for the 78 Arc app and the website 78arc.app
In short: 78 Arc is an offline-first app. Your draws, settings and history are stored exclusively on your device. We operate no user accounts, no tracking and no analytics tools. Data leaves your device only when you actively send us feedback by email or purchase a subscription.
Martin Hoffmann, sole proprietorship
Berlinstr. 28, 90766 Fürth, Germany
Email: kontakt@78arc.app
The app stores the following data exclusively on your device: drawn cards and history, chosen settings (e.g. language), onboarding status and your subscription status. This data is not transmitted to us or to third parties. It is deleted when you uninstall the app.
Subscriptions are processed through the respective app store (Apple App Store or Google Play). Payment data is processed solely by the app store; we do not receive any payment or credit card data.
To manage and technically verify subscription status, we use RevenueCat (RevenueCat, Inc., USA) as a processor. RevenueCat receives a pseudonymous app user ID and information about purchase and subscription status in order to unlock and restore premium access. We are not able to identify you personally through this.
Legal basis: Art. 6 (1) (b) GDPR (performance of a contract, provision of the purchased service). As RevenueCat is based in the USA, data may be transferred to a third country; such transfers are safeguarded by the EU Standard Contractual Clauses. Information: revenuecat.com/privacy.
The privacy policies of the app stores also apply: Apple and Google.
If you contact us via the app's feedback function or directly by email, we process your email address and the content of your message in order to handle your request. Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in responding), or (b) where an existing user relationship is concerned. We delete such messages once they are no longer needed and no statutory retention obligations apply.
The website is hosted by Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA) using the “Cloudflare Pages” service. When you access it, technically necessary connection data and server log files are processed (including IP address, date and time of access, page accessed, browser type) to ensure secure and stable operation. Cloudflare processes this data as a processor under a data processing agreement; transfers to the USA are safeguarded by the EU Standard Contractual Clauses. Legal basis: Art. 6 (1) (f) GDPR. The website uses no tracking or marketing cookies.
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and a right to object (Art. 21). To exercise these, contact kontakt@78arc.app.
You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany.
We will update this privacy policy when changes to the app, to services or to the legal situation require it. The current version published here applies.
As of: June 2026. This English version is provided for convenience; the German version is the legally binding one.
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