Sub Zero Hero

Privacy Policy

Information about the processing of personal data under GDPR — for this website and for the iPhone app.

1. Controller

The controller responsible for processing is:
Stefan Siebel
Bartholomäus-Arnoldi-Str. 122
61250 Usingen
Germany
Email: hello@subzerohero.de

2. The short version

Sub Zero Hero is an iPhone app that runs entirely on your device. There is no user account, no sign-in, and no server of ours holding your data. Your freezer inventory is stored locally on your iPhone and — if you are signed in to iCloud — synced across your devices through your own private iCloud database. We have no access to that data and never receive it. The app contains no analytics, tracking, or advertising components and no third-party SDKs.

3. Scope

This privacy policy applies to this website at subzerohero.niftybits.app and to the “Sub Zero Hero” iPhone app. The sections below indicate whether they relate to the website, the app, or both.

4. Website: hosting and server log files

This website is hosted with Amazon Web Services (AWS) in the eu-central-1 region (Frankfurt am Main, EU) and delivered through the Amazon CloudFront content delivery network. When you access it, information is automatically stored in server log files (IP address, date and time of the request, URL accessed, browser and device information). This data is technically necessary to deliver the content and keep operations secure, and is not merged with other data sources. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operating the website securely).

5. Website: cookies and local storage

This website sets no cookies. The only entry stored is a technically necessary item in your browser’s localStorage remembering your preferred colour theme (light/dark). It is used locally only and is not transmitted to us. We use no analytics or audience-measurement tools.

6. App: no accounts, no processing by us

Using the app requires no registration. We process neither your email address nor a password, neither your name nor your Apple Account. There is no user database on our side. The app contains no code that sends content to us or to third parties.

7. App: storage on your device and in your iCloud

The content you create in the app — households, food items, quantities, storage locations, categories, freezing dates, and notes — is stored in a database on your iPhone. If you are signed in to iCloud and iCloud Drive is enabled for the app, that content is additionally mirrored into the private iCloud database of your own Apple Account (Apple CloudKit). That makes it available on your other devices and part of your iCloud backup.

This processing takes place between you and Apple: the data sits inside your iCloud account and counts towards its storage. CloudKit gives developers no access to users’ private databases — we can therefore neither view, nor export, nor delete your inventory. Apple’s processing is governed by Apple’s Privacy Policy. You can turn iCloud syncing off at any time in the iOS settings under Apple Account → iCloud; the app then carries on working purely locally.

Legal basis, to the extent any processing is attributable to us at all: Art. 6(1)(b) GDPR (providing the app functionality you asked for).

8. App: sharing a household

You can share your household with other people through Apple’s iCloud sharing by sending them a link. The shared content stays in the iCloud database of the person who owns the household; the people you invite get access to it through their own Apple Account. Apple shows you the name and — depending on how you invited them — the email address or phone number of the people involved, so that you know who has access. This processing too runs entirely through Apple; we receive neither the content nor the details of the participants. A share can be revoked in the app at any time.

9. App: distribution through the App Store

The app is distributed through the Apple App Store. When you download and update it, Apple processes data as its own controller; see Apple’s privacy policy for details. As the developer we receive only aggregated, non-personal statistics from Apple (such as number of downloads, device types, or regions) and — only if you have explicitly agreed to share them in the iOS settings under Privacy & Security → Analytics & Improvements — crash reports. Those reports contain technical information about the crash, not the contents of your inventory. Legal basis for crash reports: Art. 6(1)(a) GDPR (consent given to Apple, revocable there at any time).

10. App: no tracking

Sub Zero Hero does not track you. The app uses no advertising identifiers, requests no tracking permission, and embeds no third-party analytics, advertising, or error-reporting services. Accordingly, its App Store listing declares Data Not Collected under “App Privacy”.

11. Contacting us

If you email us, we process your email address and the content of your message in order to deal with your request. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in answering enquiries), and for app-related enquiries additionally Art. 6(1)(b) GDPR. We delete the correspondence once it is no longer needed and no statutory retention obligations apply.

12. Recipients and processors

To operate this website we use Amazon Web Services as a processor (hosting and delivery via Amazon S3 and Amazon CloudFront, eu-central-1 region, Frankfurt am Main). With regard to iCloud and the App Store, Apple is not our processor but processes your data under your own contractual relationship with Apple. We do not pass data to third parties for advertising or analytics purposes.

13. Retention

You store your app content yourself: on your device and in your iCloud, for as long as you wish. It is deleted when you delete it in the app, remove the app from your device, or delete the associated iCloud data in the iOS settings. Server log files for this website are kept only short-term for technical and security purposes.

14. Your rights

Under GDPR you have, in particular, the following rights:

  • Access to data stored about you (Art. 15)
  • Rectification of inaccurate data (Art. 16)
  • Erasure (Art. 17)
  • Restriction of processing (Art. 18)
  • Data portability (Art. 20)
  • Objection to processing based on Art. 6(1)(e) or (f) (Art. 21)
  • Lodge a complaint with a data protection authority (Art. 77)

In relation to the app:

  • Access and data portability (Art. 15, 20): you can export your entire inventory yourself at any time from the app’s settings as a structured JSON file. We cannot provide access ourselves, because we do not hold this data.
  • Erasure (Art. 17): you delete your data yourself — in the app, by removing the app, or via the iOS settings under Apple Account → iCloud → Manage Storage.
  • For any other request, reach us by email at hello@subzerohero.de.

15. Last updated

Last updated: 11 September 2026.