2026-09-25

Privacy Policy for OTP Safe

Effective Date: September 2026

1. Controller

Mathias Todisco

Schleswiger Ufer 5

10555 Berlin

Germany

Email address: hello [at] todisco [dot] de

Phone: +49 179 8174113

Imprint: Imprint

2. Introduction

OTP Safe is an iOS app for securely managing two-factor authentication codes (TOTP and HOTP). The protection of your personal data is important to us. This privacy policy informs you about the processing of your data when using our app.

3. Data Processing

3.1 Local Data Storage

OTP Safe is a completely local app. We collect and process the following data:

OTP Accounts: Service name, username, secret key, algorithm, time interval
Categories: Self-created categorizations of your accounts
App Settings: Sorting, view preferences

Important:

All data is stored exclusively locally on your device
No cloud synchronization by the app - Your secrets are never transmitted to us or third parties. They are part of your encrypted iOS backup (iCloud Backup or an encrypted backup on your Mac/PC) and are transferred when you move to a new iPhone, so they are not lost
No trackers or analytics tools - We do not collect any usage data for advertising or marketing purposes
No advertising - The app is ad-free

3.2 Security Features

iOS Keychain: Sensitive data is stored encrypted in the iOS Keychain
Biometric Authentication: Face ID / Touch ID / Optic ID to unlock the app
Encrypted Export: AES-256 encryption for backup files

3.3 Camera Access (optional)

If you allow camera access, OTP Safe can scan QR codes to add new accounts. The scanned data is only processed locally and not transmitted.

3.4 File Access (optional)

When importing or exporting backups, the app accesses local files. This data is only processed locally.

3.5 Feedback Function (optional)

If you use the optional feedback function, the following data is transmitted to our server (api.todisco.de):

Required information: Category, subject, message, timestamp, language setting
Optional information: Email address (only if you provide it)
Device information (optional): Device model, iOS version, app version (only if you consent to transmission)

Important:

The feedback function is completely optional
Your OTP secrets and account data are never transmitted
The data is used exclusively to process your feedback
Processing takes place on servers in Germany

3.6 Error Reports (Crash and Error Telemetry)

To be able to fix bugs and crashes, the app transmits technical error reports in release builds to our self-hosted GlitchTip server at tip.todisco.de (hosted in Germany, no third-country transfer).

What is transmitted:

Crash reports: Stack traces, threading information, affected modules/functions
Error events: Error type, error message, timestamp, context tag (e.g. “BackupService.decrypt”)
Device context: Device model, iOS version, app version, free/available memory, language setting
Performance samples: ~1% of all app transactions (screen load times, navigation performance)
Breadcrumbs: Anonymized navigation steps (e.g. “Settings opened”, “Backup started”), to provide error context

What is NOT transmitted:

No OTP secrets (never part of an error report)
No account names (issuer/service name/username remain local)
No unique device IDs beyond what Sentry/GlitchTip automatically hashes (device-app-hash, no IDFA)

Technical details:

Based on the Sentry Cocoa SDK (open source)
Backend: GlitchTip (open-source alternative to Sentry), self-hosted by us in Germany
Session tracking is disabled
In DEBUG builds (development builds), events are tagged with environment “debug” and treated separately

Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in a functional, error-free app).

Retention: Error reports are stored for a maximum of 90 days and then automatically deleted.

Opt-out: In DEBUG builds, telemetry can be disabled via the environment variable OTP_DISABLE_TELEMETRY=1. For release builds, telemetry is active by design; if you do not want this, please uninstall the app.

4. Legal Basis for Processing

The processing of your data is based on the following legal grounds:

Art. 6 para. 1 lit. b GDPR (Contract fulfillment): Provision of app functions
Art. 6 para. 1 lit. a GDPR (Consent): Use of the optional feedback function
Art. 6 para. 1 lit. f GDPR (Legitimate interest): Error reports to ensure app functionality

5. Data Sharing

Your OTP data is not shared with third parties. Network communication only occurs with our own servers in Germany: api.todisco.de (feedback) and tip.todisco.de (error reports). Your OTP secrets and account data are never transmitted.

6. Data Storage and Deletion

6.1 Storage Duration

Your data is stored locally on your device as long as you use the app. You have full control over your data at all times.

6.2 Deletion

You can delete your data at any time:

Individual Accounts: Delete in the app
Categories: Delete in the app
All Data: Uninstall the app from your device

7. Your Rights

You have the following rights:

Right of Access (Art. 15 GDPR): All data is directly viewable in the app
Right to Rectification (Art. 16 GDPR): Edit accounts directly in the app
Right to Erasure (Art. 17 GDPR): Delete data directly in the app
Right to Data Portability (Art. 20 GDPR): Export your data encrypted
Right to Lodge a Complaint: With the competent data protection supervisory authority

8. Data Security

We take appropriate technical and organizational measures to protect your data:

Local storage under iOS security mechanisms
Encrypted storage in iOS Keychain
Biometric protection (Face ID / Touch ID / Optic ID)
AES-256 encrypted backups
Minimal network communication (only optional feedback function)

iOS Security: Your data benefits from iOS sandboxing and device encryption.

9. No Profiling

There is no automated decision-making or profiling according to Art. 22 GDPR.

10. Changes to this Privacy Policy

We reserve the right to update this privacy policy to reflect changes in law or app features. The current version can always be found at:

https://todisco.de/en/otp-privacy

11. Contact

For privacy questions, contact us at:

Email: hello [at] todisco [dot] de

Address: Mathias Todisco, Schleswiger Ufer 5, 10555 Berlin, Germany

Note for users outside the EU:

This privacy policy is primarily based on the EU General Data Protection Regulation (GDPR). Users from other regions may have corresponding rights under local privacy laws.