Who is answerable
Letters about this page, and about anything the app does, reach the business that lists Vitrail on Google Play:
Designer Fox
Owner: Anna-Marie Fox
Liljeveien 11C, 1487 Hakadal
Norway
Mail: bly@designerfox.space
In the language of the Regulation, Designer Fox is the controller — behandlingsansvarlig — for anything Vitrail might process. No processor acts on our behalf, there is no joint controller, and no third party has been given a role, because there is no flow of data to give anyone a role in. There is no data protection officer, and none is required: appointing one is mandatory for public bodies and for operations whose core activity is large-scale monitoring or large-scale processing of special categories of data, and a single offline drawing app is neither.
That mailbox reaches a person rather than a queue. It is the only route for privacy questions about the app, and it is checked.
På norsk: du kan skrive til oss på norsk, og du får svar på norsk. Henvendelser om personvern sendes til adressen over.
The short version
Vitrail gathers no personal data whatsoever. No account, no server, no route out of the application. The windows you build, the frames behind them and the glass you chose stay in a folder the app keeps for itself on your handset, for as long as you want them and not a minute after you remove either.
The sections that follow say the same thing at greater length. They exist because Google Play will not list an app without a policy at a stable address, and because the Norwegian Personal Data Act expects anyone handling data to be able to show, in writing, what they handle. Where this page and a store listing ever differ, this page is the binding one.
What the app writes to your device
Vitrail does put things on disk, and precision about where matters more than reassurance. Inside its private storage area it keeps the windows in your gallery, each with the frame it was built on and the glass assigned to every section; the duplicates you make when trying a design in another colourway; any palettes you have put together yourself; the state of the backlight, the symmetry helper and the zoom; and your choice of English or Norwegian.
On Android that area belongs to the application, which means other installed apps are not given sight of it. Nor are we: nothing in the build opens a door from outside, and a file of yours travels only when you deliberately export or share it. Uninstalling removes the area and everything inside it; clearing the app's data in Android settings empties it without removing the app.
One exception, and it is Android's doing rather than ours. The platform offers an automatic backup service attached to a Google account; where someone has it enabled, the system can lift an application's files into that person's own Drive so that a replacement handset is able to put them back. The transfer runs between the device and Google under the account holder's own settings. Designer Fox is not a party to it, cannot read what it carries, and cannot disable it on your behalf — the control is per app, inside Android's settings, and it belongs to you.
Exporting a finished window as a picture hands the file to the system picker, and the picker hands it on to whatever you point it at: a folder, a photo app, a message. At that moment it stops being the app's business, and this page stops applying to it.
What is never collected
Ask what a drawing tool could possibly want from the person using it, and the honest list for this one is empty. Nothing in the build measures you, identifies you, bills you, signs you in or reports on you, and there is no address it could send such a thing to even if it did. Spelled out item by item, so that nobody has to take it on trust, Vitrail at no point reads or transmits:
- a name, a postal address, a telephone number or an email;
- the handset's serial number, its hardware addresses, the Android ID, or the advertising identifier that ad networks use to recognise a device between apps;
- your whereabouts, however it might be worked out;
- the camera, the microphone, the address book, the diary, or anything belonging to calls and messages;
- a record of which tool you reached for, how long you stayed, or which frame you started from;
- the windows themselves, the palettes you put together, or pictures already sitting in your photo gallery.
None of that is a preference buried in a menu. The code for it is absent from the package, which is a stronger guarantee than a switch, because absent code cannot be turned back on by a server that changes its mind.
Children
Filling a frame with coloured glass is something a child can do happily for an hour, and nothing in Vitrail is unsuitable for one. There is no advertising, no chat, no link out of the app, no user-to-user feature and no purchase screen. Since nothing is collected from anyone, nothing is collected from a child either, and the question of parental consent under Article 8 of the Regulation — which Norway has set at thirteen years in the Personal Data Act — never arises, because consent is never the basis for anything here. A parent who would like that confirmed in writing is welcome to ask.
Permissions, and Google's part in this
The manifest is close to bare. Writing a picture out is done through the system's document and media pickers, which grant one write to the single destination you point at and no continuing view of your photographs. Camera, microphone, position, address book and telephone permissions do not appear in the manifest at all, so the dialogue asking you to grant them never has reason to appear either.
Glass, frames and starting templates arrive with the download. The app never asks the network for an asset, which is why it is finished the moment installation ends and why flight mode changes nothing whatsoever about how it behaves.
The store, though, is not the app. Fetching or updating anything from Google Play is business between you and Google, conducted under Google's policy rather than this one, and none of the account or device data involved passes through us. The developer console offers country-level install totals, crash rates and star ratings, already aggregated and with no route back to an individual. That is the sum of what Designer Fox is ever told about anybody.
Which law this sits under
Designer Fox operates from Norway, so the instrument is the General Data Protection Regulation as it applies here. Norway is not a member of the European Union but is party to the EEA Agreement, and the Regulation was taken into Norwegian law by the Personal Data Act of 15 June 2018 — lov om behandling av personopplysninger, the personopplysningslov — which makes the GDPR binding in Norway and adds the national provisions the Regulation leaves to each state.
Being straight about the consequence: an app that processes nothing still has duties. Article 13 requires the identity of the controller to be given whether or not data is collected, which is why section I names a person and an address rather than a brand alone. Article 5(2) puts the burden of demonstrating compliance on us, not on you — so if a sentence here is wrong, it is our failure to prove, not your failure to notice.
What we cannot claim is a long record of handling your data carefully. There is no record, because there is no handling. That is a weaker promise than it sounds like and a stronger one in practice: nothing held is nothing to leak.
The supervisory authority for Norway is Datatilsynet, at datatilsynet.no. Vitrail is sold worldwide on Google Play, so people install it from inside the European Union and from the United Kingdom as well; an EU resident may take a matter to the authority of their own country, and a UK resident to the Information Commissioner's Office at ico.org.uk, under the UK GDPR and the Data Protection Act 2018. Writing to us first is not a precondition, only a faster route.
Your rights, and the answer you will get
Articles 15 to 21 give you the right of access, of rectification, of erasure, of restriction, of portability, and the right to object to processing. Article 77 gives you the right to complain to a supervisory authority, and you keep it whatever we say.
Send a line to bly@designerfox.space; Article 12(3) allows a month to reply, and a reply will come sooner than that. It will be a short letter, because the truthful answer is that there is no file on you to hand over, amend, erase, freeze or carry anywhere else. Nobody will be asked to prove their identity first. There is no record for such a check to guard, and requesting a scan of a passport in order to report an empty result would be the one moment in the entire exchange when somebody's data was genuinely at risk.
Should the reply leave you unconvinced, say so once and let us look again; after that the matter belongs to Datatilsynet, or to the authority of your own country if you live elsewhere in the EEA or in the United Kingdom. No sentence on this page asks you to give up a right, and no sentence on it could.
When these words change
What makes a document like this worth anybody's attention is the order of events. If some later build of Vitrail acquires something that touches personal data — a gallery that syncs, a crash reporter, glass sold in packs, advertising in any form — the words here change first and the release comes afterwards. The date and revision line beneath the title moves along with them, and the substance of the change goes into the Play release notes as well, so that nobody has to visit this address to learn of it.
The address itself stays put for as long as the app is listed. That revision line is the quickest way to see whether anything has shifted since your last visit.