Privacy Policy
This Privacy Policy explains how Trailair ("we", "us", "the app") handles your information when you use our mobile application on iOS. We are committed to data minimisation: we collect only what is strictly necessary to deliver the service, and we do not sell your data for money. This policy is designed to comply with the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and other US state privacy laws. If you are a California or US-state resident, see Section 9 for your specific rights, including the right to opt out of "sale" or "sharing".
1. Data controller
Trailair is operated by an independent developer, who acts as the data controller (as that term is defined by the EU/UK General Data Protection Regulation, GDPR) for any processing described in this policy.
Contact (general): hello@trailair.online
Contact (privacy requests, GDPR Art. 15–22): privacy@trailair.online
The full identity and postal address of the publisher are available on written request to either email above, and are also disclosed to Apple Inc. as part of the App Store distribution agreement.
2. Data we collect
2.1 Stored locally on your device
The following data is stored exclusively on your device using Apple's SwiftData framework. It never leaves your phone and is not transmitted to our servers:
- Your watchlist (films you bookmark)
- Films you mark as already seen, along with optional personal notes and tags
- Actors you choose to follow
- Reading progress on encyclopedia articles, essays, director profiles and analyses
- Quiz high scores
- Recent search queries (last 5, stored in iOS UserDefaults)
- Language, appearance, notification and reader preferences
Uninstalling the app deletes all of this data permanently. You can also clear it from inside the app via Settings → Reset, or export it as JSON via Settings → Privacy & data → Export my data.
2.2 Data transmitted to TMDB
Trailair displays film metadata, posters and trailers retrieved from The Movie Database (TMDB, United States). Requests sent to TMDB include the search terms you type, the film IDs you open and your preferred display language. We do not attach any user identifier to these requests. TMDB's own privacy policy applies to those interactions.
2.3 Data transmitted to OMDb
To enrich film details with Rotten Tomatoes, Metacritic and IMDb ratings, Trailair queries the OMDb API (United States). Each request contains either an IMDb ID or the film title and year. No user identifier is attached. OMDb's terms govern those interactions.
2.4 Data collected for advertising and diagnostics by Google
Trailair displays advertisements via Google AdMob to keep the app free of charge. The Google Mobile Ads SDK and the Google User Messaging Platform (UMP, for EU consent management) may collect:
- Your Apple Advertising Identifier (IDFA), only if you grant App Tracking Transparency permission
- Device information (model, OS version, language, approximate location derived from IP)
- Ad interaction events (impressions, clicks)
- Crash data, performance data and other diagnostic data related to the SDK runtime, used to detect and prevent advertising fraud and improve SDK stability
If you decline tracking when the App Tracking Transparency prompt appears, AdMob serves non-personalised ads and does not access your IDFA. You can revisit your choice at any time inside Trailair via Settings → Privacy & data → Manage ad consent, or system-wide via iOS Settings → Privacy & Security → Tracking.
For full details, see Google's Privacy Policy.
2.5 Apple-provided diagnostics (MetricKit)
Trailair subscribes to Apple's MetricKit framework to receive aggregated crash and performance reports about the app itself. These reports are delivered by Apple to the developer in anonymised form and are only logged locally in debug builds; nothing is forwarded to any third party.
2.6 Notifications
With your permission, Trailair can send you local notifications — reminders to read the daily article and alerts when an actor you follow has a new film. These notifications are scheduled and delivered entirely on your device by iOS; no message content, device token or identifier is sent to us or to any third party. To check for new films from the actors you follow, the app queries TMDB using those actors' identifiers, exactly as described in section 2.2. You can turn notifications on or off at any time in Settings → Notifications inside the app, or system-wide via iOS Settings → Notifications → Trailair. No notification is ever sent unless you grant iOS notification permission.
