Who is responsible
The controller for the personal data described in this policy is Eutopix Labs Prosta Spółka Akcyjna (P.S.A.), ul. Hoża 86/410, 00-682 Warszawa, Poland, registered in the National Court Register (KRS) under number 0001237465 by Sąd Rejonowy dla m.st. Warszawy w Warszawie, XII Wydział Gospodarczy KRS; NIP 7011310736; EU VAT PL7011310736; REGON 544584646; share capital PLN 20,000 (“Eutopix Labs”, “we”). Privacy questions and rights requests: privacy@eutopixlabs.io. General support: support@pubharbor.app.
This policy covers the PubHarbor app for iPhone, iPad and Mac (including its Quick Look extension), the pubharbor.app website, and support correspondence.
Data handled by the app
Documents and exports (on your device only)
When you select a Publisher file, PubHarbor reads and converts it on your device. The document, extracted text, images, previews, compatibility report and exports are not sent to Eutopix Labs or anyone else. Exports are written only to a location you choose. Because this content never reaches us, we cannot see, access or recover it; it stays under your control and you can delete it at any time.
Recent files, free previews and preferences (on your device only)
PubHarbor stores recent-file references, file metadata, free-preview accounting and app preferences locally. On Apple platforms, recent files use security-scoped bookmarks so the app can reopen a file you selected, and free-preview accounting is kept in the device Keychain. Clearing the recent-file library removes those references but never deletes the source document. This data is removed when you delete the app (Keychain items may remain on the device until the system removes them).
Optional trial reminder (on your device only)
If a free trial is offered and you start it, you can choose to turn on a reminder before the trial ends. The app then asks for notification permission and schedules a local notification on your device. No reminder data is sent to us, and the reminder is removed if the subscription ends, is refunded or will not renew.
Purchases
Apple processes PubHarbor Pro purchases: the auto-renewing monthly and yearly subscriptions and the one-time lifetime purchase. PubHarbor receives the product, transaction, entitlement and refund status that StoreKit provides so it can unlock, restore or revoke Pro; it does not receive your name, Apple Account email or payment-card details. Apple may also provide Eutopix Labs with aggregated App Store sales, tax and financial reports. Apple’s handling of purchase data is governed by Apple’s privacy policy and your Apple Account settings.
Apple ad attribution (iOS App Store version)
PubHarbor shows no ads, does not use the advertising identifier (IDFA), never shows an App Tracking Transparency (ATT) prompt and does not track you across other companies’ apps or websites. Apple’s own measurement: if you install PubHarbor after tapping an Apple Ads advertisement, Apple may count the install and attribute it to that ad using its own App Store measurement. Apple is responsible for that processing; see Apple’s privacy policy (apple.com/legal/privacy). From the first update of PubHarbor released after 14 October 2026, the app sends no SKAdNetwork or AdAttributionKit conversion value in the EU/EEA, the UK or Switzerland. Earlier versions may send the coarse, aggregate value described below in every country. Outside these regions (and, in earlier versions, everywhere), the App Store version for iPhone and iPad may send a coarse, aggregate conversion value through Apple’s SKAdNetwork/AdAttributionKit: a number from 0 to 3 describing progress during the first 35 days after installation (opened the app, first successful use, viewed plans, unlocked Pro). It contains no identifier, no IDFA and nothing about you, and no ATT prompt is shown. Apple passes it on delayed and combined with other installs; Eutopix Labs receives only aggregated postbacks that identify no one. Legal basis for those regions: our legitimate interest in measuring our own advertising (Art. 6(1)(f) GDPR where applicable). The Mac version does not use these frameworks.
Local diagnostics
PubHarbor can keep Apple-provided crash and performance diagnostics (MetricKit) and fixed technical event codes on your device to help troubleshoot problems. These reports can include technical details such as app and operating-system versions, timestamps and crash stacks. The app does not add document contents, filenames or file paths to its event records, and does not upload these reports. Local retention is bounded to 14 days and 16 report files, with a maximum of 1 MiB per report; cleanup runs when the app accesses diagnostics. In Diagnostics, you can delete local reports or export a JSON report to a location you choose. Review an exported report before sending it to support; exported copies are not removed by the cleanup, and the destination you choose controls them. Apple’s own device-analytics settings separately govern what you share with Apple.
Usage analytics
Current versions of PubHarbor do not send usage analytics or telemetry to Eutopix Labs. The app contains a switched-off option for basic first-party usage counts that is not active. If we ever turn it on, it will be off by default, it will ask for your consent in the app, and this policy and the App Store privacy label will describe it before it is enabled.
What we do not collect
- No account, profile, contact list, location or device advertising identifier.
- No document content, extracted text, page images, filenames or export contents.
- No third-party analytics, advertising, crash-reporting or session-recording SDK.
- No cross-app or cross-site tracking.
