Privacy Policy

1. Introduction

ClutterScrub ("the App") is a privacy-first storage cleaner for Android developed by ToTheTower Labs LLC ("we," "us," or "our"), a California-based company. This Privacy Policy explains how we handle information in connection with your use of ClutterScrub. By using the App, you acknowledge that you have read and understood this Privacy Policy.

ClutterScrub is designed around a core principle: your files never leave your device. The App does not hold Android's internet permission, so Android's permission system blocks it from opening network connections. We do not operate servers that receive data from the App, we do not maintain user accounts, and we have no way to see your files, your apps, or anything you do in the App. Apart from what Google Play shows every developer (Section 3.5), the only information about you that reaches us is what you choose to send us yourself, such as an email (Section 3.6).

This Privacy Policy is written to meet the notice requirements of the California Online Privacy Protection Act (CalOPPA), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the EU General Data Protection Regulation (GDPR), and other applicable privacy laws worldwide.

This policy covers the App, our website at clutterscrub.com, and messages you send us. It does not cover Google Play, your email provider, or other apps and websites, which have their own policies.

2. Data Controller Information

For purposes of the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and other applicable data protection laws, the data controller is:

ToTheTower Labs LLC
2108 N ST #15629
Sacramento, CA, United States
Email: info@tothetowerlabs.com

We do not currently have a Data Protection Officer. If you have questions about data protection, please contact us at the email address above.

EU/UK Representative (GDPR Article 27): The App collects no personal data and performs no processing that leaves your device. The only personal data we handle is correspondence you choose to send us (Section 3.6) and the limited information Google Play shows every developer (Section 3.5): occasional, including no large-scale processing of special categories of data or of data about criminal convictions, and unlikely to result in a risk to your rights and freedoms. On that basis we have not appointed an EU/UK representative under Article 27(2)(a) of the GDPR and the UK GDPR. If this changes, we will update this section with our appointed representative's contact information. In the meantime, you may direct any inquiries to our contact email above.

3. Information We Collect

3.1 The App Collects Nothing

In this policy, information is "collected" when it leaves your device and reaches us or anyone acting for us. Information the App only reads or keeps on your device is not collected; Sections 3.2 and 3.3 describe it.

ClutterScrub collects no data of any kind. Specifically, the App does not collect:

• Your files or their contents. Everything the App does with your photos, videos, audio and other media (sorting them into categories, finding exact copies and similar photos, judging sharpness and exposure, adding up their sizes) happens on your device. The App never uploads a file, a thumbnail or anything computed from one, and it hands a file to another app only when you ask it to (Section 8).
• The list of your files or your apps. The names, folders, sizes and dates the App reads, and the list of apps it shows once you allow Usage access, stay on your device.
• Usage analytics or behavioral data. The App contains no analytics or telemetry of any kind. We do not know what you scan, what you remove, how much space you clear, or how often you open the App, unless you tell us yourself.
• Crash reports. The App contains no crash-reporting service. Release builds write only technical warnings and errors to Android's own system log, which stays on your device, which ordinary apps cannot read, and which the App never sends anywhere.
• Advertising identifiers. The App contains no ads and no ad-related tracking.
• Location data. The App does not request your location. It also does not hold the permission Android requires to read the location stored inside photos, so Android withholds that location from the App.
• Your messages, contacts or calendar. The App reviews media files that messaging apps have saved to your device's shared storage, such as the photos in a messaging app's media folder. It never reads your chats, your contacts, your calendar or your call log.
• Account credentials. There is no user account or login system.
• Payment information. Purchases are processed entirely by Google Play (see Section 3.5). We never receive or store payment details.

This is enforced by the App's technical design, not only by this policy: the App does not declare the Android internet permission, so the operating system blocks it from opening network connections. If a future version of the App were ever to change what it collects, we would update this policy before releasing that version.

The only ways information about you can reach us are through Google Play's developer tools (Section 3.5) and an email you choose to send us (Section 3.6).

