Control: Analytics events are automatically excluded in development/debug builds. TelemetryDeck does not offer an opt-out mechanism because no personal data is collected — all data is anonymized before transmission.
Privacy Policy: https://telemetrydeck.com/privacy/
GDPR Status: TelemetryDeck processes only anonymized data. Under GDPR Recital 26, anonymized data falls outside the scope of the regulation. Nevertheless, we disclose this processing for full transparency.

4.2 Sentry — Crash Monitoring & Performance

Purpose: Detecting, diagnosing, and fixing crashes, errors, and performance issues to maintain app quality and stability.
Data Processing Location: European Union (Germany) — *.ingest.de.sentry.io
Data Collected:
Crash Reports: Stack traces, error messages, exception types, and thread states at the time of a crash or error.
Performance Data: Transaction traces and response times for app operations.
Device Context: Operating system version, device model, available memory, battery state, and CPU architecture.
App State: Whether the app was in foreground or background, current active feature, subscription tier (free/Pro).
Breadcrumbs: A sequence of recent user interactions and navigation events leading up to a crash (e.g., "opened player," "started export"). These are functional descriptions, not screen recordings.
App Hangs: Detection of UI thread freezes exceeding 2 seconds.
MetricKit Data: Apple-provided diagnostic and performance metrics.
Anonymous Installation ID: A random identifier generated by Sentry on first launch, used solely to correlate crashes from the same device installation. This ID cannot be linked to your Apple ID, name, or any personal account.
Session Replay (on error only): When a crash or error occurs, a short visual replay of the app state may be captured. All text and all images are fully masked — the replay shows only the layout structure, not your content.
Screenshots & View Hierarchy (on crash): A screenshot of the app's UI state and its view structure may be captured at the moment of a crash. These use privacy-safe defaults and do not capture your video content or personal data.
Data NOT Collected by Sentry: Email addresses, usernames, IP addresses (stripped by sendDefaultPii = false), video content, photos, annotations, pose data, or any user-created content.
Privacy Measures:
sendDefaultPii is set to false — no personally identifiable information is sent by default.
Email and username fields are explicitly stripped before transmission via a beforeSend hook.
Session Replay masks all text and all images.
Data Retention: Sentry retains crash and performance data for 90 days by default. We do not extend this period.
Legal Basis: Legitimate Interest (GDPR Art. 6(1)(f)) — maintaining software quality and resolving crashes is necessary for providing a reliable service. You may object to this processing by contacting us (see Section 15).
Privacy Policy: https://sentry.io/privacy/
Data Processing Agreement (DPA): We maintain a Data Processing Agreement with Functional Software, Inc. (Sentry) in accordance with GDPR Art. 28.

4.3 RevenueCat — Subscription Management

Purpose: In-app subscription and purchase management.
Data Processing Location: United States
Data Shared: Anonymous app user ID (generated by RevenueCat), purchase events, subscription status, entitlement information, and transaction identifiers.
Data NOT Shared: Videos, photos, annotations, pose data, or any user-created content.
Legal Basis: Contract Performance (GDPR Art. 6(1)(b)) — processing subscription data is necessary to fulfill the service you purchased.
Data Retention: RevenueCat retains purchase records in accordance with their privacy policy and applicable legal requirements (including tax and accounting obligations).
Privacy Policy: https://www.revenuecat.com/privacy
Data Processing Agreement (DPA): We maintain a Data Processing Agreement with RevenueCat, Inc. in accordance with GDPR Art. 28.

4.4 Apple iCloud (CloudKit)

Purpose: Optional synchronization of your projects, video metadata, annotations, and video files across your Apple devices.
Data Synced: Project metadata, video metadata, annotations, and video files (to your personal iCloud account only).
Control: iCloud sync is controlled entirely by your device's system settings. You can disable it at any time via Settings > [Your Name] > iCloud > AXIFY.
Privacy Policy: https://www.apple.com/legal/privacy/

4.5 Apple App Store

Purpose: Payment processing for in-app subscriptions.
Data: All payment information (credit card, billing address) is handled exclusively by Apple. We never receive or store your payment details.

We do not integrate any advertising networks, social media SDKs, or user tracking services.

5. How We Use Your Information

We use the data described above for the following purposes only:

Providing Core Functionality — Storing your projects, videos, and annotations so you can analyze sports motion.
Subscription Management — Verifying your subscription status to enable Pro features.
iCloud Synchronization — Syncing your content across your Apple devices (if you have enabled iCloud for AXIFY).
Handoff / Continuity — Allowing you to continue viewing a video on another Apple device using Apple's encrypted Handoff protocol.
Product Improvement — Understanding how features are used (via anonymized TelemetryDeck analytics) to prioritize development and improve the user experience.
Stability & Quality — Identifying and fixing crashes, errors, and performance issues (via Sentry) to ensure the App works reliably.

