Privacy Policy

1. Introduction

Imgport ("the App") is a privacy-first batch image utility developed by ToTheTower Labs LLC ("we," "us," or "our"), 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. Apart from what Google Play shows every developer (Section 3.3), the only information about you that reaches us is what you choose to send us yourself, such as an email (Section 3.4).

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): The App collects no personal data and performs no processing that leaves your device. The only personal data we handle is correspondence you choose to send us (Section 3.4) and the limited information Google Play shows every developer (Section 3.3): occasional, including no large-scale processing of special categories of data or of data about criminal convictions, and unlikely to result in a risk to your rights and freedoms. On that basis we have not appointed an EU/UK representative under Article 27(2)(a) of the GDPR and the UK 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 The App Collects Nothing

Imgport collects no data of any kind. Specifically, the App does not collect:

• Photo or image content. All image processing — format conversion, resizing, compression, metadata removal, background removal, and face detection for the Blur faces tool — happens entirely on your device, in memory. Your photos are never uploaded or transmitted by the App, and never stored by us unless you choose to attach one to an email you send us (Section 3.4).
• 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, unless you tell us yourself.
• 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.

The only ways information about you can reach us are through Google Play's developer tools (Section 3.3) and an email you choose to send us (Section 3.4).

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, default output destination and, if you use the Folder destination, a reference to the folder you picked (the handle Android issues for that one folder; it identifies a folder, never a photo).
• 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") and, for a preset that saves into a folder you picked, the same folder reference; they never store photos.
• 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 street 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.

Like every developer on Google Play, we can also see some information through Google's developer tools: reviews you choose to post publicly on Google Play (with the name and device details Google shows beside them), crash and freeze reports that Google collects from devices whose owners allow diagnostics to be shared (these name a device model and Android version, not a person), and records of Pro purchases (the order number and date, and the postal code, state and country Google records for the purchase). Google collects this information under its own privacy policy; the App plays no part in it. We use it only to answer reviews, fix problems and keep our business records.

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

3.4 If You Email Us

Settings has a Send feedback option. It opens your own email app with a draft addressed to support@tothetowerlabs.com: space for your message, then a short note and one line of details (the App's version and build number, your Android version and API level, your device's maker and model, and the language the App is showing, for example "Imgport 1.23.0 (30) · Android 16 (API 36) · Google Pixel 8a · en") so a problem can be traced to the device it happens on. The draft contains nothing else: no identifier of you or your device (no serial number, Android ID or advertising ID), and nothing about your photos, your settings or your purchase. Imgport sends nothing itself: the draft goes nowhere unless you send it from your email app, you can edit or delete any part of it first, and the App never learns whether you sent it. If your device has no email app, the App shows the address with a Copy button instead.

If you write to us, through this option or any other way, at either address in Section 15, we receive what you send: your email address and the name your email account shows, your message, the details line if you leave it in, anything you attach, and the routing information every email carries. We use it to answer you, to look into and fix what you report (including letting you know when a fix ships), and to consider any idea you suggest. We never add you to a mailing list or write to you about anything else, and we share your correspondence with no one apart from the provider that hosts our mailbox (Section 7), or where the law requires it.

Email is not end-to-end encrypted unless both you and we use a service that does this, so send only what you would put in an ordinary email. A photo you attach may carry metadata, including its location; you can remove it with Imgport's Strip metadata before attaching.

You can ask us to delete your correspondence at any time, by replying in the same conversation or writing to info@tothetowerlabs.com, and we will, unless we must keep a particular message to meet a legal obligation or to establish or defend a legal claim (for example, a notice under our Terms of Service). Section 10 says how long we otherwise keep it.

4. Legal Basis for Processing (GDPR)

Under the GDPR, a legal basis is required for processing personal data. Imgport does not collect, transmit, or process personal data off your device, so the App itself involves no such processing and needs no legal basis. If you email us (Section 3.4), we process what you send to answer you and to look into what you report, on the basis of our legitimate interest in answering people who contact us and fixing the problems they report (Article 6(1)(f)); where your message concerns your Pro purchase, to deal with it (Article 6(1)(b)); and where we must keep a message to meet a legal obligation, on that basis (Article 6(1)(c)). We use what Google Play shows us (Section 3.3) on the basis of the same legitimate interest. You may object at any time (Section 11).

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; "Browse files" opens the system file browser instead, with the same rule. Either way the App can only read the exact photos you hand it, for the duration of processing.
• Folder destination (access to one folder, only if you use it). If you choose "Folder" as a destination, Android's own folder chooser lets you pick a folder and grants the App access to that folder alone, so it can save outputs there. The App uses that access only to create the files you asked for, keeps it only while a setting or a saved preset still refers to the folder, and releases it when neither does. No storage permission is involved, and the App reads nothing else through it.
• 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.
• Blur faces finds faces in the photos you choose so you can cover them with a blur, a mosaic, or a solid block. The detection runs on your device with a small model that ships inside the App — nothing is downloaded and nothing leaves the phone. It finds faces; it never identifies them: the App reads no facial landmarks, computes no embeddings or identity of any kind, compares nothing across photos, and keeps no record of what it found. The positions of the faces exist only in memory while you are working on that batch and are discarded with it; a saved preset remembers the fill and its strength, never a face. You can reveal any detected face or mark any other area yourself before the covered copies are written.
• Remove background runs another bundled model (a larger one, about 49 MB) on your device in the same way, to separate the subject from the background; nothing about the photo or its result is retained.
• 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), keeps capture dates and camera details, never applies to the Strip Metadata operation, and is off by default. Location data is never kept: on Android 10 and later the operating system removes it from a photo before any app that selects photos the way Imgport does (the system photo picker, a share from another app) can read it, so the App never even receives it. 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, a folder you picked, or the share sheet); your original photos are untouched, and nothing is written anywhere else.
• 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

