Privacy Policy
This policy explains what happens to personal data in connection with the Skilloo app and the skilloo.com website. The short answer, unusual for an AI product, is: almost nothing — and everything that does happen is listed here, completely.
1. Controller
The controller responsible for the processing described in this policy is:
Skilloo GmbH
Sophie-Ressl-Weg 13
84034 Landshut
Germany
Managing Director: Christian Haas
Email: info@skilloo.com
Phone: +49 (0) 151 44244386
Full company details are in the Impressum (legal notice). Skilloo GmbH has not appointed a data protection officer, as none is legally required.
2. The app collects no personal data
The Skilloo app collects no personal data. This is not a promise bolted onto the product afterwards; it is the product's architecture:
- No account. Skilloo requires no registration, no email address, and no login.
- No Skilloo servers. Voice synthesis and storage of your content happen on your device; AI generation runs where you chose — on your device, or on Apple’s Private Cloud Compute (section 3.7). There is no Skilloo backend your data could be sent to.
- No tracking, no analytics upload, no third-party SDKs. The app transmits no usage data, no crash reports, and no advertising or tracking identifiers to Skilloo GmbH or anyone else. The technical connection data (such as your device’s IP address) that necessarily accompanies the network features listed in section 3 is described there.
- An empty App Store privacy label. Skilloo’s privacy label states “Data Not Collected” because there is nothing to declare.
The app does open network connections — today in exactly six precisely defined situations (sections 3.1–3.5 and 3.7), each visible to and controlled by you. Section 3 lists them completely and, for completeness, adds two further entries: the strictly local diagnostics feature that involves no transfer at all (section 3.6) and the Apple Watch app, which exchanges data only between your own devices (section 3.8). None of them gives Skilloo GmbH access to your personal data. This section describes the app; the skilloo.com website is covered in section 5.
3. Network connections of the app — the complete list
3.1 iCloud sync (optional, PRO)
Sync is off by default and is part of Skilloo PRO. If you enable it, the app synchronizes your content into the private database of your own Apple iCloud account.
| Data | Your Skilloo content (such as experts, hubs, settings, and generated media), transferred between your device and your personal iCloud account. |
|---|---|
| Purpose | Keeping your content in sync across your own devices. |
| Legal basis | Consent, Art. 6(1)(a) GDPR. You enable sync yourself and can turn it off again at any time in the app (Art. 7(3) GDPR). |
| Recipient | Apple, as the operator of your iCloud account, under your own agreement with Apple. The data resides in the private database of your account. Skilloo GmbH has no access to it — technically none, not merely as a matter of policy. |
| Storage | In your iCloud account, under your control, until you delete the content or disable sync. Skilloo GmbH stores nothing. |
3.2 Voice-model downloads
Skilloo’s voices run entirely on the device. The voice models themselves are downloaded on demand through Apple’s Background Assets service.
| Data | The technical request data needed to deliver the download — including your device’s IP address — transmitted to Apple’s content-delivery infrastructure. |
|---|---|
| Purpose | Downloading voice models so that speech synthesis can run on your device. |
| Legal basis | Art. 6(1)(b) GDPR — the download is necessary to provide the function you request. |
| Recipient | Apple (Background Assets / content-delivery network), which processes these requests under its own privacy terms. |
| Storage | Skilloo GmbH stores nothing. The downloaded model is stored locally on your device. |
3.3 Purchases through the App Store
Skilloo PRO is available exclusively as an auto-renewable in-app purchase through Apple’s App Store. The entire purchase runs with Apple.
| Data | Purchase and subscription data, processed entirely by Apple. The app itself only learns whether an active subscription exists. |
|---|---|
| Purpose | Concluding, providing, and managing your subscription, including restoring purchases. |
| Legal basis | Art. 6(1)(b) GDPR — performance of the contract. |
| Recipient | Apple, as the seller of record for App Store purchases and an independent controller. Skilloo GmbH never receives your payment data — no card numbers, no billing address, no bank details. |
| Storage | Your subscription status is stored locally on your device. Payment data remains with Apple under Apple’s terms. |
3.4 Web tools with per-use consent
Some AI tools can, at your request, open a specific website on the open web. This never happens automatically: every single access requires your explicit consent, each time.
| Data | Your device connects directly to the website you chose, which — as with any website visit — sees your device’s IP address and the technical request. |
|---|---|
| Purpose | Executing the specific web tool you invoked. |
| Legal basis | Consent, Art. 6(1)(a) GDPR, granted per individual use. If you decline, the tool simply does not access the web. |
| Recipient | The website chosen in the individual case. Its operator is responsible for its own processing under its own privacy policy. |
| Storage | Retrieved results are stored only locally on your device. Skilloo GmbH stores nothing. |
3.5 Apple Newsroom feed
The app can display current headlines from Apple’s public newsroom feed.
| Data | A technical request (including your device’s IP address) to Apple’s public RSS feed. |
|---|---|
| Purpose | Displaying current Apple news within the app. |
| Legal basis | Art. 6(1)(b) GDPR — delivering the content this feature shows when you use it. |
| Recipient | Apple, which processes the request under its own privacy terms. |
| Storage | Nothing beyond the local display on your device. Skilloo GmbH stores nothing. |
3.6 Optional diagnostics — local only
Diagnostics are off by default. This is the rare case of a diagnostics feature with no upload at all.
