Privacy notice for the iOS app

Last updated: 23 August 2026

The German version is legally binding. This notice supplements the website and web-app privacy notice and describes the native CircleRecs app for iOS.

1. Controller and privacy contact

The controller is Axel Springer Deutschland GmbH, Axel-Springer-Straße 65, 10888 Berlin, Germany. Contact the data protection officer at datenschutz@axelspringer.com using “CircleRecs – Betroffenenrechte” as the subject.

2. Installation, sign-in, and account

Apple independently processes App Store download data. Sign-in uses Sign in with Apple or Google Login, and CircleRecs manages the session. We process a technical user ID, provider, email where supplied, profile name, username, profile photo, language and, if you provide it voluntarily, birth year and age band. CircleRecs is for adults aged 18 or over; you confirm this independently of the optional age field. Other users do not receive your exact birth year. You can remove the age information from your profile at any time.

3. Circles, public profiles, subscriptions, chats, and content

Recommendations, lists, notes, tags, photos, videos, reactions, messages, and profile data follow the visibility you choose. Private circles and chats are restricted to their members. Content you release through a public profile can be publicly visible. Blocks, personal Want and Pass places, import previews, and unpublished drafts remain private. For a private profile, signed-in users may still see your display name, username, profile photo, and aggregate counts of recommendations, followers, and followed profiles. Recommendations, places, bio, taste tags, social links, and the follower/following lists remain hidden. Private profiles are excluded from ranked creator suggestions; a signed-in user must explicitly enable the separate private-profile view and may then filter it by name or username. Following a private profile does not unlock this content. You can remove followers or block accounts. CircleRecs does not create movement profiles and prohibits using place data to monitor or stalk people.

If you join an Exclusive Circle, Apple independently handles the purchase and payment; CircleRecs does not receive card or bank details. To verify, provide, and restore access, we process a random identifier linking the purchase to your app account, Apple product identifier, original and latest transaction identifiers, environment, purchase and expiry times, and subscription, renewal, grace-period, refund, and revocation status. The legal bases are Art. 6(1)(b) GDPR, Art. 6(1)(f) GDPR for misuse prevention and legal claims, and Art. 6(1)(c) GDPR for legally required accounting records.

For approved creators, we also process approval and account status, assigned product and Exclusive Circle, agreed revenue share, payout currency and threshold, and proceeds, refund, adjustment, and payout entries. Contract, invoice, tax, and bank details are handled only through authorised finance and contracting processes and are not displayed publicly.

4. Location, maps, and places

With iOS permission, the app uses your current location only to centre the map, run Near Me, or support a search you start. We do not create a persistent location history or use background location. The app uses Apple MapKit and Apple Maps for address suggestions. For place searches, OpenStreetMap/Nominatim and, where needed, Geoapify may receive the search term, language, and an optional country hint. OpenFreeMap supplies map styles and tiles, MapLibre GL runs locally, and Overture place data is also used without receiving your queries.

If you explicitly open directions in Google Maps, iOS passes the selected destination to Google Maps. Google then processes the data required for maps and navigation under its own terms. Google Maps is not the embedded map provider in the CircleRecs iOS app.

5. Ask, AI, embeddings, and voice

Ask and labelled AI-assisted place features send the current input and necessary recommendations to OpenAI under the Axel Springer enterprise agreement. Outputs are generated automatically and may be wrong. API content is not used to train general-purpose models. Pinecone processes embeddings with limited search metadata. CircleRecs considers only content you are allowed to access, and semantic search data is deleted with its content or account.

When you explicitly start AI-assisted place search, the query, language, region, and the place or map context you selected may also be sent to OpenAI. OpenAI may search publicly available web sources to suggest a venue identity, address, and—where reliably found on the official website of that exact venue—opening hours. CircleRecs does not accept AI-suggested coordinates without verification against our place catalogue and geocoding services. Suggestions may be wrong or outdated and can be reviewed before saving.

If the detected language of a personal recommendation note visible to you differs from your app language, CircleRecs may use OpenAI to create a display-only translation. The original remains unchanged and can always be shown. The access-controlled translation is refreshed after edits and deleted with the recommendation or account; editing, Ask, search, and filters continue to use the original.

Voice first uses Apple Speech. Only after your explicit first-use consent do we send a short recording securely to OpenAI for improved transcription. You may withdraw consent for the future. Raw recordings are discarded after the request and are not retained; typing is always available.

