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Scan Export privacy policy

Last updated

The short version

Scan Export turns a photo of a page into editable text, and lets you export it as a TXT, PDF or DOCX file. There is no sign-up and no analytics. The app does create an anonymous identifier for your installation, so that Complex Writing allowances can be counted on our server; it is not linked to your name, email, or any account you own.

Standard scans are read entirely on your device using Google’s ML Kit — the image never leaves your phone. If you choose Complex Writing — an optional mode for hard-to-read handwriting and awkward layouts, with a small free monthly allowance and larger ones on paid plans — that page’s image is sent through our own backend (hosted by Supabase) to Google’s Gemini API to be transcribed. Free-tier use shows ads through Google AdMob, which can use advertising identifiers with your consent. Purchases are handled by Apple, Google Play, and RevenueCat. We never see your payment details, and we don’t sell your data to anyone.

This policy explains what that means under the EU General Data Protection Regulation (GDPR), and — for residents of California and other U.S. states with comprehensive privacy laws — under those laws too (see US State Privacy Rights below).

Who is responsible for your data

Scan Export is developed by Ali Završnik, trading as Silom Digital, based in Slovenia, European Union.

For the purposes of the GDPR, Ali Završnik / Silom Digital is the data controller for any personal data processed through the app.

What data Scan Export processes

Scan Export has no sign-up, so almost everything below stays on your device. The one exception is the anonymous installation identifier described next. The paragraphs below are grouped by what triggers each piece of processing.

Anonymous installation identifier. On first launch the app registers an anonymous identity with our backend and stores the resulting token on your device. It contains no name, email address or contact detail, and we cannot use it to identify you. It exists so that the Complex Writing page allowance can be enforced on our server rather than on your device. It stays on your phone until you delete the app; how long our server keeps its record is under Retention.

Camera. Used only to photograph the page you are scanning. The photo is processed on your device and is not written to your photo library.

Photo library (optional). If you import from your gallery, Scan Export uses the system photo picker and receives only the photos you select. It has no access to the rest of your library and cannot browse, index or upload it.

Imported files (optional). If you open a PDF or Word file, Scan Export receives only the file you pick in the system file browser. Its text is read on your device, unless you choose Complex Writing for that import — then its pages are sent for transcription exactly as a Complex Writing scan is.

The page you scan. A scanned page can itself contain personal data — your own or someone else’s (a letter, a form, a name in someone’s handwriting). You control what you photograph and export; Scan Export does not inspect scans for content beyond recognizing text.

Text recognition (standard scans). Handled on-device by Google’s ML Kit. No image or text is transmitted, and no internet connection is required.

Text recognition (Complex Writing, opt-in). When you turn this on for a specific scan, that page’s image is sent over the network to our backend (hosted by Supabase), which forwards it to Google’s Gemini API and returns the transcribed text. The image is held only in memory for the length of that request and is not stored on our servers. This only happens for scans where you explicitly choose Complex Writing.

Local storage. Exported files (so “Recent exports” works), your preferences (theme, default style and format), whether you’ve seen onboarding, your subscription tier, and daily scan counters are all stored locally on your device. You can delete any of this from within the app.

Advertising (free tier only). Free-tier use shows ads through Google AdMob. AdMob may use device or advertising identifiers for ad delivery, frequency capping, and fraud prevention. Paid tiers see no ads and no ad identifiers are used.

On iOS, the system App Tracking Transparency prompt asks separately for permission to use the device’s advertising identifier (IDFA). Declining changes nothing about how the app works — you still get every feature, and ads still appear on the free tier; they are simply not personalised.

Purchases and subscription status. Handled by the Apple App Store (and Google Play on Android), with RevenueCat used to track subscription status across the app. RevenueCat reports your active plan and its expiry date to our backend, which stores them against the anonymous installation identifier so the right allowance applies. We never see or store your payment card details.

Scan Export does not use analytics SDKs, does not build a profile of you, and does not sell your data.

Under GDPR Article 6, each processing activity needs a legal basis. Here is ours for each:

  • Providing the scanning and export features you use (camera, photo picker, on-device text recognition, local storage of exports and preferences) — Article 6(1)(b), performance of a contract: this is the service you’re using the app for.
  • Complex Writing cloud transcription — Article 6(1)(b): it’s a feature you explicitly opt into and, on paid tiers, pay for, on a scan-by-scan basis.
  • Advertising and advertising identifiers (free tier) — Article 6(1)(a), consent: obtained through the in-app consent prompt before any ad identifier is used. You can withdraw this consent at any time — see Your rights below.
  • Security, abuse prevention, and rate limiting (such as daily scan counters and safeguards around Complex Writing usage) — Article 6(1)(f), legitimate interests: our interest in keeping the service reliable and preventing abuse of paid features.

Recipients — who else sees data

  • Google ML Kit — runs on your device. No data is sent to Google for standard scans, so Google is not a recipient here.
  • Supabase — hosts our backend. Complex Writing pages pass through it on the way to Google, and it stores the anonymous installation identifier, the running count of Complex Writing pages used, and, if you subscribe, your active plan and its expiry date.
  • Google Gemini API — receives the page image for scans where you use Complex Writing, and returns the transcribed text.
  • Google AdMob — receives advertising/device identifiers to serve ads, on the free tier, where you have given consent.
  • Apple App Store / Google Play — process your purchase; we don’t see your payment details.
  • RevenueCat — receives purchase and subscription status so the app can unlock paid features.

