Privacy Policy

1. Introduction

Imgport ("the App," "we," "us," or "our") is a privacy-first batch image utility developed by ToTheTower Labs LLC, a California-based company. This Privacy Policy explains how we handle information in connection with your use of Imgport. By using the App, you acknowledge that you have read and understood this Privacy Policy.

Imgport is designed around a core principle: your photos never leave your device. The App does not have permission to access the internet — it cannot make network connections even in the event of a defect. We do not operate servers that receive your data, we do not maintain user accounts, and we do not have the ability to access your photos or anything you do in the App.

This Privacy Policy is provided in compliance with the California Online Privacy Protection Act (CalOPPA), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the EU General Data Protection Regulation (GDPR), and other applicable privacy laws worldwide.

2. Data Controller Information

For purposes of the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and other applicable data protection laws, the data controller is:

ToTheTower Labs LLC 2108 N ST #15629 Sacramento, CA, United States Email: info@tothetowerlabs.com

We do not currently have a Data Protection Officer. If you have questions about data protection, please contact us at the email address above.

EU/UK Representative (GDPR Article 27): Because the App collects no personal data and performs no processing that leaves your device, we are not required to appoint an EU/UK representative under Article 27(2)(a) of the GDPR. If this changes, we will update this section with our appointed representative's contact information. In the meantime, you may direct any inquiries to our contact email above.

3. Information We Collect

3.1 We Collect Nothing

Imgport collects no data of any kind. Specifically, we do not collect:

• Photo or image content. All image processing — format conversion, resizing, compression, and metadata removal — happens entirely on your device, in memory. Your photos are never uploaded, transmitted, or stored by us.
• Usage analytics or behavioral data. The App contains no analytics or telemetry of any kind. We do not know what features you use, how often you open the App, or anything else about your usage.
• Crash reports. The App contains no crash-reporting service. Release builds of the App produce no diagnostic output at all.
• Advertising identifiers. The App contains no ads and no ad-related tracking, in either the free or Pro tier.
• Location data. We do not request or access your location. In fact, one of the App's core features removes location data (GPS coordinates) embedded in your photos.
• Contacts, calendar, or other personal data.
• Account credentials. There is no user account or login system.
• Payment information. Purchases are processed entirely by Google Play (see Section 3.3). We never receive or store payment details.

This is not a policy choice that could quietly change with an update — it is enforced by the App's technical design: the App does not declare the Android internet permission, so the operating system prevents it from making any network connection.

3.2 Data Stored Locally on Your Device

The App stores a small amount of data locally on your device, solely to make the App work. This data never leaves your device and is not accessible to us:

• Settings — your theme choice, default quality, and default output destination.
• Saved presets — the names and settings of processing presets you create (Pro feature). Presets store only the configuration (for example, "resize to 1920, save to Gallery"); they never store photos or file paths.
• Purchase status — a locally cached flag indicating whether the Pro upgrade has been purchased, so the App works offline. The authoritative record belongs to your Google account and is managed by Google Play.

Uninstalling the App deletes all of this local data.

3.3 Google Play Billing

The optional Pro upgrade is a one-time in-app purchase processed by Google Play. When you make a purchase, the transaction is handled by the Google Play Store application and Google Play services on your device — not by Imgport and not by our servers (we have none). We never receive your name, email address, payment method, or billing address. Google provides the App only with an anonymous confirmation that the purchase completed.

Completing or restoring a purchase requires your device to have an internet connection — that connection is used by the Google Play Store app, not by Imgport. Imgport itself holds no network permission and makes no network connections; it communicates with the Play Store app only through Android's on-device inter-process mechanisms. Every other feature of the App works with no connectivity at all.

Google's handling of your payment information is governed by the Google Privacy Policy and the Google Play Terms of Service.

4. Legal Basis for Processing (GDPR)

Under the GDPR, a legal basis is required for processing personal data. Because Imgport does not collect, transmit, or process personal data off your device, no such processing occurs and no legal basis is required.

All image processing occurs locally on your device at your direction. Data processed locally on your own device by software acting solely under your control does not involve us as a controller or processor of that data.

5. Device Permissions

Imgport requests the minimum permissions possible:

• Photo selection (no permission on modern Android). On Android 13 and later, the App uses the system Photo Picker, which lets you choose specific photos without granting the App any access to your photo library. The App can only read the exact photos you hand it, for the duration of processing.
• Storage write (Android 10 only). On devices running Android 10, the App declares the legacy storage-write permission (WRITE_EXTERNAL_STORAGE, limited to that OS version) solely so it can save your converted photos to the gallery. On Android 11 and later this permission is not requested or used; saving works through the modern scoped-storage APIs.

