Privacy Policy

Last updated: July 23, 2025

Introduction

PureRAW (the “App”) is a mobile application for capturing and processing photos in RAW and JPEG formats. We respect your privacy and are committed to protecting your personal data in compliance with the General Data Protection Regulation (GDPR). This Privacy Policy explains what data we collect, how we use it, and your rights as a data subject.

Data Controller & Contact

Data Controller: Anatoly Makaruk

Email: anatolymakaruk@icloud.com

Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: When you grant camera or photo library access.
• Legitimate Interest: For internal analytics and app performance monitoring, including advertising attribution.
• Contractual Necessity: To provide you with the core functionalities of the App.

Data We Collect & How It Is Used

• Camera Access: Used solely to capture photos within the App.
• Photo Library Access: If granted, allows saving captured photos and selecting existing ones for processing. No photo data is transmitted to our servers or third parties.
• Advertising Data: We use Facebook Ads (Meta Platforms Ireland Ltd.) to promote the App and track installations and subscriptions. Meta may collect limited data, such as device identifiers (e.g., IDFA) and app usage patterns, to measure ad performance. This processing is subject to Meta’s Privacy Policy.

Advertising (Google AdMob)

We show rewarded video ads only via Google AdMob (Google Ireland Limited / Google LLC). AdMob may process device information and the iOS advertising identifier (IDFA) to deliver, measure, and prevent fraud in ads. We do not share your photos or content with AdMob, and the App does not offer in-app ad settings.

Control on iOS: Settings > Privacy & Security > Tracking — allow or deny tracking for this App.

Learn more: Google Privacy Policy · How Google uses information from apps

Data Storage & Security

All photos and related metadata remain on your device or in your personal photo library. We do not store or transmit your photos. Any advertising-related data collected by Meta is handled under their security and privacy frameworks.

We apply reasonable technical and organizational measures to protect your data in accordance with Article 32 of the GDPR.

Data Sharing

We do not share your personal data with any third parties except Meta (Facebook Ads) for advertising purposes. All data shared with Meta is anonymized or pseudonymized where possible, and governed by Meta’s GDPR compliance policies.

No personal data is transferred outside the European Economic Area (EEA) unless adequate safeguards are in place (e.g., Standard Contractual Clauses).

Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

• Right of access – You can request information about the personal data we hold about you.
• Right to rectification – You can request correction of inaccurate data.
• Right to erasure – You can request deletion of your data (“right to be forgotten”).
• Right to restrict processing – You can ask us to limit how we use your data.
• Right to data portability – You can obtain a copy of your data in a commonly used format.
• Right to object – You can object to data processing based on legitimate interest or for direct marketing.
• Right to withdraw consent – You can revoke your consent at any time via iOS Settings.
• Right to lodge a complaint – You have the right to lodge a complaint with your national data protection authority.

Controlling Your Data

• You can revoke camera or photo library permissions in iOS Settings at any time.
• You can limit ad tracking via: Settings > Privacy > Advertising > Limit Ad Tracking.
• You can delete all data associated with the App by uninstalling it from your device.

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Significant changes will be communicated through the App or App Store listing.