Legal

Data protection notes – Mandatum

Supplementary notes to the general Data protection for the Mandatum apps (Governance & Compliance) by Christian Tonke. One section per app: what is stored locally, which permissions are used and why, and whether data leaves the device.

Contents

Modules

Controller

Christian Tonke
Adelheider Str. 258
27755 Delmenhorst
Germany
Email: christian@tonke.de

Applies to all modules

  • No user account. None of the apps requires registration, an email address or a login with me. I do not know who uses the apps.
  • Local first. All content is stored in a local database on your device; depending on the app, photos, documents and audio are additionally encrypted with a key in the keychain (iOS Keychain or Android Keystore). Deleting the app removes this data.
  • Three classes. (a) Local only: data leaves the device only when you share or back it up yourself. (b) Optional cloud sync: additionally an end-to-end encrypted sync, off by default, via your own iCloud Drive or Google Drive – with no server of mine. (c) Optional server: additionally a self-hosted server for collaboration or web links that you or your team operate. The class is shown at the top of each app section.
  • Usage statistics only with opt-in. Every app offers usage statistics that are off by default. If you turn them on, the app counts anonymous, typed events (such as “export created”) exclusively on the device, without content, without identifiers and without transmission to me or any analytics service. There is no advertising, no tracking SDK and no crash reporting to third parties.
  • Notifications. Reminders are scheduled as local notifications on the device and need no internet connection. Only apps with a server additionally use push notifications without content.
  • Sharing and export only on your request. PDF, CSV, JSON, ZIP or text are created only when you trigger it, with field selection and preview; personal or sensitive fields are deselected by default. Where you share a file is decided in the system share sheet.
  • Backups in your hands. Backups are files that you store and restore yourself. Your operating-system backup (iCloud or Google device backup) is subject to Apple's or Google's terms; some apps exclude particularly sensitive data from it.
  • Deletion. The settings of every app contain “Delete all data”. This removes database, files and keys on the device; with sync or a server enabled, also the cloud files or the workspace on the server if you confirm it.
  • Demo data for trying things out stays on the device and can be removed with one tap.
  • Diagnostics. A diagnostic report in the settings contains only technical details (version, device, error codes), no content – and is only sent if you email it to support yourself.

AI Register

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Audits & Actions

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Compliance Dashboard

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Controls & Evidence

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Face ID / Touch ID / fingerprint: for the optional app lock.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Retention Periods & Processing Register

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Risks & Exceptions

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Obligations Map

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Policies & Acknowledgement

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Face ID / Touch ID / fingerprint: for the optional app lock.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Vendor Risk Assessment

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

Vendor Documentation

Local only – data leaves the device only when you share or back it up yourself

What the app stores locally

The app stores the entries, lists, notes and attachments you create in it in a local SQLite database on your device. Files and attachments are stored encrypted inside the app; the key stays in the keychain (iOS) or Keystore (Android). Text recognition, if used, runs on the device.

Permissions

Each permission is requested only when you first use the feature and can be revoked at any time in the system settings.

  • Camera: only when you photograph or scan something.
  • Photos: only when you pick an existing photo yourself.
  • Face ID / Touch ID / fingerprint: for the optional app lock.
  • Notifications: for local reminders.

Does data leave the device?

No. All content stays exclusively on your device. The app has no user account, no server of its own and no cloud sync. Data leaves the device only when you export it yourself via the share sheet, pass on a file or create a backup – and only to the recipient you choose.

Backup: a password-protected, encrypted backup file (AES-256) that you store yourself, for example in your own cloud or on your computer. It cannot be read without your password. Share extension: content handed over via “Share” from other apps is copied only locally into this app.

App stores

When downloading and using an app through the Apple App Store, Google Play or the Aptoide app marketplace, Apple, Google or Aptoide process data independently, for example to operate their stores, install apps, provide updates and handle purchases. On Aptoide we publish primarily our iOS apps. Read more in the Apple Privacy Policy and the Google Privacy Policy.

Legal basis

Where I process personal data at all – for example when you email me or when I operate a preset server myself – this is done to fulfil the usage relationship (Art. 6(1)(b) GDPR) or on the basis of my legitimate interest in a secure, working service (Art. 6(1)(f) GDPR). Processing on your device, in your own cloud or on a server you operate takes place without my involvement.

Your rights

Subject to applicable law, you have rights of access, rectification, erasure, restriction, portability and objection. You may also lodge a complaint with a data-protection supervisory authority. Because the apps work without an account, I can neither view nor delete data on your device – you do that yourself via “Delete all data” or by uninstalling the app. Questions can be sent to christian@tonke.de.

Last updated: September 2026

The German version is authoritative.