Home / Privacy Policy – MediaDeclutter Pro
Last updated: 2026-04-02
Valid since App-Version: 26.0
This Privacy Policy explains how MediaDeclutter Pro (“the App”) processes data. Hawkwise Labs is committed to processing personal data only where necessary and to minimizing your exposure. The App is designed to work locally on your device, and this policy reflects that commitment.
The App is developed and provided by:
Hawkwise Labs OÜ
Tornimäe tn 5, 10145 Tallinn, Estonia
Email: contact@hawkwise-labs.com
Website: https://www.hawkwise-labs.com/
MediaDeclutter Pro is built to work locally on your device:
The only internet connections the App makes are for subscription verification via Apple (section 5.1), aggregated launch statistics (section 5.2), an optional feedback system (section 5.3), and an optional newsletter subscription (section 5.4). Apart from these, Hawkwise Labs operates no backend services for this App.
The App processes your photo library only to provide the cleaning and optimization features you use.
With your permission, the App accesses your Apple Photos library to provide:
All duplicate detection and optimization runs on the device where you run the App.
Apple App Tracking Transparency (ATT): The App does not request the Apple Identifier for Advertisers (IDFA) and does not participate in Apple’s App Tracking Transparency system. The App does not use advertising networks, analytics SDKs, or third-party tracking libraries, and therefore does not request tracking permission.
If you grant Photos access, the App may read and process:
Important:
This information is used only locally on your device to enable filtering, duplicate detection, comparison, and optimization. It is never transmitted to Hawkwise Labs or any third party by the App. Hawkwise Labs has no remote access to your device, your photos, or their metadata.
Most settings are stored locally on your device (e.g., app preferences, tool configuration).
We do not collect these settings.
Some selected settings and custom filters can be synchronized via Apple iCloud between your devices (e.g., iPhone, iPad, Mac), using Apple-provided services such as iCloud Key-Value Store and/or CloudKit.
What syncs: Preferred optimization settings and user-created custom filter definitions. No photo data, metadata, or usage history is synced.
Default behavior: iCloud syncing follows your system-level iCloud settings for the App. You can disable iCloud for the App via your device’s iCloud settings.
Data persistence: If you delete the App, synced settings may remain in your iCloud until you manually remove them via your iCloud storage settings.
Each time the App launches, it records an aggregated launch event consisting of: device category (e.g., “iPhone”, “iPad”, “Mac”), OS version, app version, and locale. These statistics are stored as anonymous counters on our server and cannot be traced back to individual users. No personal identifiers, device IDs, or IP addresses are associated with these counters. This data collection is automatic and cannot be turned off, as it is essential for us to understand version and device distribution and to maintain the App.
The App includes an optional feedback system that allows you to rate features and leave comments. See section 5.3 for full details.
Key distinctions:
MediaDeclutter Pro does not:
The App uses Apple In-App Purchase to offer subscriptions and to check whether a subscription is active.
This communication is handled via Apple’s systems (StoreKit).
Each time the App launches, it sends an aggregated launch event to our server. This event consists of: device category (e.g., “iPhone”, “iPad”, “Mac”), OS version, app version, and locale. These data points are incremented as anonymous counters. No personal identifiers, device IDs, advertising identifiers, or IP addresses are stored with these counters. The data cannot be traced back to individual users.
This collection is automatic and cannot be turned off. It helps us understand which device types and OS versions our users run, so we can prioritize compatibility and testing. The legal basis for this processing is Art. 6(1)(f) GDPR (legitimate interest in maintaining and improving the App).
MediaDeclutter Pro includes an optional feedback system that allows you to rate features and leave comments. This helps us improve the App. You choose whether to submit feedback — the App does not prompt or require it.
Data collected when you submit feedback:
This feedback data does not include user accounts, advertising identifiers, or location data.
Rate limiting (IP address):
To prevent abuse and ensure the feedback system remains available, your IP address is collected when you submit feedback. This IP address is:
While your IP address is technically separated from all other data, it constitutes personal data under applicable privacy laws. We process it under Art. 6(1)(f) GDPR (legitimate interest in preventing abuse of the feedback system) and disclose it accordingly in the applicable privacy rights sections of this policy.