| Data | If enabled, the app stores MetricKit summaries provided by the operating system: aggregate performance and stability metrics. No content, no conversations, no identity data. |
|---|---|
| Purpose | Making the app’s performance and stability visible on the device itself, for example to help troubleshoot a problem. |
| Legal basis | Consent, Art. 6(1)(a) GDPR. Diagnostics can be turned off at any time in the app’s settings (Art. 7(3) GDPR). |
| Recipient | None. The data never leaves the device. It is not transmitted to Skilloo GmbH or to anyone else. |
| Storage | Only locally on the device; removed at the latest when the app is deleted. |
3.7 Private Cloud Compute (Apple)
AI generation in Skilloo can run on Apple’s Private Cloud Compute — Apple’s server infrastructure for Apple Intelligence. Whether it does is your own decision: during setup the app asks explicitly where your experts should think and recommends Private Cloud Compute; the choice can be changed at any time under Settings → AI Status and is not tied to a subscription. If you choose “On this device only”, no AI request leaves your device. This is the only situation in which AI processing leaves the device; voice synthesis, images, videos and the storage of all your content stay on the device in every case.
| Data | The content of the specific AI request: your messages, the definition of the experts and hubs involved (roles, experiences, talking points, topics), excerpts of the conversation so far and — only where you granted a tool the corresponding permission — the details that tool contributes (such as calendar events, contacts, location or photo descriptions). Skilloo adds no identifier; the connection runs through Apple’s system and carries its technical connection data. |
|---|---|
| Purpose | AI generation with a larger model than the one available on the device. |
| Legal basis | Art. 6(1)(b) GDPR — providing a function you expressly enable after prior notice and can switch off again at any time. |
| Recipient | Apple (Private Cloud Compute). Under Apple’s published commitments, request data is not stored, is not accessible to anyone — not even Apple —, is not used for training, and the security architecture is publicly documented and open to independent verification (Apple Security Research). Apple processes the request under its privacy terms for Apple Intelligence; Skilloo GmbH receives neither the request nor the result. |
| Storage | Under Apple’s design, requests are processed transiently and not retained. The result is stored only on your device. |
| Fallback | If Private Cloud Compute is unreachable, throttled or too slow, the app finishes that one request on your device; your chosen setting stays unchanged, and the origin is recorded on the message or session. |
| Quota | Apple limits the daily use of Private Cloud Compute per user. Once the limit is reached, generation runs on your device until the reset; Settings → AI Status shows the status. |
3.8 Apple Watch — only between your own devices
The optional Apple Watch app is a companion to Skilloo on your iPhone: it plays what your experts say and lets you ask them a question. For this, data moves only between your own paired devices.
| Data | From your iPhone to your Apple Watch: the names and roles of your experts, the titles and spoken text of messages and sessions, the voice generated for them and the avatar pictures. From your Apple Watch to your iPhone: a question you enter on the Watch, as text, and the information which messages you have listened to. The Watch app itself records no audio. |
|---|---|
| Purpose | Playing messages and sessions and asking questions on the Apple Watch. |
| Legal basis | Art. 6(1)(b) GDPR — providing the function you use. |
| Recipient | None. The transfer runs between your paired devices through the connection Apple provides between iPhone and Apple Watch; Skilloo GmbH receives nothing. If you dictate a question, the speech is recognized by the dictation of watchOS — a system function of Apple under Apple’s privacy terms; the Skilloo app receives only the resulting text. The answer is generated where you chose (section 3.7). |
| Storage | Only on your Apple Watch and your iPhone. The Watch keeps pictures and voice only as long as the expert or message they belong to is shown there; deleting the app removes them. |
4. Share links
Skilloo can create share links of the form https://skilloo.com/e/… and https://skilloo.com/h/…. The character string at the end is a randomly generated content ID. It contains no personal data — no device information, no user identifier, nothing that could identify you or the person you share it with. Opening such a link in a browser is an ordinary visit to this website, to which section 5 applies.
5. The skilloo.com website
5.1 Hosting and server logs
skilloo.com is a static website hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. IONOS processes data on our behalf as a processor; a data processing agreement under Art. 28 GDPR is in place.
When the site is accessed, the web server automatically processes technical access data in server logs: IP address, date and time of the request, requested resource, HTTP status, transferred data volume, referrer URL, and browser/operating-system identifier (user agent). The purpose is the reliable delivery of the website and its stability and security, including detecting and defending against attacks and misuse. The legal basis is Art. 6(1)(f) GDPR — our legitimate interest in a secure, functioning web presence. Log files are typically deleted within eight weeks at the latest, in line with IONOS’s log rotation. The logs are not merged with other data sources and are not used to identify visitors.