We do not sell data to anyone, and we do not share data with recipients beyond the ones listed above.

International data transfers

Google (Gemini API, AdMob), Supabase, Apple, and RevenueCat may process data outside the European Economic Area, including in the United States. Where that happens, these providers rely on safeguards such as the European Commission’s Standard Contractual Clauses and/or the EU–US Data Privacy Framework. Their own privacy policies have more detail:

Retention

  • Complex Writing images: sent to Google’s Gemini API to be transcribed and returned as text. We don’t retain a copy on our side. Google’s own retention of API request data is governed by Google’s terms, which we don’t control and can’t override.
  • Exported files: stay on your device, inside the app’s storage, until you delete them yourself.
  • Daily scan counters (on your device): reset automatically each day.
  • Complex Writing page count (on our server, against the anonymous installation identifier): kept per calendar month so the monthly allowance can be enforced.
  • The anonymous identifier and everything stored against it (page count, plan and expiry): deleted automatically after 12 months without the app being opened, or immediately if you ask — see About erasure and access below. Uninstalling removes the identifier from your phone at once; the server-side record then expires under the 12-month rule unless you delete it sooner. A record with an active paid plan is kept while the plan runs, and becomes eligible 12 months after it ends.
  • Preferences, onboarding flag, subscription tier: stay on your device until you delete the app or clear its data.

Your rights

Because Scan Export has no sign-up, most of your data lives only on your device and is already under your control — deleting the app or clearing its files removes it. For anything else, GDPR gives you the right to:

  • Access the data we hold about you.
  • Rectify inaccurate data.
  • Erase your data.
  • Restrict processing.
  • Data portability — receive your data in a portable format.
  • Object to processing based on legitimate interests.
  • Withdraw consent at any time for advertising identifiers, without affecting the lawfulness of processing before withdrawal (you can manage or withdraw ad consent from the in-app consent settings).

To exercise any of these rights, or ask a question about this policy, email admin@silomdigital.com.

About erasure and access in particular

The identifier we hold is anonymous by design, so an email alone gives us no way to find which record is yours — and we deliberately collect nothing that would. The session on your phone is the only thing that can prove which record it is, so erasure lives in the app: Settings → Privacy → “Delete my data from our server” deletes the record and everything stored against it immediately. Deleting the app also removes everything held on the phone, and any server-side record left behind still expires under the 12-month rule above.

Right to lodge a complaint

If you believe your data protection rights have been violated, you can lodge a complaint with a supervisory authority. As the controller is based in Slovenia, that’s:

Informacijski pooblaščenec (Information Commissioner of the Republic of Slovenia)
ip-rs.si

You can also complain to the supervisory authority in your own EU country of residence.

US State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Virginia, Utah, or another U.S. state with a comprehensive privacy law, this section covers the rights those laws give you, in addition to everything above.

“Sale” and “sharing.” Several of these laws — California’s CCPA/CPRA most notably — define “sale” and “sharing” broadly enough to include letting an ad partner use a device or advertising identifier for personalized ads. That is what happens on the free tier through Google AdMob. Under that definition, Scan Export shares your advertising identifier with AdMob for personalized advertising, and nothing else. We do not sell any personal information for money, and paid tiers involve no sharing at all, because paid tiers show no ads.

Categories of personal information involved. In the terms these laws use, the only category “shared” is a unique identifier (the device/advertising identifier used to serve ads). Nothing else — not your scanned documents, not your usage history, not your contact details — is sold or shared with anyone for advertising purposes.

Your rights. Depending on your state, you may have the right to:

  • Opt out of the sale/sharing of your personal information for advertising.
  • Know what personal information is collected, used, and shared, and why.
  • Delete personal information we hold about you.
  • Correct inaccurate personal information.
  • Non-discrimination — we will not deny you service, charge a different price, or provide a lower level of service because you exercised any of these rights.

How to opt out. Open Settings → Ad privacy choices in the app at any time to change or withdraw your choice. Because Scan Export has no sign-up system, this in-app control is how the choice is recorded — there is no separate “Do Not Sell My Info” web form to submit.

Exercising your rights. Settings → Privacy → “Delete my data from our server” deletes the server-side record immediately, from inside the app. Email admin@silomdigital.com for anything else. Because the app keeps no sign-up account, most of what these laws call “personal information” already lives only on your device — deleting the app removes it.

No automated decision-making

Scan Export does not use automated decision-making or profiling that produces legal effects on you or similarly significantly affects you (GDPR Article 22). Text recognition simply reads text from an image you provide — it doesn’t make decisions about you.

Children’s privacy

Scan Export is not directed at children under 16, and we do not knowingly collect data from them.

Changes to this policy

If this policy changes, the updated version will be published on this page with a new “Last updated” date.

Contact

Questions about this policy, or a request about your data? Email admin@silomdigital.com.

Ali Završnik, trading as Silom Digital
1000 Ljubljana, Slovenia

This policy is provided in good faith to describe how Scan Export actually works. It is not legal advice, and the developer should have it reviewed by a qualified professional before publishing the app.