App privacy policy
1. Controller
The controller for the processing in the Framura app is Ersin Kurt, trading as stubelabs, Lütgendortmunder Hellweg 16, 44388 Dortmund, Germany. Email: hallo@framura.app. For privacy questions and your rights: datenschutz@framura.app. We have not appointed a data protection officer because we are not required to. This policy covers the app. The website framura.app has its own privacy policy.
2. Overview
Framura edits your photos on your device. Photos, drafts and edits are not uploaded unless you upload a profile photo or publish a template (then only its preview image made from sample photos). You only need an account for community features. We use no usage-analytics or advertising services and no tracking. The app sends crash reports only if you agree.
3. Account and public profile
Account. You need an account to vote, save templates, keep collections, follow creators and publish templates. Editing and exporting work without an account. When you sign in with Google or Apple, we receive your email address, an ID of your Google or Apple account and, if you share it there, your name (with Google also the address of your profile photo). Google or Apple are independently responsible for the sign-in itself (see their privacy notices). An email address is required for an account; without an account you can use Framura to edit and to browse templates.
Public profile. Every account has a profile. Visible to everyone, also to people without an account, are your username and, if you add them, your display name, profile photo, bio and Instagram name. Also public are the templates you publish publicly, your public collections, the number of your public templates and the total votes and uses on them. Not public: when you created your account or changed your profile, whom you follow, whom you block, what you saved or put into private collections, and what you voted for; only the total number of votes per template is shown. New accounts first appear under a neutral handle (e.g. “user_1a2b3c4d5e6f”) and without a display name. You don't have to use your real name. We keep your name and the address of your profile photo from your Google account (for Apple only the name, if you share it) only in your private account data. They aren't visible to others and are used only to suggest a username and, if you want, your Google profile photo.
The legal basis is Art. 6(1)(b) GDPR (providing the community features under our terms of use). We keep your account and profile until you delete your account (see “Deleting your account”).
4. Changing your username
Changing your username. You can change your username up to twice in 30 days. We then reserve your previous name for you for 30 days: nobody else can take it, and you can switch back. For this we store the old name with your account ID; after the 30 days we delete the entry automatically, at the latest one day later. Old names don't redirect to your profile. If you delete your account, the reservation for you ends; we then block the name for everyone for 30 days (see “Deleting your account”).
5. Profile photo and Instagram
Profile photo. When you choose a profile photo, the app resizes it on your device and saves it again without metadata such as location, date taken or camera data. Only then is it uploaded. If you signed in with Google, we offer once to use your Google profile photo. Only when you tap “Add photo” does the app download the image from Google to your device; Google receives your IP address, as with any request. If you use it, we store a copy as described above. Others load your profile photo only from our servers, never from Google. When you replace or remove your profile photo, we delete the old file; copies in the content delivery network (CDN) expire within one hour.
Instagram. If you add an Instagram name, we show it on your profile as a link to instagram.com. We don't check that the account is yours, and we don't fetch anything from Instagram. Instagram opens outside Framura only when someone taps the link; Instagram's privacy policy (Meta Platforms Ireland Ltd.) applies there.
6. Templates you publish
Templates you publish
When you publish a template, we store: the layout (frames, shapes, colours and the text you created in the template), name, description and tags, the visibility you chose, whether remixes are allowed, for a remix the link to the original template, and when it was published and last changed. The app also renders a preview image on your device from bundled sample photos (or without photos) and uploads it. Your own photos, your edits, camera data from your photos and text you only type while filling a template are not uploaded. The preview image carries no metadata such as date or location.
Who can see the template depends on your choice: Public – in the gallery and on your profile, for everyone, also without an account. Unlisted – not in the gallery or on your profile, but for anyone who has the link. Private – only you. Public and unlisted templates are shown with your username, which links to your profile. Preview images are stored at an address that can't be guessed and can be opened without signing in. If you switch to a narrower visibility, we move the preview image to a new address.
If you allow remixes, others can publish a changed version that links to your template. If you delete your template, other people's remixes stay online; the link to your template is removed.
The legal basis is Art. 6(1)(b) GDPR (providing the publishing feature under our terms of use). If a template contains information about other people, we rely on Art. 6(1)(f) GDPR for that; our legitimate interest is running the gallery. We remove content that breaks the law or our terms after it is reported.