Optional contact information:
If you choose to provide your name and/or email address via the optional contact form, this information is processed via our Supabase API endpoint and forwarded to Mailgun for inclusion in the feedback notification email sent to our development team. Your contact information is not stored in the Supabase database — it passes through in transit only and is included in the notification email delivered via Mailgun.
Mailgun retains email delivery logs (including timestamp, sender, recipient, and delivery status) for up to 30 days. Email message content is retained for up to 3 days by default. These retention periods are governed by Mailgun’s standard policies.
Providing contact information is entirely voluntary and is not required to submit feedback. If you provide contact information, you consent to its processing by Supabase and Mailgun for the sole purpose of delivering your feedback to our team.
You may optionally subscribe to our newsletter by selecting the newsletter option on the feedback screen. Newsletter subscription is a separate, voluntary action, independent of feedback submission, and is not required to use the App.
The launch statistics, feedback system, and newsletter are processed by the following sub-processors:
| Sub-Processor | Legal Entity | Location | Purpose | Data Processed |
|---|---|---|---|---|
| Supabase | Supabase Inc. (USA), hosted in AWS EU-West-1 (Dublin, Ireland) | Database in EU | Database hosting and server functions for launch statistics, feedback, and rate limiting | Aggregated launch counters, feedback ratings, IP addresses (rate limiting), contact info (in transit only) |
| Mailgun | Sinch AB (publ) and subsidiaries (Sweden/EU) | EU (Germany, Ireland) | Email delivery for feedback notifications | Name, email (if provided), email delivery metadata |
| MailerLite | MailerLite Limited (Ireland) | EU (Germany, Netherlands) | Newsletter management | Email address (if subscribed) |
Data Processing Agreements:
Hawkwise Labs has executed Data Processing Agreements (DPAs) with all sub-processors in accordance with Art. 28 GDPR and applicable US state privacy laws. These agreements require each sub-processor to:
If we change sub-processors, we will update this Privacy Policy accordingly.
Copies of our Data Processing Agreements are available upon request at contact@hawkwise-labs.com.
Sub-processor privacy policies:
Feedback data is stored on Supabase’s infrastructure in AWS EU-West-1 (Dublin, Ireland). Supabase Inc. is a US company. Where personal data is accessible to Supabase Inc. in the United States, the transfer is governed by Standard Contractual Clauses (SCCs) approved by the European Commission under Art. 46(2)(c) GDPR.
Mailgun (Sinch AB) processes email data within the EU (Germany and Ireland). Mailgun is part of the Sinch group, headquartered in Sweden (EU).
MailerLite Limited is incorporated in Ireland (EU) and processes newsletter data within the EU (Germany and Netherlands). For EU/EEA customers, data remains within the EU. MailerLite’s DPA incorporates Standard Contractual Clauses for any transfers outside the EU/EEA.
Apart from Apple In-App Purchase (section 5.1), the aggregated launch statistics (section 5.2), the optional feedback system (section 5.3), and the optional newsletter (section 5.4), Hawkwise Labs operates no other backend services for MediaDeclutter Pro and does not receive app usage data.
Apple Photos may store your photos in iCloud and download originals to your device when needed.
If a photo is not available locally, Apple Photos may download it during use of the App. This behavior is controlled by Apple and your iCloud/Photos settings.
MediaDeclutter Pro does not control this download process and does not receive those photos; the download happens between your device and Apple services.
When you optimize media, the App requests the original(s) from Apple Photos, performs processing locally, and can create optimized versions.
Optimized versions are written back to Apple Photos only after you review and explicitly confirm the changes.
If you choose to delete items (e.g., duplicates or originals after optimization), the App will instruct Apple Photos to delete them only after an explicit deletion confirmation.
When the App instructs Apple Photos to delete an item, Apple Photos may retain the item in the “Recently Deleted” album for up to 30 days before permanent removal. The duration and behavior of “Recently Deleted” is controlled by Apple and your device settings, not by Hawkwise Labs. Hawkwise Labs cannot guarantee permanent erasure within a specific timeframe.
For the purposes of deletion requests under applicable privacy laws (GDPR, CCPA, and US state privacy laws), deletion is considered complete when the App instructs Apple Photos to delete the item. Photo data is processed entirely on your device and is not held on Hawkwise Labs’ servers.
