Viselo Privacy Policy

Effective date: 19 October 2026 · Last updated: 19 October 2026

The short version

• No account. We don't ask for your name, email, phone number or password.
• Your board and your photos stay on your phone. Your answers, your board, the photos you import and their cut-outs are stored on your device. The cut-out is made on your device, and your photos are not uploaded to us.
• Anonymous usage analytics, on by default, easy to switch off. We use PostHog (servers in the United States) to count a few anonymous actions in the app. Turn it off any time in Settings → Share anonymous usage data.
• Superwall and Apple handle subscriptions. Superwall shows the subscription screen. Apple takes the payment. We never see your card details.
• No ads and no tracking. No advertising ID, no tracking across other companies' apps or websites, and we never sell your data.
• Questions or requests? Email [email protected].

The rest of this policy explains the details.

1. Who we are

Viselo is made by LAM Digital Infrastructure SL ("we", "us").

• Tax ID (NIF): ESB26805986
• Address: CL Cirilo Amorós 58 1, 46004 Valencia, Spain
• Contact for privacy questions: [email protected]

We are the data controller for the personal data described in this policy. That means we decide how and why it is used.

2. What stays on your phone

These things are stored only on your device. We can't see them, and they are never sent to us, to PostHog or to Superwall:

The app's data file is stored with iOS file protection. If you delete the app, all of this is deleted with it. We have no copy, so we can't bring it back.

3. Your photos

• Importing. When you add photos, the app uses Apple's photo picker. The app only receives the photos you choose, not your whole library.
• Cut-outs happen on your device. The subject of each photo is cut out on your phone, using Apple's Vision framework. Photos are not uploaded to our servers or to any third party. The app keeps the resulting sticker (a reduced-size PNG) in its own storage on your phone. You can delete a sticker from the app at any time.
• Saving your wallpaper. When you tap save, iOS asks for permission to add photos to your Photos library. This is "add only" access. The app can't see or read the photos you already have.
• Printing. If you print your board, it is sent from your phone to the printer you choose through Apple's print system. We don't receive it.

4. Data that leaves your phone, and why

Viselo does not connect to any third-party accounts, such as social media or photo accounts.

4.1 Anonymous usage analytics (PostHog)

We use PostHog to understand how the app is used, so we can fix problems and improve it. PostHog stores this data on servers in the United States (us.i.posthog.com).

What we collect. Only three actions are recorded today:

• the map screen was viewed;
• the paywall (subscription screen) was viewed, and from which place in the app (for example "edit" or "settings");
• the Edit button was tapped.

Each event also says whether you currently have a subscription (yes or no), which version of the app you use, and whether it is a development or test build. PostHog's software also attaches standard technical information that comes with any app request, such as a randomly generated anonymous ID created by the app on your device, your device and system type, and your IP address (which PostHog receives because the event travels over the internet).

What we don't collect. Not your photos, notes, answers, name, email, Apple Account or advertising ID. We don't link events to an identity: we don't create person profiles. Screen recording ("session replay") and automatic capture of taps and screens are off.

How to turn it off. Open Settings → Share anonymous usage data and switch it off. The app then stops sending analytics events. The switch is on by default.

Legal basis. Our legitimate interest in understanding and improving the app and fixing problems (Article 6(1)(f) GDPR). You can object at any time by switching it off, or by contacting us (see section 8).

4.2 Subscriptions and payments (Superwall and Apple)

Viselo offers paid subscriptions, sold through Apple's App Store. Apple processes your payment and handles your Apple Account, billing and refunds. We never see your card details. The purchase itself uses Apple's StoreKit on your device.

We use Superwall to show the subscription screen and to keep track of whether you have an active subscription. To do this, Superwall's software in the app sends Superwall information about your use of the paywall and purchases (for example, which paywall was shown, which plan you chose, whether a purchase or restore succeeded), the subscription status, and technical information about your device and the app (such as device model, system version, language and an anonymous identifier). Superwall handles this data under its own privacy policy: superwall.com/privacy. We use it to unlock paid features, restore purchases and measure how many people subscribe.

The analytics switch in Settings controls PostHog only. Superwall is needed to show the subscription screen, so it is not controlled by that switch.

Legal basis. Performance of a contract (Article 6(1)(b) GDPR) to give you what you paid for; our legitimate interest (Article 6(1)(f)) to measure subscriptions; and legal obligations (Article 6(1)(c)) for accounting and tax records.

4.3 When you contact us

If you email [email protected], we receive your email address and whatever you write. We use it only to answer you. Legal basis: our legitimate interest in helping you, or performance of a contract if your question is about your subscription (Article 6(1)(f) or (b) GDPR).

5. Who we share data with

We don't sell your personal data, and we don't share it for advertising. We only share what is described above, with these providers:

We may also share data if the law requires it, for example with a court or a public authority.

6. International transfers

PostHog and Superwall process data in the United States, outside the European Economic Area (EEA) and the UK. When personal data goes outside the EEA, we rely on a safeguard recognised by European law, such as the EU-US Data Privacy Framework (if the provider is certified) or the European Commission's Standard Contractual Clauses. You can ask us for details at [email protected].

7. No ads and no tracking

Viselo has no ads. We don't use advertising IDs and we don't ask for "tracking" permission, because we don't track you across other companies' apps or websites. We don't sell your data or share it with data brokers.

8. Your rights

If you are in the EU, the UK or another place with similar laws, you have these rights:

• Access: ask what data we hold about you and get a copy.
• Correction: ask us to fix data that is wrong.
• Deletion: ask us to delete your data.
• Restriction: ask us to limit how we use your data.
• Portability: ask for your data in a format you can move elsewhere.
• Objection: say no to uses based on our legitimate interest, including analytics. You can also just switch analytics off in Settings.
• Withdraw consent: where we rely on your consent, you can withdraw it at any time.

Please note: because there are no accounts, most of your data is only on your phone, and what reaches us is anonymous. That means we often can't link data to you. To delete what is on your phone, delete the content in the app or delete the app. To stop analytics, switch it off in Settings. If you want to make a request, email [email protected]. We may need some information (for example, an Apple receipt or transaction ID) to find what you are asking about. We will reply within one month.

Right to complain. If you are unhappy with how we handle your data, you can complain to the Spanish data protection authority:

Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan 6, 28001 Madrid, Spain
www.aepd.es

You can also complain to the data protection authority where you live or work (in the UK, the Information Commissioner's Office). We'd appreciate the chance to fix things first, so please contact us at [email protected].

9. How long we keep data

10. Children

Viselo is not directed at children under 13, and we do not knowingly collect personal data from children under 13. The app does not ask your age.

If you are a parent or guardian and think your child has used Viselo in a way you are not comfortable with, contact us at [email protected]. Because the app has no accounts, deleting the app from the device deletes everything stored in it. Apple's Ask to Buy lets a parent or guardian approve purchases.

11. Security

We keep data to a minimum, which is the best protection. Connections to PostHog and Superwall use HTTPS. The app's data file is stored with iOS file protection. No system is perfectly secure, but we work to protect what little we process.

12. Changes to this policy

We may update this policy, for example if we add features or change providers. We'll change the "Last updated" date at the top. If a change is important, we'll tell you in the app before it takes effect.

13. Contact

LAM Digital Infrastructure SL
CL Cirilo Amorós 58 1, 46004 Valencia, Spain
[email protected]