Privacy Policy
Scope of the beta
This privacy policy applies to the Managed TestFlight beta and the accompanying website. The closed test group consists of invited adults in Germany. The beta is used to test and improve the app; it is not a public release.
Controller
Max Wehle, trading as Wehle Studio
Elisenstraße 21
48317 Drensteinfurt
Germany
For privacy questions, withdrawal of consent and deletion requests: support@managed-app.com.
Planning data and sign-in
Managed processes reminders, routines, folders, notes and added attachments on your device. These contents support your personal planning. AI requests and beta logs are separate processing activities; they may also involve transmitting content from your planning.
For Sign in with Apple, the account identifier supplied by Apple and, where shared, your name and email address are processed. With Hide My Email, this may be an Apple relay address. The data is used for sign-in and account assignment.
The requested planning and account features are provided on the basis of Article 6(1)(b) GDPR. Necessary sign-in data is processed for the lifetime of the account. Without it, account-based features are unavailable.
AI on your device and through external services
Depending on the AI feature, Managed uses on-device models, Apple's Private Cloud Compute or OpenAI. On-device processing is distinct from transmission to Apple or OpenAI; not every AI request stays local.
Processed data may include your message, the necessary chat history, reminders, routines, personal planning information, and time, location and weather details. Images and files may be included when you select them for an AI feature. Requests forwarded through AWS are technically processed there.
Transmitting personal content to external AI services requires prior informed consent (Article 6(1)(a) GDPR). Participation in the beta alone is not consent. Without permission, the relevant external AI features are unavailable; manual planning remains unaffected.
AI supports your planning and can make mistakes. You can review and change the results. Managed does not use it to make decisions that have legal or similarly significant effects on you.
Information from Apple: Apple Intelligence & Privacy. Information from OpenAI: OpenAI Privacy Policy.
Beta logs containing chat content
Complete chat content is also logged during the beta. This includes inputs, assembled AI requests with the supplied context, responses and technical action data. Usage counts, the model used, input/output token counts and error data are also included. Content may contain personal information; these logs are not universally anonymous.
The purpose is to trace errors and improve planning quality during testing. The logs are stored in Amazon S3 and analysed by Wehle Studio. An AWS region in Europe is used for the beta infrastructure. This does not mean that all participating AI services also process data exclusively in Europe.
Content diagnostics are voluntary and require separate, understandable consent (Article 6(1)(a) GDPR). General acceptance of terms of use or a reference to anonymous statistics is insufficient. Use of the other features must not depend on this consent.
Where possible, use sample data for testing and do not submit confidential information about other people. In particular, please do not use health data or other particularly sensitive information in logged AI requests.
Retention and deletion
Beta logs stored on Wehle Studio's servers are subject to a maximum retention period of six months from the receipt of each record by the server. They are deleted sooner if no longer needed. The end of the beta or a later analysis does not restart this period.
This maximum period also applies to copies of beta logs that we create. Backups must not extend it. It does not describe Apple's independent storage as part of TestFlight.
You manage and delete local planning data in the app. Device backups also depend on your system settings. Deleting a local entry, signing out or removing the app does not automatically delete logs already submitted or server-side account data.
You may withdraw consent at any time with effect for the future, including by email. Please tell us whether this concerns external AI, beta diagnostics or both. After withdrawal, the affected data is deleted unless another legal basis permits its continued retention. Withdrawal does not affect earlier lawful processing.
For access to and deletion of data already submitted, or questions about account deletion, contact us at support@managed-app.com. We only need the information required to locate your data and verify your identity.
Apple TestFlight and voluntary feedback
Apple processes its own usage and crash data for TestFlight and provides test information to the app provider. Feedback may also include comments, screenshots and, depending on the invitation method, your name and email address. This processing is separate from Managed's own beta diagnostics.
Wehle Studio uses the test information received to fix errors and support the test group. The basis is our legitimate interest in a functioning beta (Article 6(1)(f) GDPR); for specific support requests, Article 6(1)(b) GDPR also applies. Our own copies are deleted once their purpose has been fulfilled, and no later than six months after receipt.
Apple's processing and retention rules are governed by Apple's TestFlight privacy notice. A Managed diagnostics switch does not control Apple's TestFlight processing.
Optional device permissions
Access to calendars and reminders enables importing. Location access enables location-based features; the camera and photo picker enable images and attachments. The microphone and speech recognition enable voice input and recordings. Notifications and Face ID support reminders and app protection.
You decide which system permissions to grant and can change them in your device settings. Without a permission, the dependent feature is unavailable. A device permission does not automatically authorise transmission to external AI or storage in beta logs.
Service providers and processing locations
Amazon Web Services (AWS) provides website and backend infrastructure and Amazon S3 for beta logs. Apple provides Sign in with Apple, TestFlight and the Apple AI services used. OpenAI processes AI requests sent to its service. These providers receive the data submitted for the respective service.
External services may process data outside the European Economic Area. This requires compliance with Articles 44 et seq. GDPR, for example through an applicable adequacy decision or appropriate contractual safeguards. A European S3 region does not constitute a general promise of exclusively European processing.
You can request information about the recipients and safeguards applicable to a specific transfer, and a copy of relevant safeguards, through our privacy contact. Our own six-month beta period is not a blanket retention promise on behalf of Apple or OpenAI.
Website and contact
The website is provided through AWS. When you visit it, technically necessary connection data such as your IP address, time, requested address and browser information is processed to deliver the page and enable its secure operation. The basis is Article 6(1)(f) GDPR; our interest is an accessible and secure website.
The website itself does not set cookies or use advertising or analytics trackers. Your chosen language is stored locally in your browser so it can be used again on your next visit. Technical operating logs are limited to the necessary purpose; beta operating logs stored by us are deleted no later than six months after receipt.
If you email us, we process your address, message content and information needed to handle your request. The basis is Article 6(1)(b) GDPR for questions about use, and otherwise our interest in responding (Article 6(1)(f) GDPR). Correspondence is deleted after completion when no further need remains; statutory retention obligations are unaffected.
Your rights
Subject to the statutory conditions, you have the right to access, rectification, erasure, restriction of processing and data portability. You may object to processing based on legitimate interests on grounds relating to your particular situation and may withdraw consent at any time.
You may lodge a complaint with a data protection supervisory authority, particularly where you live, work or where the suspected infringement occurred. The authority responsible for our registered location is the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information. You do not need to contact us first.
Changes and later public release
This version describes the beta. A separate update is planned for the public release; in particular, logging of complete chat content is intended to stop then. Changes to data processing will be explained before their introduction and may require new consent.