Privacy Policy
Version 1.1 · In force from 12 September 2026
This Privacy Policy (the "Policy") sets out how personal data is handled in connection with the Clipset mobile application. It forms an integral part of the Terms of Use and is binding in the same manner. Its substance is brief for a single reason: the Application operates without accounts, without servers of the Developer and without analytics, and therefore no personal data is collected.
Definitions
Terms defined in the Terms of Use bear the same meaning in this Policy. In addition:
- Personal data means any information relating to an identified or identifiable natural person.
- Processing means any operation performed on personal data, including collection, storage, use, disclosure and erasure.
- Controller means the natural or legal person who determines the purposes and means of the processing of personal data.
- Device means the iPhone or other Apple-branded device on which the User has installed the Application.
- Local storage means the storage area allocated to the Application on the Device by the operating system and protected by it.
Identity of the Developer and contact details
The Application is developed and distributed by an independent developer (the "Developer"), who is responsible for the Application within the meaning of clause 3 of the Terms of Use.
All questions, notices and requests relating to this Policy shall be addressed to the Developer by electronic mail at tesserly.dev@gmail.com. Enquiries are answered by the Developer personally.
The Developer has not appointed a data protection officer, and is not required to do so, because no systematic processing of personal data is carried out.
Scope
This Policy applies to the Application and to any data arising from its use.
This Policy does not apply to the services through which the User chooses to transmit a Pack or a backup, nor to the App Store, nor to any other third-party product. Those services are governed by the privacy notices of their respective providers.
This Policy does not apply to the manner in which a Recipient handles content received from the User. Once a Pack has been transmitted, its further handling lies outside the Developer's control and outside the scope of this Policy.
Principle of local processing
The Developer collects no personal data, operates no server on which User Content is stored, and has no technical means of accessing the data held on the Device.
All data generated through the use of the Application is written to Local storage on the Device and remains there.
The Application requires no registration, no account, no electronic mail address and no other identifier of the User.
Accordingly, in respect of data held on the Device, the User alone determines the purposes and means of processing. The Developer does not act as a controller of that data, and no personal data of the User is transmitted to the Developer in the ordinary operation of the Application.
The Application is distributed with a privacy manifest declaring no collected data categories and no tracking domains. That declaration is reproduced on the App Store product page under App Privacy and may be verified there independently of this Policy.
Categories of data held on the Device
The following categories are written to Local storage and are not transmitted to the Developer:
- Exercise clips — the video files imported and trimmed by the User, together with their cover images.
- Exercise details — designation, muscle group, equipment, notes, repetitions, load and rest interval.
- Programs and workouts — the User's weekly plan and the sequence of exercises within it.
- Session history — completed sessions, their dates and the sets recorded by the User.
- Progress photographs — the photographs taken through the Application, with their dates and, where entered, body weight.
- Settings — units of measurement, rest interval, sound, playback preferences and author name.
- Signing key — the cryptographic key from which the Clipset ID is derived, held in the Keychain of the operating system. It stays on the Device unless the User enables iCloud sync in Settings, in which case Apple synchronises it between the User's own devices through iCloud Keychain, encrypted end to end.
Progress photographs and exercise clips may constitute personal data, and progress photographs may additionally relate to health. They are held exclusively on the Device, and the Developer receives neither the files nor any information derived from them.
Deletion of the Application removes every category listed in this clause from the Device.
Network connections established by the Application
The Application establishes one connection of its own. Upon launch it issues a request without a body to apple.com and reads from the response the date and time only.
The purpose of that connection is to determine a reliable current time, so that a Pack subject to an expiry date cannot be revived by altering the clock of the Device. The legal basis, where such a basis is required, is the legitimate interest of the Developer and of the User transmitting the Pack in the integrity of that mechanism.
The request carries no content, no identifier and no information concerning the User. As with any request over the internet, the receiving server observes the internet protocol address from which the connection is made; the Application transmits nothing further and retains from the response nothing but the date.
Apart from that connection, the Application communicates only with the App Store for the purpose of ascertaining the status of a Subscription. The Application contacts no server operated by the Developer, uses no interface of the Developer and incorporates no third-party software development kit that transmits data.
Data transmitted at the initiative of the User
Data leaves the Device only upon an express instruction of the User and only to a destination designated by the User.
Packs. Upon sharing, the Application generates a single .clipset file and submits it to the sharing interface of the operating system. The User designates the destination. The file is transmitted directly to that destination and does not pass through any infrastructure of the Developer. A Pack contains the User Content selected by the User, the author name, the public Clipset ID and, where configured, an expiry date and a recipient lock. Its media are encrypted and the Pack is signed with the key held on the Device.
Backups. A backup exported by the User is an ordinary file, stored at a location of the User's choosing, containing the library, workouts and history in full. Any person in possession of that file is able to restore the library, and the User is responsible for keeping it securely.
Progress videos. A timelapse video is written to the User's own photo library only where the User requests that it be saved.