5.2 Storage in your browser — no cookies
This website sets no cookies and loads nothing from third parties — no external fonts, scripts, or images. It stores a small number of values directly in your browser:
skilloo-theme(localStorage): your chosen display mode (light/dark).skilloo-lang(localStorage): your chosen language.skilloo-entrance(sessionStorage): a flag ensuring the entrance animation plays only once per tab; it contains no personal data and is deleted when the tab is closed.skilloo-consent(localStorage): records the choice you make in the cookie banner, so that it can be honored on later visits.
These values remain in your browser and are never transmitted to us. Theme and language are strictly necessary preference storage under § 25(2) no. 2 of the German TDDDG and require no consent; the consent record is itself necessary to respect your decision; the entrance flag contains no personal data at all. Details are in the Cookie Policy.
5.3 Email contact
If you write to info@skilloo.com, we process the data you provide (your email address, the content of your message, and its metadata) to handle your enquiry. The legal basis is Art. 6(1)(b) GDPR where your enquiry relates to a contract or precedes one, and otherwise Art. 6(1)(f) GDPR — our legitimate interest in answering messages addressed to us. Correspondence is deleted once the matter is fully resolved, unless statutory retention duties (for example under commercial or tax law) require longer storage.
5.4 Analytics — currently none
This website currently uses no analytics, no reach measurement, and no tracking of any kind. If we activate reach measurement in the future, it will run only after consent given via the cookie banner (Art. 6(1)(a) GDPR, § 25(1) TDDDG), and the choice can be changed at any time via “Cookie settings” in the footer.
6. Recipients and third-country transfers
Personal data is disclosed only to the recipients named in this policy: IONOS as our processor for website hosting, and Apple as an independent controller for App Store purchases, voice-model delivery, your iCloud account, and Private Cloud Compute (section 3.7). Websites you access through the web tools of section 3.4 are chosen by you and are independent controllers of their own processing.
We do not initiate transfers of personal data to third countries. Where Apple processes data on its global infrastructure, that processing takes place within your own relationship with Apple and under Apple’s terms and safeguards. A request to Private Cloud Compute is sent only on your own explicit choice (section 3.7); Apple processes it under its published commitments and privacy terms, and Skilloo GmbH receives neither the request nor the result.
7. Your rights under the GDPR
First, the practical reality: because the app stores your content exclusively on your device, Skilloo GmbH generally holds no personal data about you as an app user at all. You exercise control directly — content can be deleted in the app, and deleting the app removes all locally stored data; if you have enabled iCloud sync (section 3.1), content already synced to your own iCloud account is not removed by deleting the app — delete it in the app beforehand or manage it in your iCloud settings. In the interest of transparency: the app does not yet offer a combined one-tap export of all data or a single “erase everything” control; deleting the app — together with any content synced to your iCloud account — remains the complete way to erase everything.
With regard to the data we do process (website server logs and email correspondence, section 5), you have the right to:
- access (Art. 15 GDPR),
- rectification (Art. 16 GDPR),
- erasure (Art. 17 GDPR),
- restriction of processing (Art. 18 GDPR),
- data portability (Art. 20 GDPR), and
- objection to processing (Art. 21 GDPR).
Right to object (Art. 21 GDPR): where processing is based on Art. 6(1)(f) GDPR — such as the website’s server logs — you may object at any time, on grounds relating to your particular situation.
Withdrawal of consent (Art. 7(3) GDPR): any consent you have given can be withdrawn at any time with effect for the future — in the app by turning off iCloud sync or diagnostics, or simply by not granting web-tool access again; in the iOS Settings app for system permissions; and on the website via the cookie settings. Withdrawal does not affect the lawfulness of processing carried out before it.
No obligation to provide data: you are under no statutory or contractual obligation to provide personal data. Visiting the website merely requires the technical access data described in section 5.1, without which the site cannot be delivered; providing an email address is necessary only if you wish to contact us and receive a reply (section 5.3).
Right to lodge a complaint: you may complain to a data protection supervisory authority, in particular in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. The authority competent for Skilloo GmbH is the Bavarian Data Protection Authority: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany.
No automated decision-making: Skilloo makes no decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR). The AI generation in Skilloo runs locally, serves entertainment, and decides nothing about anyone.
8. Age requirement: 18+
Skilloo is directed exclusively at adults; use of the app requires being at least 18 years old. The offering is not directed at children, and Skilloo GmbH does not knowingly collect or process personal data of minors — indeed, given the architecture described above, the app collects no personal data from anyone.
9. Information for users in the United States
Skilloo GmbH does not sell personal information and does not share it for cross-context behavioral advertising within the meaning of the CCPA/CPRA. The app collects no personal information in the first place, and the only personal information processed in connection with the website — server logs and email correspondence (sections 5.1 and 5.3) — is never sold or shared with anyone. No opt-out is required, because no sale or sharing occurs.
10. Changes to this policy
We will update this policy whenever the app or the website changes in a way that affects it — for example, before any activation of reach measurement (section 5.4); Private Cloud Compute (section 3.7) was activated with the version of 22 September 2026. The current version, with its date, is always published on this page. Material changes affecting the app are additionally presented in the app before they take effect.
11. Contact
Questions about privacy: info@skilloo.com, or by post to Skilloo GmbH, Sophie-Ressl-Weg 13, 84034 Landshut, Germany.