Before deleting originals, the App may allow you to export and save originals to a location you choose (e.g., local disk / Files). The destination is chosen by you. The App does not upload these exports to Hawkwise Labs.
Because the App processes all photo data locally on your device and does not transmit photos to our servers:
We do not collect personal data that identifies you in the normal operation of the App, and therefore we do not share such data with third parties.
Where you voluntarily provide information (e.g., name or email via the feedback contact form, or newsletter subscription), this data is processed by the sub-processors listed in section 5.5 solely for the stated purposes.
Other third-party processing may occur only within Apple’s ecosystem for:
Apple processes such data under Apple’s own terms and privacy policy.
We do not sell personal data. We do not share personal data for cross-context behavioral advertising. We do not disclose personal data to third parties except as described in this policy.
This section applies where the General Data Protection Regulation (GDPR) is applicable. As Hawkwise Labs OÜ is established in Estonia (EU), the GDPR applies to our processing activities.
Where the GDPR applies, we rely on the following legal bases for each processing activity:
| Processing Activity | Legal Basis | Justification |
|---|---|---|
| Photo library access and on-device processing (duplicate detection, optimization, filtering) | Art. 6(1)(a) — Consent | You grant explicit access via the iOS/iPadOS/macOS Photos permission. You may revoke access at any time via your device’s privacy settings. |
| Photo metadata including EXIF and location data (GPS) | Art. 6(1)(a) — Consent | Covered by the Photos access permission. This data is processed on-device only and never transmitted to Hawkwise Labs. |
| iCloud synchronization of settings | Art. 6(1)(a) — Consent | Enabled via your Apple iCloud settings. You may disable iCloud for the App at any time. |
| Basic local configuration (app preferences) | Art. 6(1)(f) — Legitimate interest | Necessary for the functional operation of the App. No personal data is transmitted. |
| Feedback ratings and aggregated statistics | Art. 6(1)(f) — Legitimate interest | Hawkwise Labs has a legitimate interest in understanding how features are used and improving the App. This data contains no personal identifiers. |
| IP address for rate limiting | Art. 6(1)(f) — Legitimate interest | Hawkwise Labs has a legitimate interest in preventing abuse of the feedback system. The IP address is stored separately from all other data, retained for one hour only, and automatically deleted. This retention period is the minimum necessary to identify and block repeated abuse attempts. |
| Optional contact information (name/email via feedback form) | Art. 6(1)(a) — Consent | You actively choose to provide this information. It is not required to submit feedback. |
| Newsletter subscription | Art. 6(1)(a) — Consent | Requires separate, explicit consent via double opt-in. Independent of feedback submission. |
Regarding special categories of data (Art. 9 GDPR):
Photos in your library may contain sensitive content (e.g., health-related images) or metadata that could be considered special category data (e.g., precise location data). The App accesses this data only on-device, exclusively to provide the features you request, and never transmits it to Hawkwise Labs. Processing is covered by your explicit consent when granting Photos access (Art. 9(2)(a) GDPR). You control which photos the App can access via your device’s privacy settings.
If the GDPR applies to you, you have the following rights regarding personal data processed about you:
Practical scope of these rights:
Because MediaDeclutter Pro processes photo data exclusively on your device, Hawkwise Labs does not hold and cannot access that data. Data subject rights requests therefore apply to feedback data you have submitted (if any), including any contact information and IP address data (if still within the one-hour retention window). Photo data, metadata, and app usage data remain entirely under your control on your device and within Apple’s ecosystem.
To exercise any of these rights, send a request to: contact@hawkwise-labs.com
Please include:
We will respond within 30 days of receipt. If your request is complex or we receive a high volume of requests, we may extend this period by up to 60 additional days with notice to you. We may request additional information to verify your identity before processing your request.
If you have submitted feedback with contact information and request erasure, we will delete your data from our systems and instruct our sub-processors (Supabase and Mailgun) to delete any associated data. If you are subscribed to our newsletter and request erasure, we will instruct MailerLite to permanently delete your email address.
Hawkwise Labs assessed whether a Data Protection Impact Assessment (DPIA) is required under Art. 35 GDPR for the processing activities described in this policy. We concluded that a DPIA is not mandatory because:
This assessment is documented internally and is available for review by supervisory authorities upon request.
