Privacy Policy

Last updated: May 1, 2026

Controller

Dr. Jeannot Muller Consulting & Publishing
Schillerstr. 41
80335 Munich, Germany

Data Processing in the SpiderLens App

SpiderLens is a portfolio analysis app that displays information about stock and ETF holdings of the SPDR MSCI ACWI IMI UCITS ETF based on publicly available data. When retrieving this data over the internet, connection data such as IP address, date/time of request, and user agent are technically processed. No user profiling takes place; there are no user accounts and no sale of personal data.

Purpose: Provision of portfolio data and app functionality (e.g., country allocation, sector breakdown, holdings analysis, historical price and drawdown analysis).
Legal Basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(f) GDPR (legitimate interest in secure, stable operation).

Local Data Storage and iCloud Sync

All portfolio configurations, snapshots, and settings are stored locally on your device. SpiderLens does not transmit your personal portfolio allocations or settings to any servers operated by us. If iCloud sync is enabled on your devices, the app uses Apple's iCloud infrastructure under your own Apple ID to synchronize data between your iPhone, iPad, Apple Watch, and Mac. We have no access to that data.

Diagnostics, Crash Reports, and Logs

If the app generates crash reports or diagnostic data, these are used exclusively for error analysis. Transmission to third parties only occurs if corresponding services are integrated.

Current Status: No third-party analytics. Should this change, this policy will be updated and providers will be named.

Recipients, Processors, and Third Country Transfers

In the course of app operation, the following categories of recipients may receive data:

Data providers for ETF NAV, historical prices, and holdings data (receipt of connection data when retrieving publicly available information).
Apple iCloud (when iCloud sync is enabled on your devices) for synchronizing data between your own Apple devices under your Apple ID.
Hosting/infrastructure providers for the website and support pages.
Server log and security services (e.g., to prevent attacks).

If providers outside the EU/EEA are used, transmission is based on appropriate safeguards (e.g., EU Standard Contractual Clauses). Upon request, we will inform you of the specific providers used.

Storage Duration

Personal data is only stored for as long as necessary for the stated purposes.

Server/access logs: regularly deleted, typically within 30-90 days.
Support communication via email: for processing the request and in accordance with legal retention requirements.

Your Rights

You have the right to access, rectification, erasure, restriction of processing, objection, and data portability in accordance with legal requirements. You also have the right to lodge a complaint with a data protection supervisory authority, particularly in the member state of your residence, workplace, or the place of alleged infringement.

Provision Requirements and Profiling

An internet connection is required to load NAV and holdings data. No automated decision-making including profiling within the meaning of Art. 22 GDPR takes place.

Children

The app is not specifically directed at children. No special categories of personal data according to Art. 9 GDPR are processed.

No User Accounts or Tracking

SpiderLens does not require user registration, does not create user accounts, and does not track your usage behavior. We do not collect analytics data about how you use the app. All portfolio configurations remain on your device or in your private iCloud account.

Changes to this Privacy Policy

We will update this privacy policy if processing or legal requirements change. The current version is always available at this URL. Significant changes will be highlighted in the app or on the website.

Contact

For privacy inquiries, please contact:
dr@jeannot-muller.com