6. Photos and videos

Media is uploaded only after you select or capture it and follows your chosen audience. Do not upload unnecessary sensitive data, confidential documents, or content about others without permission. You can delete your media; previews and optimized copies follow the same visibility and deletion lifecycle.

7. Google Login and public-list import

Google Login is only for authentication. Separately, you can paste a public Google Maps list link. CircleRecs uses the public list data to show you editable place suggestions and may use the providers described in sections 5 and 11 for this purpose. Nothing is saved or shared until you confirm. There is no access to your private Google account and no Google Data Portability/OAuth import. Unselected candidates are not semantically indexed and are deleted within 30 days.

8. Import from public social-media links

Through the iOS share sheet, you can send CircleRecs a public Instagram, TikTok, or YouTube post. We may process the public link, platform, text or caption supplied by the share sheet, and publicly available preview data (title, creator name, cover) to suggest a place. CircleRecs does not sign in to your social-media account or access private content.

We reduce link parameters to the required public post address. Shared text may be sent to OpenAI to prepare editable place suggestions. A caption does not automatically become your personal recommendation. Temporary share-extension files are removed after handoff or discard. Only places and media you confirm are stored as CircleRecs content with the visibility you choose. If you confirm the post is yours and choose to show it on the recommendation, we store the public link and the creator name you confirmed; the cover may then be stored as your recommendation photo. We do not store another creator's name or image as yours. Share only content you are entitled to use.

9. Push notifications

If enabled, an APNs device token is processed through Apple for selected circle, chat, and account notices. You can control notifications in iOS and, where offered, per circle. The token is removed on logout, account deletion, or technical invalidation.

10. Affiliate links, analytics, and diagnostics

Marked partner links may use a pseudonymous attribution ID, destination, time, and status, deleted within 90 days. Minimal product events used to improve CircleRecs are deleted within 30 days. Dash0 processes technical telemetry and errors. CircleRecs does not perform cross-app advertising tracking.

First-party product analytics covers no more than one active-day record per platform, the app version, and categorised actions such as opening a place detail, push notification, or Ask source, or sharing an invitation. It contains no search text, message content, location coordinates, or place, recommendation, or Circle identifiers. The legal basis is our legitimate interest in developing a useful and stable service under Art. 6(1)(f) GDPR. We use neither third-party analytics SDKs nor cross-app advertising tracking for this purpose. You may object on grounds relating to your particular situation.

11. Recipients, transfers, and security

Depending on your choices, recipients include circle members, followers, or public visitors, and our providers AWS, Apple for App Store purchases and subscription status, Google for sign-in and public-list retrieval, OpenAI, Pinecone, Dash0, OpenStreetMap/Nominatim, Geoapify, OpenFreeMap, and Hostinger. Transfers outside the EEA rely on adequacy decisions including the EU-US Data Privacy Framework or Art. 46 GDPR safeguards. Transfers are encrypted and access is restricted according to your permissions.

For creator payouts, only authorised product, legal, tax, and finance teams within the Axel Springer organisation receive the necessary data. Banks and, where legally required, tax authorities may be further recipients. Apple independently processes App Store purchases under its own privacy terms.

12. Retention and deletion

Product data is normally retained until you delete the content or account. Technical logs, product events, and unselected import candidates are deleted within 30 days. Cohort statistics derived from them contain no user or content identifier and remain only as aggregate metrics. Affiliate attribution is deleted within 90 days and database backups within seven days unless law requires longer. Account deletion removes active product data, media, import data, and semantic search data, while remaining backups expire on schedule.

Account deletion does not cancel an Apple subscription. We delete or detach the active account association, while minimised transaction and payout records may be retained for Apple notifications, refunds, misuse prevention, legal claims, and statutory accounting and retention duties. They are deleted or anonymised when those purposes end. You manage and cancel the subscription separately in your Apple Account.

13. App Store data summary

Depending on use, CircleRecs processes contact and account data, user content, approximate or actively requested precise location, searches, public social-media links and content supplied through the share sheet, purchase history and subscription status, usage and diagnostics, and technical identifiers for app functionality, personalization, security, and analytics—not third-party advertising or cross-app tracking. The Apple App Store declarations and this full notice provide the authoritative details.

14. Your rights

Subject to legal requirements, you have rights to access, rectification, erasure, restriction, portability, objection, and withdrawal of consent for the future. Contact datenschutz@axelspringer.com with “CircleRecs – Betroffenenrechte” as the subject. You may also complain to a data protection authority.