Once a Pack or a backup has left the Device it is subject to the privacy notice of the service or person to which it was sent, and no longer to this Policy.
Permissions requested on the Device
The Application requests the following permissions, each for the purpose stated and for no other:
- Camera — solely to take a progress photograph, which is written directly to Local storage. The Application does not record video by means of the camera and does not access the microphone.
- Addition to the photo library — solely to save an exported progress video at the User's request. The permission is limited to addition: the Application may place a file in the library but may not read or browse it.
- Selection of media — when a video is imported, the operating system presents its own selection interface and transfers only the item selected. The Application obtains no access to the remainder of the library.
The Application does not request access to location, contacts, the calendar, health records, the microphone or notifications, and has no functionality requiring them.
Each permission may be withdrawn at any time in the settings of the operating system. Withdrawal disables the corresponding function and affects no data already stored.
Subscriptions and payment data
Clipset Pro is sold by Apple through the App Store. The purchase is effected entirely within the systems of Apple, which acts as the merchant of record.
The Developer receives no payment card details, no billing address and no Apple Account identifier. The Application obtains from StoreKit only an indication whether a Subscription is currently active, and that indication remains on the Device.
The processing of payment data is governed by the privacy notice of Apple.
Absence of tracking, analytics and advertising
The Application does not contain and does not employ:
- analytics frameworks of any kind, whether proprietary or third-party;
- advertising, advertising networks or advertising identifiers;
- device fingerprinting or any technique of cross-application or cross-site tracking;
- profiling, scoring or automated decision-making producing legal or similarly significant effects;
- attribution, crash-reporting or marketing software development kits transmitting data to third parties.
No personal data is sold, shared for cross-context behavioural advertising, or disclosed to data brokers. No such data is held.
Recipients and international transfers
The Developer discloses no personal data to any recipient, because no personal data is collected.
No international transfer of personal data is carried out by the Developer. The connection described in clause 6 is addressed to a server operated by Apple and transmits no personal data beyond the internet protocol address inherent in any internet connection.
Where the User transmits a Pack or a backup to a Recipient in another country, that transfer is effected by the User and under the User's responsibility, and is governed by the terms of the service used.
Retention and erasure
Data is retained on the Device for as long as the User retains it. The Developer applies no retention period, because it holds no data.
The User may erase data at any time by the following means:
- Clear history removes the session history and retains clips and workouts;
- Delete progress photographs removes every progress photograph together with its files;
- deletion of an individual clip, workout or photograph removes it and its associated media immediately;
- deletion of the Application erases the entire library, all photographs and all settings from the Device.
Erasure is immediate and irreversible. Since no copy is held by the Developer, no erasure request need be addressed to the Developer and no such request can be executed on the Developer's side.
Security
Data is held within the storage area allocated to the Application by the operating system, protected by the file protection mechanisms of that system and, where a passcode is set, by the encryption of the Device.
The signing key is held in the Keychain with an accessibility attribute restricting it to the Device. Where the User enables iCloud sync in Settings, the key is synchronised between the User's own devices exclusively through iCloud Keychain, which Apple encrypts end to end; the Developer has no access to it at any point.
Media within a Pack are encrypted, and a Pack is signed so that its author may be verified by the Recipient.
No system of security is absolute. The User is responsible for the security of the Device itself, including the use of a passcode, and for the safekeeping of exported backups.
Rights of the data subject
Where the User resides in the European Economic Area, the United Kingdom, Switzerland, Ukraine, Brazil, the State of California or another territory conferring such rights, the User is entitled to access, rectification, erasure, restriction of processing, portability and objection in respect of personal data concerning the User.
Those rights are satisfied by the design of the Application. The Developer is not a controller of personal data concerning the User, as it neither receives nor retains such data. The data resides on the Device, where the User may inspect it, correct it, export it in the form of a backup and erase it at any time, without recourse to any third party.
No request addressed to the Developer can therefore be executed in respect of data which the Developer does not hold. A request may nevertheless be addressed to the Developer, who will respond and explain the position.
Complaints
The User is entitled to lodge a complaint with the supervisory authority for data protection of the User's place of residence or place of work.
The User is invited, though not obliged, to raise the matter with the Developer first, so that it may be addressed directly.
Children
The Application is not directed at children under the age of 13 and is not intended for their use.
No personal data is knowingly collected from any person, and consequently none is collected from a child. Where a parent or guardian nevertheless believes that a matter requires attention, the Developer may be contacted at the address given in clause 2.
Amendment of this Policy
The Developer may amend this Policy, in particular where the functionality of the Application changes or where applicable law so requires.
The version in force is published at this address and bears the date of its entry into force. Material amendments are additionally notified within the Application.
Continued use of the Application after the entry into force of an amendment constitutes acknowledgement of the amended Policy.
This Policy is drawn up in English. Translations are provided for convenience only; in the event of divergence the English version prevails.
Contact
Questions and requests under this Policy shall be addressed to tesserly.dev@gmail.com. The Terms of Use govern all other aspects of the relationship between the User and the Developer.