The App collects no data, so there is no App data on any server to secure. Email you choose to send us is kept in our business mailbox, hosted by Proton AG in Switzerland, which stores it with zero-access encryption so that only we can read it. 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. The App gives us none. The personal information we hold is limited to email you choose to send us (Section 3.4) and what Google Play shows every developer (Section 3.3); we share neither with anyone, apart from the provider that hosts our mailbox (Section 7), or where the law requires it. We have never received a government or law-enforcement demand for user data; if we did, there would be nothing to produce beyond those two, because the App sends us nothing.

The App hands something to another app only when you ask it to: your processed photos to the Android share sheet when you choose Share, a photo's location coordinates to your maps app when you tap Open in maps in the metadata viewer, and a feedback draft to your email app when you choose Send feedback. The app you pick receives them under its own privacy policy.

9. International Data Transfers

The App transfers no data internationally — or anywhere — because no data leaves your device. If you email us, your message is stored by our email provider, Proton AG, in Switzerland, and read and answered by us in the United States, where ToTheTower Labs LLC is based. It travels there because you sent it to us, and it is used only as Section 3.4 describes.

10. Data Retention and Deletion

• Photos: never retained by us in any form, unless you attach one to an email you send us, which we keep only as that email is kept (below). 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.
• Email you send us: kept in our mailbox only until the matter you wrote about is closed (for example, once a problem you reported is fixed and we have told you), then deleted; deleted sooner whenever you ask, with the exceptions in Section 3.4. Notes we keep to track a reported problem describe the problem and the device, never your name or email address.
• 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. Uninstalling does not reach email you have sent us; to have that deleted, ask us (Section 11).

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.

Apart from email you choose to send us (Section 3.4) and what Google Play shows every developer (Section 3.3), we hold no personal data about you, so for everything the App does, every right these laws protect is satisfied structurally: your data stays with you. For email you have sent us, you can ask for a copy, a correction or deletion, or object to our keeping it.

To make any privacy request, write to info@tothetowerlabs.com, or simply reply in the conversation you started at support@tothetowerlabs.com. To protect your correspondence, we act on a request about an email address only when it comes from that address. We will respond within the time required by applicable law (one month under the GDPR, extendable where the law allows; 45 days under the CCPA/CPRA). For information Google holds, such as a review you posted, Google's own tools and privacy policy apply.

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. The App collects no personal information. If you email us, we collect from you the personal information you choose to send: identifiers (your name and email address as your email shows them) and the contents of your message, which may include device information from the details line, commercial information if you write about your purchase, and photos you attach. We use it for the purposes in Section 3.4, disclose it only to the service provider that hosts our mailbox, and keep it as Section 10 describes. Through Google Play's developer tools (Section 3.3) we also see the postal code, state and country Google records for a Pro purchase, and the name and device details shown with a public review; Google collects these, and we use them only as Section 3.3 describes. 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). The App collects no data at all, so no child's personal information can be collected through it. If we learn that an email came from a child under 13 (or that equivalent age), we use it only to reply and then delete it; a parent or guardian may also ask us to delete it at any time.

13. Third-Party Services Summary

Service	Purpose	Data involved
Google Play Billing	Processes the optional one-time Pro purchase	Payment handled entirely by Google; the App receives only an anonymous purchase confirmation
Google Play Console (Google's developer tools)	Shows us public reviews, crash and freeze reports, and purchase records	Collected by Google under its own privacy policy (Section 3.3)
Your email app (Send feedback)	Opens a draft you may choose to send us	Nothing unless you send it; your email provider then handles it under its own policy
Proton Mail (our email provider)	Hosts our support@ and info@ mailboxes	Email you choose to send us, stored encrypted in Switzerland (Section 7)

That is the complete list. The App itself 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. Email you have already sent us will not be used for a new purpose under a revised policy without your consent.

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

15. Contact

To reach us:

ToTheTower Labs LLC 2108 N ST #15629 Sacramento, CA, United States Email: info@tothetowerlabs.com — privacy questions and requests, and legal notices Support: support@tothetowerlabs.com — help with the App, problem reports and ideas (Settings → Send feedback writes here)

We read both, so a privacy request sent to either will be handled.

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: The App does not collect personal data as defined by your state's consumer privacy law. Beyond what you choose to send us (Section 3.4) and what Google Play shows every developer (Section 3.3), we process no personal data, and we never sell or share it or 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, and what reaches us is handled as Sections 3.3 and 3.4 describe.