> For the complete documentation index, see [llms.txt](https://cullshot.gitbook.io/cullix/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://cullshot.gitbook.io/cullix/reference/privacy-policy.md). # Privacy Policy Last updated: November 12, 2026 Cullshot is built so that your photos and data never leave your device. This policy describes what the app processes. ## Controller Manfred Prinz c/o MDC#2355 Welserstraße 3 87463 Dietmannsried Germany Phone: +43 670 4015040 Email: ## In short * Cullshot **does not collect personal data** and **sends no data** to the developer or to third parties. * There is **no tracking**, no advertising, and no analytics or crash-reporting services. * Your photos are **never uploaded**. The AI analysis runs entirely on your device. * The app needs **no internet connection** for its features. ## What Cullshot processes on your device ### Photos and folders Cullshot reads photos from folders you choose yourself (for example from a memory card) and, on iPad, from the Photos library if you wish. You grant access explicitly through the system dialogs of macOS or iPadOS. Photos are only displayed and analyzed; originals are not modified. Exceptions that you trigger yourself: * **Move Rejects to Trash:** moves rejected images to the Trash after confirmation. * **Share selection:** creates copies of your photos with embedded ratings at the location you choose, or hands them to the app you choose (for example Lightroom or Apple Photos). From the handoff on, that app's privacy policy applies. ### Ratings Cullshot stores stars, picks, rejects and color labels in XMP files next to your images (on iPad, for Photos library items, in a file of the app). These files stay on your device or wherever your photos are stored. ### AI analysis Sharpness, eyes, exposure, series and visual impact are calculated **locally** using Apple's image analysis functions (Vision). Cullshot stores the results in a cache in the app's directory on your device. No image data or results are transmitted. ### Settings The app stores settings, view options and the list of opened folders (as a system access bookmark) locally on your device. Cullshot also reads file timestamps (capture and modification dates) of your photos to group and sort them by day. ## Subscription to Cullshot Pro Cullshot Pro is an auto-renewing subscription (monthly or yearly) with a 7-day free trial, processed entirely by Apple (App Store). The app checks on your device, via Apple's StoreKit, whether a subscription or the trial is active; no data is sent to me for this. I do not receive any payment data. Apple's privacy policy applies. ## Sharing with third parties No data is shared with third parties, because no data is collected. ## Retention and deletion All data resides on your device and under your control. Deleting the app removes the settings and the analysis cache. You delete XMP files next to your photos in the Finder or the Files app. ## Your rights Since I do not process personal data about you, I cannot assign any data to you for access, correction or deletion. For questions or concerns about privacy you can reach me at the address above. You also have the right to lodge a complaint with a data protection supervisory authority. ## Changes If the app changes so that it processes data not listed here, I will update this policy beforehand. The date above shows the current version. ## Contact Manfred Prinz, c/o MDC#2355, Welserstraße 3, 87463 Dietmannsried, Germany, Phone: +43 670 4015040, Email: --- # Agent Instructions This documentation is published with GitBook. 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