We do not use your data for:

Advertising or ad targeting
User profiling or behavioral tracking
Automated decision-making
Sale to third parties
Any purpose beyond those listed above

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to any third party.

Your data may only be shared in the following limited circumstances:

With TelemetryDeck — Anonymized usage analytics, as described in Section 4.1. This data cannot identify you.
With Sentry — Crash reports and performance data, as described in Section 4.2. This data contains no personally identifiable information.
With RevenueCat — Anonymous purchase and subscription data, as described in Section 4.3.
With Apple — Via iCloud sync (your personal iCloud account) and App Store payment processing.
With Other Users — Only if you explicitly choose to share a project using the App's sharing feature (powered by CloudKit). You control who receives shared projects.
Legal Obligations — If required by law, court order, or governmental regulation, we may disclose information to comply with legal obligations.

7. Cross-Border Data Transfers

As a service operated from Japan, your data may be transferred to and processed in the following jurisdictions:

TelemetryDeck — Processing location: Germany (EU). Transfer mechanism: Anonymized data — GDPR scope does not apply. Japan has EU adequacy decision.

Sentry — Processing location: Germany (EU). Transfer mechanism: Japan-EU adequacy decision (GDPR Art. 45). APPI Art. 28 compliance via equivalent protection.

RevenueCat — Processing location: United States. Transfer mechanism: Standard Contractual Clauses (SCCs) as provided by RevenueCat. APPI Art. 28 compliance via contractual safeguards.

Apple iCloud — Processing location: User's iCloud region. Transfer mechanism: Managed by Apple under Apple's privacy policy and applicable transfer mechanisms.

For users in the EU/EEA/UK: The European Commission has recognized Japan as providing an adequate level of data protection (Adequacy Decision of January 23, 2019). Data transfers between Japan and the EU/EEA are therefore permitted under GDPR Art. 45.

For users in Japan: Cross-border transfers to the EU (Sentry, TelemetryDeck) are conducted under APPI's framework recognizing the EU as a jurisdiction with equivalent data protection standards. Transfers to the US (RevenueCat) are conducted with appropriate contractual safeguards in compliance with APPI Article 28.

8. Data Retention

On-Device Data (projects, videos, annotations, preferences) — Retained until you delete them or uninstall the App. You can delete data within the App or by uninstalling.

iCloud Data — Retained per your iCloud storage settings and Apple's policies. You can delete this data via iCloud settings on your device.

TelemetryDeck Analytics — Anonymized data with no personal data to delete. Data cannot be linked to you.

Sentry Crash Data — Retained for 90 days from collection. Contact us to request early deletion.

RevenueCat Subscription Data — Retained per RevenueCat's retention policy and applicable legal requirements. Contact RevenueCat or us to inquire.

Apple App Store Purchase Records — Retained per Apple's policies and tax/legal obligations. Contact Apple for details.

9. Data Security

We implement the following security measures:

On-Device Storage: All data is stored using Apple's SwiftData framework with iOS/macOS-level encryption (Data Protection).
Encrypted Transit: All communications with TelemetryDeck, Sentry, RevenueCat, and iCloud use TLS (Transport Layer Security) encryption.
No External Servers: We do not operate our own backend servers that store your data. Your content lives on your device and, optionally, in your personal iCloud account.
No Credentials Stored: We do not store passwords or authentication credentials. Subscription authentication is handled entirely by Apple.
Sentry Privacy Defaults: Personally identifiable information is not sent (sendDefaultPii = false). Session Replay fully masks all text and images. Email and username fields are explicitly stripped before transmission.
TelemetryDeck Anonymization: All data is cryptographically hashed before transmission. No IP addresses are stored.

10. Your Rights Under GDPR (European Economic Area) and UK GDPR (United Kingdom)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you have the following rights:

Access (Art. 15) — You may request a copy of the personal data we hold about you.
Rectification (Art. 16) — You may request correction of inaccurate personal data.
Erasure (Art. 17) — You may request deletion of your personal data ("right to be forgotten").
Restriction (Art. 18) — You may request restriction of processing of your personal data.
Portability (Art. 20) — You may request your data in a structured, machine-readable format.
Objection (Art. 21) — You may object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds.
Withdraw Consent (Art. 7) — Where processing is based on consent, you may withdraw consent at any time.