Support email
If you email support, we receive your email address, your message, any technical details and the attachments you intentionally send. Do not attach a confidential publication unless support explicitly asks for it and you have the right to share it. Our email is hosted by Soverin.
This website
This site uses no analytics, advertising pixels, third-party fonts, forms, cookies or browser storage set by us. Cloudflare hosts the site and may process basic request data, such as IP address, browser information, time and requested URL, to deliver and secure it; Cloudflare may set a strictly necessary security cookie if it presents a security challenge. Some links to the App Store include a campaign label for a referring AI search service when your browser provides that information; no cookies, local storage, conversation addresses or visitor identifiers are used, and Apple controls reporting availability and aggregation. We do not combine website request data with app activity.
Purposes, legal bases and retention
- On-device document processing, recent files, previews, trial reminder: performed on your device to provide the features you use; Eutopix Labs receives none of it. Kept on your device until you delete it or the app.
- Purchases and entitlement: performance of the purchase contract (Art. 6(1)(b) GDPR) and legal obligations for tax and accounting (Art. 6(1)(c)). Apple’s sales and financial reports are kept for as long as Polish accounting and tax law require — usually 5 years from the end of the calendar year in which the related tax fell due (Accounting Act art. 74; Tax Ordinance arts. 70 and 86). App purchases are sold by Apple, so your purchases do not appear in our accounting records.
- Apple ad attribution (outside the EU/EEA, the UK and Switzerland; in versions released up to 14 October 2026, everywhere): our legitimate interest in measuring, in aggregate and without identifying anyone, whether advertising leads to installs and use (Art. 6(1)(f)). The coarse value stays on your device until the measurement windows end; Apple’s postbacks are governed by Apple and the advertising network.
- Local diagnostics: kept on your device for at most 14 days; sent to us only if you choose to export and send a report, which is then handled as support correspondence.
- Support correspondence: steps you request and performance of our contract with you (Art. 6(1)(b)) and our legitimate interest in answering, securing and improving PubHarbor (Art. 6(1)(f)). Normally deleted 24 months after the last exchange, unless it is still needed for an unresolved request, a legal claim or a legal obligation.
- Website delivery and security: our legitimate interest in providing a reliable and secure website (Art. 6(1)(f)). Request and security logs are retained by Cloudflare only for its operational and security needs under its terms.
- Legal claims and requests from authorities: legal obligation (Art. 6(1)(c)) or our legitimate interest in establishing, exercising or defending legal claims (Art. 6(1)(f)), for as long as the matter requires.
We do not use profiling or automated decision-making that produces legal or similarly significant effects.
Recipients and international transfers
We share personal data only with: Apple (App Store, StoreKit purchases and ad attribution, under Apple’s own terms as an independent controller); Cloudflare (website hosting and security); Soverin (support email hosting); professional advisers where necessary; and authorities where the law requires it. Apple and Cloudflare may process data outside the European Economic Area, including in the United States. Where that happens, transfers rely on the EU–US Data Privacy Framework where the recipient is certified, or on the European Commission’s Standard Contractual Clauses (and the UK equivalents). Contact us for more information about the safeguard relevant to your data.
Your rights and choices
Under the GDPR and UK GDPR you have the right to access, rectify and erase your personal data, to restrict or object to processing (including processing based on legitimate interests), to data portability, and to withdraw any consent at any time without affecting earlier processing. Send requests to privacy@eutopixlabs.io; we may need to verify your identity and normally respond within one month. Data that exists only on your device, such as documents, recent files, diagnostics and preferences, is not available to us: you can view and delete it yourself in the app, in the Files app or Finder, or by deleting the app. You can turn off notifications in your device settings.
You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl. You may also complain to the authority in the country where you live or work.
California and other US state privacy laws
We do not sell or share personal information, as those terms are defined by the California Consumer Privacy Act as amended by the CPRA and similar US state laws, and we do not use or disclose sensitive personal information. In the past 12 months the only categories we may have collected are identifiers and the content of your messages when you email support, and internet activity such as IP address and request data processed by Cloudflare when you visit this website. We use them only for the purposes described above. You may ask to know, correct or delete your personal information at privacy@eutopixlabs.io, and we will not discriminate against you for exercising these rights.
Do Not Track: this site and our apps do not track you across third-party sites or services, so they behave the same whether or not your browser sends a Do Not Track or Global Privacy Control signal.
Children
PubHarbor is a general productivity tool and is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has sent us personal data, contact us and we will delete it.
Security and changes
We use technical and organisational safeguards appropriate to the limited data we process; no system can be guaranteed completely secure. We may revise this policy when the app or the law changes; the effective date at the top identifies the current version, and material changes will be announced where the law requires.
Changelog: 14 October 2026 — added full controller details, Apple ad attribution, trial reminders, legal bases and retention per purpose, transfers, US state law and complaint details; clarified that usage analytics are not active in current versions.
14 October 2026 (update): Apple ad measurement by region, accounting-record retention and Do Not Track clarified.