Retention. We keep templates until you delete them or your account. We delete preview images together with the template. If you narrow the visibility, we store the preview image at a new address and delete the old one; if that doesn't work right away, the app retries the next time it starts. Copies cached by the content delivery network (CDN) at the old address expire after one hour at the latest. Preview images that belong to no template, for example after a cancelled upload, are deleted automatically within two days at the latest. Our daily database backups keep the template's details for up to seven days; preview images are not part of them. We can't recall copies others have already made or that their apps have cached (for example screenshots, drafts or image caches on their devices).
Location. Data is stored in the database and file storage of Supabase Pte. Ltd. (Singapore) as our processor, on servers in Frankfurt am Main (AWS region eu-central-1). Preview images are delivered through the worldwide content delivery network of Cloudflare, Inc. (USA), a sub-processor of Supabase, which processes the IP address of requesting devices. Access from third countries is covered by standard contractual clauses (Implementing Decision (EU) 2021/914). Cloudflare, Inc. is certified under the EU-US Data Privacy Framework.
Camera data. If you place camera data in a layout, the app reads camera, lens, exposure and date taken from the photo file on your device. Location data is not used for this. Some starter layouts (such as “Margins”) include a date stamp that shows the date taken; you see it before exporting and can remove it. The values stay on your device and appear only in images you export yourself.
7. Following, votes, search, previewing with your photos, links
Following, blocking, saving and collections. We store whom you follow to show you new templates from these creators under “Following”. Only you can see this list; creators aren't told who follows them, and there are no follower counts. If you block someone, we store this so we no longer show you their templates, collections and profile. They aren't told and can still see what you share publicly. Only you can see your saved templates and private collections. Public collections (name, your username and the public templates in them) are visible to everyone. We keep this data until you change it or delete your account. Legal basis: Art. 6(1)(b) GDPR.
Votes, uses and order. We keep your votes as long as they exist. When you tap “Use template” while signed in, we count one use per template and day. So that it isn't counted twice, we briefly store that you used the template that day and delete this entry automatically the next day. What remains are numbers without reference to you: the total number of uses and a daily number per template, which we delete after eight days. The order in “For you” and “Trending” is the same for everyone. It results from our featuring, the age of the template and the votes and uses of the last seven days; we don't build interest profiles. “Following” shows templates from creators you follow; templates of accounts you blocked are hidden. Legal basis: Art. 6(1)(b) GDPR for votes and Art. 6(1)(f) GDPR for counting uses. Our legitimate interest is showing how popular templates are and ordering the gallery.
Search. We send search terms and filters to our server to find matching templates and creators; we don't store or analyse them there. The app keeps your recent searches (up to eight) only on your device; you can clear them at any time.
Previewing with your photos. If you pick your own photos to preview templates with them – in a template, under “Choose a template” or when you first start the app – the photo picker places copies of these photos in the app's cache; the app resizes them on your device. Your selection lasts until you close the app or don't use it for 30 minutes. Until then the app shows your photos in every template you open, under “Choose a template” and, while the “With my photos” switch is on, in “Discover”. The app renders these previews on your device and keeps them in memory only. None of this is uploaded or linked to your account. The app deletes the copies and the resized versions when you remove a photo or tap “Remove photos”, when your selection has expired, when you sign out or when you delete your account in the app, and at the latest the next time the app starts. They are excluded from Android backups and from transfers to a new device. If you tap “Use template”, the app copies the photos shown into a draft on your device (see “Drafts and RAW files”); the preview copies stay separate and are deleted as described.
Sharing links. When you share a template or profile, the app creates a link like framura.app/t/… or framura.app/u/… with its ID and without tracking parameters. The page behind the link contains no data about the template or profile; it opens the app. Opening it creates the usual server logs at our hosting provider (see the website's privacy policy).
8. Reporting
Reporting. You can report content with “Report” on templates, profiles and public collections, or by email to hallo@framura.app, also without an account. We store:
- the category you chose and your description;
- for illegal content, your statement that you act in good faith and, if you choose to give them, your name and email address, so we can confirm receipt and tell you our decision;
- a copy of the public texts and names of the reported content at the time of the report, so we can review it even if it changes.