Legal Bases for Processing

Subscription management (RevenueCat) — Legal basis: Contract Performance (Art. 6(1)(b)). Necessary to provide the subscription service you purchased.

Crash monitoring (Sentry) — Legal basis: Legitimate Interest (Art. 6(1)(f)). Necessary to maintain software quality and fix defects. Balanced against your rights — we collect minimal data with privacy safeguards.

Anonymous analytics (TelemetryDeck) — Legal basis: Not applicable (anonymized data). Anonymized data falls outside GDPR scope per Recital 26. Disclosed for transparency.

iCloud synchronization — Legal basis: Consent (Art. 6(1)(a)). You choose to enable iCloud sync via system settings.

Data Controller

Narelio A sole proprietorship based in Japan Email: support@narelio.com

The identity of the operator will be disclosed upon legitimate request in accordance with applicable law.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For EEA residents, you may contact your local Data Protection Authority. For UK residents, you may contact the Information Commissioner's Office (ICO) at https://ico.org.uk/.

To exercise any of these rights, please contact us using the information in Section 15. We will respond within 30 days (or one calendar month under UK GDPR).

11. Your Rights Under CCPA/CPRA (California, USA)

If you are a California resident, you have the following rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
Right to Delete: You may request deletion of personal information we have collected.
Right to Correct: You may request correction of inaccurate personal information.
Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising. There is no need to opt out.
Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined by the CPRA.
Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA/CPRA rights.

Categories of Personal Information Collected:

Identifiers — Not collected. We do not collect names, email addresses, or account identifiers.
Commercial Information — Collected (limited). Purchase/subscription records via RevenueCat.
Internet or Network Activity — Collected (limited). Anonymized app usage analytics via TelemetryDeck; crash/performance data via Sentry.
Geolocation — Not collected.
Biometric Information — Not collected.
Sensory Data — Not collected. Videos are processed and stored on-device only.
Professional/Employment Information — Not collected.
Education Information — Not collected.
Inferences — Not collected.

We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

To exercise your CCPA/CPRA rights, please contact us using the information in Section 15.

12. Your Rights Under APPI (Japan / 個人情報保護法)

If you are located in Japan, your personal information is protected under the Act on the Protection of Personal Information (個人情報の保護に関する法律). You have the right to:

Request Disclosure (開示請求) of the purpose of use and content of your retained personal data.
Request Correction (訂正請求) of inaccurate personal data.
Request Cessation of Use (利用停止請求) if your data is being handled in violation of the APPI.
Request Cessation of Provision to Third Parties (第三者提供停止請求).

Personal Information Handling Business Operator (個人情報取扱事業者)

Business Name: Narelio

Contact: support@narelio.com

The name and address of the operator will be disclosed without delay upon request from the data subject, in accordance with APPI Article 32.

Purpose of Use (利用目的)

Providing in-app subscription services and feature access management
Identifying and fixing software crashes and errors (Sentry)
Understanding anonymized product usage patterns for improvement (TelemetryDeck)
Optional iCloud data synchronization across your devices

Cross-Border Transfers (外国にある第三者への提供)

In accordance with APPI Article 28, we disclose the following cross-border data transfers:

Functional Software, Inc. (Sentry) — Country: Germany (EU). Data transferred: Crash reports, performance data. Safeguards: EU jurisdiction with equivalent data protection (EU adequacy recognized under APPI).

RevenueCat, Inc. — Country: United States. Data transferred: Subscription/purchase data. Safeguards: Contractual safeguards (DPA) ensuring equivalent protection under APPI Art. 28.

TelemetryDeck GmbH — Country: Germany (EU). Data transferred: Anonymized analytics only. Safeguards: Anonymized data — no personal information transferred.

Apple Inc. — Country: User's iCloud region / United States. Data transferred: iCloud data, purchase records. Safeguards: Apple's privacy terms and contractual safeguards.

To exercise your rights, please contact us using the information in Section 15.

13. Children's Privacy

AXIFY is not directed at children under the age of 13 (or 16 in the EEA, or the applicable minimum age in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided personal information through the App, please contact us and we will take steps to delete such information promptly.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will:

Update the "Last Updated" date at the top of this document.
For material changes, notify you through an in-app notice or update description on the App Store.

We encourage you to review this Privacy Policy periodically. Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or wish to exercise any of your rights described above, please contact us at:

Narelio

Email: support@narelio.com

Website: https://axify.narelio.com

We will respond to all legitimate requests within 30 days. For complex requests, we may extend this period by an additional 60 days, in which case we will notify you.

This Privacy Policy is provided in both English and Japanese. In the event of a discrepancy, the English version shall prevail.

Privacy Policy