Hawkwise Labs implements the following technical and organizational measures to protect the personal data it processes:
In the event of a personal data breach affecting data held by Hawkwise Labs or its sub-processors, we will:
Our sub-processors are contractually obligated to notify us promptly of any data breach affecting data they process on our behalf.
This section applies to residents of the United States and supplements the information in this Privacy Policy.
Depending on your state of residence, you may have rights under one or more of the following laws:
Other US states may have enacted or may enact similar privacy legislation. If you reside in a state with an applicable consumer privacy law not listed here, please contact us and we will address your request in accordance with applicable law.
In the preceding twelve (12) months, we have collected the following categories of personal information:
| Category | Collected? | Source | Details | Business Purpose (CCPA § 1798.140(e)) |
|---|---|---|---|---|
| Identifiers (name, email) | Only if voluntarily provided | Directly from you via the in-app feedback contact form | Optional contact info via feedback form (section 5.3) | Performing services on behalf of the business (delivering feedback to development team) |
| Internet or network activity (IP address) | Yes, temporarily | Automatically collected from your device when you submit feedback via the App | IP address for rate limiting, stored separately from all other data, auto-deleted after 1 hour (section 5.3) | Detecting security incidents; protecting against malicious or illegal activity (abuse prevention) |
| Geolocation data | On-device only | Your Apple Photos library (EXIF metadata in photos) | Photo metadata containing GPS data is processed only on your device and never transmitted to our servers | Performing services you requested (on-device duplicate detection and filtering) |
| Audio, electronic, visual, or similar information | On-device only | Your Apple Photos library | Photos are processed locally and never transmitted to our servers | Performing services you requested (on-device optimization, duplicate detection, cleanup) |
| Commercial information | Limited | Apple Inc. (via StoreKit framework) | Subscription status (active/inactive) | Performing services you requested (enabling paid features) |
| Inferences | No | — | We do not draw inferences from personal information to create profiles | — |
| Professional or employment information | No | — | — | — |
| Education information | No | — | — | — |
| Sensitive personal information | No | — | — | — |
We do not sell your personal information. We have not sold personal information in the preceding twelve (12) months.
We do not share your personal information for cross-context behavioral advertising purposes.
Because we do not sell or share personal information, no opt-out mechanism is necessary.
Depending on your state of residence, you may have the following rights:
To exercise any of these rights, contact us at: contact@hawkwise-labs.com
Include “Privacy Request” in your subject line and describe which right you wish to exercise. We will verify your identity and respond within 45 days of receipt. If your request is complex, we may extend this period by up to 45 additional days with notice to you.
You may also designate an authorized agent to make a request on your behalf. We may require verification of your identity and the agent’s authorization before processing such requests.
Practical scope:
Because all photo and usage data remains exclusively on your device, Hawkwise Labs has no remote access to your device or the data stored on it. We may therefore not be able to fulfill certain requests regarding data that we do not hold. Requests apply to data held on our systems: feedback data, contact information (if provided), IP address data (if still within the one-hour retention window), and newsletter subscription data (if applicable).
The App does not track users across third-party websites or online services. The App does not respond to Do Not Track (“DNT”) browser signals because it does not engage in tracking activities that such signals are designed to prevent.
No third parties collect personally identifiable information about your online activities over time and across different websites or online services when you use the App.
In accordance with CalOPPA:
The App is not directed at children under the age of 13 (or under 16 in jurisdictions where a higher age of consent applies) and does not include social features, advertising, or features designed to appeal to children.
We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will promptly delete it.
Hawkwise Labs OÜ is established in Estonia (European Union).
If you use the App outside the EU/EEA, local data protection laws may also apply. This Privacy Policy is designed to comply with the GDPR (section 10), US state privacy laws (section 11), and general data protection principles.
For information about international data transfers involving our sub-processors, see section 5.6.
We may update this Privacy Policy to reflect changes in the App, legal requirements, or platform requirements.
When we make material changes, we will update the “Last updated” date at the top of this policy and, where practicable, provide notice within the App. The current version will be made available where the App is distributed and on our website.
If you have questions about privacy and data protection in MediaDeclutter Pro, contact:
Email: contact@hawkwise-labs.com
Website: https://www.hawkwise-labs.com/
We aim to respond to all inquiries within 10 business days.