If you're signed in, we link the report to your account so you can see its status under “Your reports”. We don't store your IP address with it. We only share your name with the person you report if that's strictly necessary. For reports of illegal content the legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 16 of Regulation (EU) 2022/2065 (Digital Services Act). For other reports it is Art. 6(1)(f) GDPR; our legitimate interest is enforcing our terms of use and protecting our users. We delete reports, including contact data and the copy, six months after our decision, and undecided reports after twelve months at the latest. Emails about a report are deleted after the same period.
9. Moderation and moderation emails
Moderation. If we hide or delete content, remove profile details or suspend an account, we store the measure with its reason, the rule and the facts, and for suspensions also their duration. We tell the person concerned by email to their account address at the latest when we take the measure and, where possible, also in the app (Art. 17 DSA). Decisions are made by a person. While an account is suspended, the person can still sign in and then sees a notice about the suspension. Until it ends, they can't publish, vote, follow or collect, or change their profile; we don't show their templates and public collections to others during that time. They can still see their data, delete their own content and ask us to delete their account in the app (Settings › Account › “Delete account”) or by email to datenschutz@framura.app. We store that an account is suspended and until when only until the suspension ends; after that we delete this entry automatically, at the latest one day later. We delete records of measures twelve months after they end. Legal basis: Art. 6(1)(c) GDPR in conjunction with Arts. 16 and 17 DSA, Art. 6(1)(b) GDPR (terms of use) and Art. 6(1)(f) GDPR; our legitimate interest is protecting our users and others from illegal content. If there are indications of a criminal offence threatening the life or safety of persons, we are required to inform law enforcement (Art. 18 DSA; in Germany through the Federal Criminal Police Office, Section 13 DDG). In doing so we pass on the information available to us.
We send these notices through Resend, Inc. (USA) as our processor (sending via servers in Ireland; sending logs also in the USA; EU-US Data Privacy Framework and standard contractual clauses). Resend keeps the emails for up to 30 days. We don't track whether emails are opened or links are clicked.
10. Drafts and RAW files
Drafts and RAW files. Photos you add to a draft are stored as a copy in the app's storage on your device, together with smaller versions and your editing steps. For RAW files (such as DNG or ARW) the app also keeps an unchanged copy of the RAW file so you can export at full resolution. Such copies contain everything the camera or phone wrote into the file, for example the location, serial numbers of camera and lens or an entered name. If you pick files from a folder with “Choose RAW file”, the location usually remains in the copy. When you pick files with your device's file picker, such as RAW files or looks, the app only gets access to exactly those files. It reads or copies them once and then gives the access back; it doesn't change the files themselves. On iPhone the file picker hands the app a copy of the file; the app deletes this copy as soon as it has made its own. From this information the app reads only camera, lens, exposure values and date taken (see “Camera data”); it does not read location, serial numbers or name fields. The app develops the RAW file on your device, on Android in a separate, isolated process, on iPhone with the RAW support built into iOS. The app doesn't connect to the internet for this and uses no third-party services. Drafts and RAW copies are not uploaded. On Android they are excluded from backups and from transfers to a new device. On iPhone the app marks them “do not back up”, so iCloud and computer backups and transfers to a new iPhone normally don't include them; Apple says it can't guarantee this. Exported images contain only technical information (orientation, “Framura” as software, time of export, colour space) and no metadata from the original. When you remove a photo, delete a draft or choose “Remove RAW files”, the app deletes the files, at the latest at its next start. Uninstalling the app deletes all drafts. Deleting your account affects your drafts only if you choose “Also delete drafts on this device”; we have no access to them because they exist only on your device. The app doesn't change the files in your gallery or photo library or your folders. On Android 9 and older the app asks for storage access the first time it saves; it uses it only to save your exports and reads no files there. On iPhone you pick photos with the iOS photo picker; the app only receives the photos you select and no access to your photo library. The first time it saves, it only asks for permission to add images.
11. Information on your device
Information on your device. The app stores on your device, among other things, your sign-in session, your recent searches, your drafts with photos and RAW copies (see above), whether you dismissed the Google profile photo offer, your choice about crash reports with the version of the notice and the time, and, temporarily, copies of photos you picked to preview templates. This is necessary for the features you use (Section 25(2) no. 2 TDDDG). The app doesn't send this information to us. Whether it is included in your device's backup, for example with Google or in iCloud, depends on your settings; the app excludes drafts and RAW copies (see above).