The App does not request: internet or any network permission, location, camera, microphone, contacts, calendar, phone, or SMS.

6. On-Device Processing

All of the App's functionality runs locally on your device:

• Format conversion (HEIC to JPG/PNG/WebP and between open formats), resizing, and compression are performed by your device's own media codecs and by software running inside the App.
• Metadata removal strips EXIF data — including GPS location, capture time, and camera details — from output files. Metadata is removed from every output by default. Users who purchase the Pro upgrade may explicitly enable a "Keep original metadata" option; it applies only to JPG outputs (other formats are always cleaned), never applies to the Strip Metadata operation, and is off by default. Whichever setting is used, the processing still happens entirely on your device.
• Originals are never modified. The App writes new output files to the destination you choose (gallery, Downloads, or the share sheet); your original photos are untouched.
• Processing is transient. Photos are read into memory, processed, written to your chosen destination, and released. The App keeps no library, copy, or history of your photos.

7. Data Storage and Security

Because the App collects no data, there is no server-side data to secure. The local settings described in Section 3.2 are stored in the App's private storage area, which Android shields from other applications. The App maintains no private database of your images and retains nothing after processing completes beyond the outputs you asked it to save.

8. Data Sharing and Disclosure

We do not sell, rent, trade, or otherwise share any personal information — we have none to share. We have never received a government or law-enforcement demand for user data; if we did, there would be nothing to produce, because the data does not exist on our side.

The only "sharing" that occurs is at your explicit direction: if you choose the App's Share output, your processed photos are handed to the Android share sheet, and the app you pick receives them under that app's own privacy policy.

9. International Data Transfers

No data is transferred internationally — or anywhere — because no data leaves your device.

10. Data Retention and Deletion

• Photos: never retained by us in any form. Outputs exist only where you chose to save them, under your control.
• Local settings and presets: retained on your device until you delete them in the App or uninstall the App.
• Purchase records: maintained by Google Play under your Google account, per Google's policies. The App's local cache of your purchase status is deleted on uninstall and restored on demand through Google Play's "Restore purchases."

To delete everything the App has stored, uninstall the App.

11. Your Privacy Rights

Privacy laws such as the GDPR (EU/UK), CCPA/CPRA (California), and similar laws elsewhere grant rights including access, correction, deletion, portability, and objection to processing.

Because we hold no personal data about you, there is nothing for us to provide access to, correct, delete, or port. Every right these laws protect is satisfied structurally: your data stays with you.

If you nonetheless wish to make a privacy request or have questions, contact us at info@tothetowerlabs.com. We will respond within the time required by applicable law (30 days under GDPR; 45 days under CCPA/CPRA).

California residents: We do not sell or share personal information as defined by the CCPA/CPRA, and we have not done so in the preceding 12 months. We collect no personal information categories enumerated in Civil Code §1798.140. We do not use or disclose sensitive personal information. You will not be discriminated against for exercising privacy rights.

EU/UK residents: You have the right to lodge a complaint with your national supervisory authority. A directory of EU authorities is available at https://edpb.europa.eu/about-edpb/board/members_en; the UK authority is the Information Commissioner's Office (https://ico.org.uk).

12. Children's Privacy

The App is not directed at children under 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect personal information from anyone — children included. Because the App collects no data at all, no child's personal information can be collected through it.

13. Third-Party Services Summary

Service	Purpose	Data involved
Google Play Billing	Processes the optional one-time Pro purchase	Payment handled entirely by Google; we receive only an anonymous purchase confirmation

That is the complete list. The App contains no analytics SDK, no crash-reporting SDK, no advertising SDK, and no other third-party service.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated "Last Updated" date and, where appropriate, notice in the App or its store listing. Because the App cannot transmit data, no change to this policy can retroactively affect data already on your device — there is nothing to re-purpose.

Continued use of the App after changes take effect constitutes acceptance of the revised policy.

15. Contact

For questions about this Privacy Policy or our privacy practices:

ToTheTower Labs LLC 2108 N ST #15629 Sacramento, CA, United States Email: info@tothetowerlabs.com

16. Supplemental Notices

Nevada residents: We do not sell covered information as defined by Nevada Revised Statutes Chapter 603A.

Virginia, Colorado, Connecticut, Utah, and other US state residents: We do not collect, process, sell, or share personal data as defined by your state's consumer privacy law, and we do not process data for targeted advertising or profiling.

Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act): The statements in this policy apply globally — the App collects no personal data regardless of your jurisdiction.