2.7 Data we explicitly do NOT collect
- No account, no sign-up, no email harvesting
- No precise geolocation
- No contacts, photos, microphone or camera access
- No cross-app or cross-site tracking by Trailair itself
- No analytics SDK other than the ones disclosed above
3. Why we process your data (legal bases under GDPR)
- Performance of the service (Art. 6(1)(b)) — to display films, read editorial content, and save your local preferences and progress.
- Consent (Art. 6(1)(a)) — for personalised advertising via IDFA, only after the UMP consent screen and the iOS App Tracking Transparency prompt.
- Legitimate interest (Art. 6(1)(f)) — to serve non-personalised ads, to detect ad fraud, and to keep recent search history for usability.
4. Sub-processors and recipients
We rely on the following sub-processors. Each transfer is limited to the data described above and to the purposes listed.
| Provider | Role | Country | Data transmitted | Transfer safeguard |
|---|---|---|---|---|
| Google LLC (AdMob, UMP, Mobile Ads SDK) | Advertising and consent management | United States | IDFA (if consented), device info, IP, ad events, SDK diagnostics | EU-US Data Privacy Framework + Standard Contractual Clauses (SCC) |
| The Movie Database (TMDB) | Film metadata, posters, trailers | United States | Search query, film ID, preferred language | Article 49(1)(b) GDPR — necessary for performance of the user's request |
| OMDb API | Ratings (Rotten Tomatoes, Metacritic, IMDb) | United States | IMDb ID or film title + year | Article 49(1)(b) GDPR — necessary for performance of the user's request |
| Apple Inc. | App distribution, App Tracking Transparency, MetricKit, SKAdNetwork postbacks | Worldwide (with EU servers) | Standard App Store telemetry, anonymised diagnostics, ad attribution postbacks | Apple Developer Program data processing terms |
We do not sell or rent your personal data for money. Note that, under US state laws such as the CCPA/CPRA, disclosing your advertising identifier to Google for personalised ads can be treated as a "sale" or "share"; see Section 9.3 for how to opt out.
5. Data retention
- Local data on your device: retained until you delete it from Settings → Reset, or until you uninstall the app.
- Advertising data on Google's side: retention follows Google AdMob's standard schedule (typically up to 13 months for ad-event logs, longer for aggregated reports).
- TMDB and OMDb logs: governed by their respective policies; we do not control them.
- MetricKit diagnostics: handled by Apple under its standard developer telemetry retention.
6. Your rights under GDPR
You have the right to:
- Access the personal data we process about you (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erase your data ("right to be forgotten", Art. 17)
- Restrict or object to processing (Art. 18 and 21)
- Receive your data in a portable, structured format (Art. 20)
- Withdraw consent at any time (Art. 7(3))
- Lodge a complaint with your national supervisory authority
Because most of your data stays on your device, the fastest way to exercise your rights is from inside the app:
- Settings → Reset for erasure (Art. 17)
- Settings → Privacy & data → Export my data for portability (Art. 20)
- Settings → Privacy & data → Manage ad consent to withdraw or update tracking consent (Art. 7(3))
For any other request, email privacy@trailair.online. We respond within 30 days.
You also have the right to lodge a complaint with the data protection or privacy authority of your country of residence. If you are in the European Union or the United Kingdom, you can find your national authority through the European Data Protection Board or the UK ICO; residents of other countries should contact their own local authority.
7. Children
Trailair is rated 12+ on the App Store due to occasional references to mature themes in film synopses. We do not knowingly collect personal data from children under 13. If you believe a child has provided personal data, please contact privacy@trailair.online and we will delete it without undue delay. Where applicable, the Google UMP and ATT prompts are presented before any ad-related identifier is processed; non-personalised ads are served by default for users who do not consent.
8. International data transfers
The sub-processors listed in section 4 are based in the United States. Such transfers are covered by:
- Google AdMob: the EU-US Data Privacy Framework adequacy decision (July 2023) and Google's Standard Contractual Clauses.
- TMDB and OMDb: Article 49(1)(b) of the GDPR — the transfer is necessary for the performance of the contract between you (the user) and us, since you are the one requesting film information.