12. Crash reports
Crash reports. Only if you agree does the app send a report to Sentry (Functional Software, Inc., 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA) as our processor when it crashes. The report contains the error message and code location, the names of the screens you last opened, the app version and the device model, OS version and memory figures. Before sending we remove file names, paths, usernames and identifiers; we send no user or device identifier, and Sentry doesn't store your IP address. Reports are stored in Sentry's EU region (Frankfurt am Main) and deleted after 30 days. Access from the USA is possible; Sentry is certified under the EU-US Data Privacy Framework, and standard contractual clauses apply in addition. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time with effect for the future under Profile › Settings › Privacy (without an account: Profile › Privacy); the app then sends nothing more and deletes reports not yet sent. Because the reports contain no identifier, we can't link them to you. Crash reporting is never active in the image-processing process for RAW files.
13. No usage analytics, no advertising; store statistics
No usage analytics and no advertising. Framura contains no usage-analytics, advertising or attribution services and builds no usage profiles. Crash reports (see above) serve only to fix bugs; in Google Play's data safety section they are listed under “Analytics” following Google's categories. Google (Google Play) and Apple (App Store, TestFlight) collect statistics under their own responsibility, for example on downloads, installs and crashes; we receive crash and usage data from Apple devices only if you agreed to share with app developers. We only see aggregated numbers. Google's and Apple's privacy policies apply.
14. Deleting your account
Deleting your account. You can delete your account in the app under Settings › Account › “Delete account”, or ask us to delete it by email to datenschutz@framura.app from your account's email address. We then immediately delete your templates with their preview images, your profile photo, your profile, your votes, collections, follows and blocks, and your sign-in details. Copies in the content delivery network (CDN) expire within one hour, server logs after seven days. Reports you sent are no longer linked to your account; names and email addresses you gave voluntarily stay with the report until it is deleted (see “Reporting”). We keep reports about your content and decisions about measures (with the ID of your former account and the names that were public at the time) until the periods stated there end, so we can show that we met our duties under the DSA and defend ourselves against claims (Art. 17(3)(b) and (e) GDPR). After the deletion we block your chosen username for everyone for 30 days so nobody can pose as you; for this we store only the name and the end date, without any link to you (Art. 6(1)(f) GDPR). The app deletes drafts on your device only if you choose that when deleting. Deleting your account doesn't affect your entry on the website's waiting list.
Our daily database backups still contain your account data for up to seven days, until these backups are deleted automatically. We use them only to restore the database after a failure; if we ever had to, we would immediately delete again any account whose deletion was requested after the backup was taken. Images are not part of these backups.
15. Your rights
Your rights. You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and the right to withdraw consent at any time with effect for the future (Art. 7(3)).
Right to object (Art. 21 GDPR). Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR – for example server logs, counting uses, blocking your username after an account deletion or handling reports), you can object at any time on grounds relating to your particular situation. We then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims. Write to datenschutz@framura.app.
To get a copy of your data, correct it or have your account deleted without the app, write to datenschutz@framura.app from your account's email address. We reply within one month. If a request is particularly complex, the period can be extended by up to two months; we'll tell you within the first month. You receive the copy as a machine-readable file (JSON) together with your profile photo and the preview images of your templates and the profile details we received from Google or Apple. We don't disclose names or contact details of people who reported content (Art. 15(4) GDPR). Crash reports contain no identifier we could use to link them to you; we therefore can't provide access to them or delete them specifically (Art. 11(2) GDPR). They are deleted after 30 days. Server and sign-in logs (see “Server functions and logs”), however, contain your account ID; we can't delete individual entries there, and Supabase deletes them after seven days.
You can lodge a complaint with a data protection supervisory authority, for example the one responsible for us: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.
There is no automated decision-making, including profiling, within the meaning of Art. 22 GDPR.