9. United States privacy rights (California CCPA/CPRA and other states)
This section applies to residents of US states with comprehensive privacy laws, including California (CCPA, as amended by the CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon, Montana and others. Where a term such as "sale", "share", "personal information", "consumer" or "targeted advertising" is defined by your state law, that meaning applies.
9.1 Notice at collection — categories of personal information
In the past 12 months, depending on your tracking choice, the following categories of personal information (using CCPA category names) may be collected and disclosed to our advertising partner. We collect this information from your device as you use the app.
| CCPA category | Examples | Collected | "Sold" / "Shared" | Purpose |
|---|---|---|---|---|
| Identifiers | Apple Advertising Identifier (IDFA), device identifiers | Only if you opt in to App Tracking | Shared with Google (only if you opt in) | Personalised advertising, frequency capping, fraud prevention |
| Internet or network activity | Ad impressions, ad clicks, interaction with ads | Yes | Shared with Google (only if you opt in) | Ad delivery and measurement |
| Geolocation data | Coarse/approximate region derived from IP by Google | Yes (by Google) | Shared with Google (only if you opt in) | Ad delivery, fraud prevention |
| Commercial / inferences | Profiles or inferences drawn by Trailair | No — we draw none | No | — |
We do not collect sensitive personal information (precise geolocation, government identifiers, account credentials, contents of your messages, biometric or health data), and we do not use or disclose any such category for advertising. We do not knowingly "sell" or "share" the personal information of consumers under 16 years of age.
9.2 "Sale" and "Sharing" of personal information
We do not sell your personal information for money. However, when you opt in to tracking, the disclosure of your IDFA and ad-interaction data to Google AdMob for personalised advertising may qualify as a "sale" or a "share" (cross-context behavioural advertising) under the CCPA/CPRA and similar state laws. We treat it as such for the purpose of your opt-out rights below.
9.3 Your right to opt out — "Do Not Sell or Share My Personal Information"
Personalised advertising is off by default: it only ever happens if you actively opt in. You can opt out — or stay opted out — at any time:
- Decline the App Tracking Transparency prompt shown on first launch, or turn tracking off in iOS Settings → Privacy & Security → Tracking. When tracking is off, no IDFA is accessed and only non-personalised ads are served. This satisfies your right to opt out of the sale or sharing of your personal information and of targeted advertising.
- In the app: Settings → Privacy & data → Manage ad consent.
Because Trailair is a native iOS app and uses no web cookies, opt-out is enforced through these device-level and in-app controls rather than a browser signal. Where the Global Privacy Control (GPC) applies, we honour it to the extent technically feasible.
9.4 Your other rights
- Right to know / access the categories and specific pieces of personal information collected about you.
- Right to delete personal information.
- Right to correct inaccurate personal information.
- Right to opt out of targeted advertising, sale, sharing, and profiling (Virginia, Colorado, Connecticut and similar states).
- Right to limit the use of sensitive personal information — not applicable here, as we collect none.
- Right to non-discrimination: we will never deny you service, charge a different price, or provide a different quality of service because you exercised your privacy rights.
9.5 How to exercise your rights and use an authorised agent
The fastest way to exercise most rights is inside the app: Settings → Privacy & data → Export my data (access & portability) and Settings → Reset (deletion). For any other request, email privacy@trailair.online. We will verify your request using information reasonably available to us and respond within 45 days (extendable once by another 45 days where permitted), or within the time required by your state law. You may use an authorised agent acting on your behalf with your written permission. We do not offer financial incentives in exchange for your personal information.
10. Security
Network traffic is encrypted with HTTPS / TLS 1.2+. Local data benefits from iOS file-system encryption when your device is locked. We follow Apple's App Transport Security requirements and do not whitelist any insecure origin.
11. Changes to this policy
We may update this policy from time to time. The "Last updated" date at the top reflects the most recent change. Material changes will be announced in the app's release notes.
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