16. Beta test
Beta test. During the beta test we distribute the app through Apple's TestFlight (iPhone) and a closed test on Google Play (Android). If you join our test group at Google for this, we see the name and email address of your Google account; only we can see the member list. We use it only to give you access to the test, send no emails through the group and delete the group no later than one month after the test ends (Art. 6(1)(b) GDPR). If you take part in the internal test, we add your Google account's address to the tester list on Google Play with your consent and remove it after the internal test. Feedback you send through TestFlight reaches us with screenshots, device details and possibly your email address; your own photos may be visible on screenshots. We use the feedback only to fix bugs and delete screenshots once handled. Apple and Google are themselves responsible for TestFlight and Google Play; their privacy policies apply.
17. Server functions and logs
Server functions and logs. Small server functions run at Supabase to delete accounts and to clean up images that are no longer used; what these functions log themselves is only numbers and error codes. Separately, Supabase logs every call the app makes to our server: the time, the address called with its parameters, the status, the IP address, technical details of the app and device (user agent) and, if you're signed in, your account ID. For sign-up, sign-in, password resets and account deletion, Supabase also logs the event with your account ID, email address and IP address. Search terms are not part of the address called and are not logged otherwise either. These logs serve secure operation, preventing abuse and troubleshooting; we only look at them when needed and don't use them for other purposes. Supabase deletes them after seven days. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is secure and error-free operation.
18. Recipients and processors
Recipients. We use the following processors, which process data only on our instructions:
- Supabase Pte. Ltd. (Singapore): database, sign-in, file storage and server functions, servers in Frankfurt am Main; sub-processor Cloudflare, Inc. (USA) for delivering images.
- Functional Software, Inc. (Sentry) (USA): crash reports, only with your consent, EU region Frankfurt.
- Resend, Inc. (USA): sending moderation notices.
- Google Cloud EMEA Limited (Ireland, Google Workspace): our email mailbox when you write to us.
- Vercel Inc. (USA): hosting of the website framura.app, which serves the pages behind shared links and this policy.
Google (Sign in with Google, Google Play) and Apple (Sign in with Apple, App Store, TestFlight) process data under their own responsibility. Public content (profile, public templates and collections) is visible to everyone. Beyond that we only pass on data if the law requires it (for example Art. 18 DSA).
19. Transfers to third countries
Third countries. Supabase and Cloudflare: standard contractual clauses (Implementing Decision (EU) 2021/914), for Cloudflare also the EU-US Data Privacy Framework. Sentry and Resend: EU-US Data Privacy Framework and standard contractual clauses. Google Workspace: EU-US Data Privacy Framework and standard contractual clauses. Vercel: standard contractual clauses.
20. Retention at a glance
| Data | Period |
|---|---|
| Account, profile, templates, votes, collections, follows, blocks | until you delete them or your account; account deletion is immediate |
| CDN copies | at most 1 hour |
| Images that belong to nothing | within two days at the latest |
| Database backups (without images) | 7 days |
| Server and sign-in logs (with IP address, account ID, for sign-in events email address) | 7 days |
| Reserved previous username | 30 days (+ ≤ 1 day) |
| Blocked username after account deletion (no link to you) | 30 days (+ ≤ 1 day) |
| Per-person use entry / daily number without reference to you | next day / 8 days |
| Reports (with contact data, copy, emails) | 6 months after decision, open ≤ 12 months |
| Moderation measures | 12 months after they end |
| Account suspension entry | until the suspension ends (+ ≤ 1 day) |
| Moderation emails at Resend | 30 days |
| Crash reports at Sentry | 30 days |
| Emails to datenschutz@ / requests | after handling; record of requests 3 years |
| Export folder of an access request | after sending, at most 7 days |
| Google test group | at most 1 month after the test ends |
| TestFlight screenshots | after handling |
| Data on your device (drafts, searches, settings) | until you delete it or uninstall the app |
| Photos for previewing templates (cache on your device) | until you remove them, sign out, close the app or don't use it for 30 minutes; files deleted at the latest the next time the app starts |
21. Links to other services
Links. The app contains links to other services, for example on the licences page of the Android app to the LibRaw source code (libraw.org), to Instagram profiles or to our website. When you tap one, your browser or the respective app opens; the app sends nothing to the provider. The provider's privacy policy applies there.
22. Changes
Changes. If the app's features or the law change, we update this policy. The current version is in the app under Settings › Legal and on framura.app. Effective: 27 October 2026.