3.2 What the App Reads on Your Device

To do its job, the App reads the following on your device. None of it leaves your device:

• Your media library, through the media permission you grant (Section 5): each file's name, folder, size, type, dates, dimensions and length, as Android's media store reports them. From the folder a file sits in and its name, the App works out its category, for example a screenshot, a screen recording, or media a messaging app saved, and whether that media was sent or received.
• The contents of your files, only to compare them. To find exact copies, the App computes a fingerprint of the file's bytes (a SHA-256 hash) for files that share a size. To find similar photos and photos that look blurry, too dark or too bright, it computes a small fingerprint from a tiny grayscale copy of each photo, a sharpness measure, and the share of the photo that is close to black or close to white.
• Your device's storage figures: the total and free space, and the space Android counts for each kind of media.
• Your apps, only if you allow Usage access (Section 5): the apps that show an icon in your launcher, the space each one, its data and its cache take, and when you last used each one, along with the storage figures of the whole profile. The App reads these from Android when a screen needs them, holds them in memory while it runs, and never writes them to storage.
• Android's trash: the files you moved to the trash with the App, so its Trash screen can show them and offer to restore them.

3.3 Data Stored Locally on Your Device

The App stores the following in its private storage area, solely to make the App work. This data never leaves your device and is not accessible to us:

• A scan index. For each media file, the details listed in Section 3.2 and the fingerprints and measures computed from it, so that the next scan only reads what has changed; and a record of each scan (when it ran and the totals per category). An entry for a file that is gone is dropped at the next scan.
• Your cleanup rules. The name, folder, type and age each rule covers, whether it is paused, and when it last ran and how many files it moved to the trash.
• Settings. Your theme, the sizes from which a file counts as large, how alike two photos must be to count as similar, whether the weekly reminder is on and the growth that triggers it, the months you have finished in the swipe review, a running total of the space the App has cleared, and whether setup is complete.
• Free tier and purchase status (only in the free edition with the Pro upgrade). How many of the free removals you have used, and a flag recording that Pro is unlocked, with the purchase token and purchase time Google Play issued, so that Pro keeps working offline. The authoritative record of your purchase belongs to your Google account and is managed by Google Play.

Thumbnails come from the thumbnail cache Android itself keeps for your media; the App holds the images it shows in memory only.

The App opts out of Android's cloud backup and device-to-device transfer, so Android does not copy this data off your device in a backup or a transfer to a new device. Uninstalling the App, or clearing its storage in Android's settings, deletes all of it.

3.4 Removing Files

The App never removes a file on its own. Every move to the trash, every restore and every permanent delete is a request to Android, and Android asks you to confirm it before anything changes. A file in the trash can be restored until Android deletes it for good when its time in the trash runs out (30 days by default). A cleanup rule never runs by itself: the weekly reminder only tells you that a rule has files ready, and running a rule shows you its files first.

3.5 Google Play

Buying the App. ClutterScrub is sold on Google Play either as a paid app that includes every feature, or as a free app with an optional one-time Pro upgrade bought inside the App, depending on how it is listed when you get it. Either way, the purchase is handled by the Google Play Store application and Google Play services on your device, not by ClutterScrub, and no server of ours is involved. Google does not give us your name, email address, payment method, or street address.

• If you bought the App itself, the App receives nothing about your purchase: the paid edition contains no billing component at all.
• If you buy the Pro upgrade in the free edition, Google Play gives the App a confirmation that the purchase completed, with a purchase token, which the App keeps on your device (Section 3.3). Completing or restoring a purchase requires your device to have an internet connection; that connection is used by the Google Play Store app, not by ClutterScrub. The App holds no network permission and makes no network connections; it communicates with the Play Store app only through Android's on-device inter-process mechanisms. Every other feature of the App works with no connectivity at all.

Like every developer on Google Play, we can also see some information through Google's developer tools: reviews you choose to post publicly on Google Play (with the name and device details Google shows beside them), crash and freeze reports that Google collects from devices whose owners allow diagnostics to be shared (these name a device model and Android version, not a person), and records of purchases (the order number and date, and the postal code, state and country Google records for the purchase). Google collects this information under its own privacy policy; the App plays no part in it. We use it only to answer reviews, fix problems and keep our business records.

Google's handling of your payment information is governed by the Google Privacy Policy and the Google Play Terms of Service.

3.6 If You Email Us

The App contains no contact form and sends nothing to us. If you write to us at either address in Section 15, we receive what you send: your email address and the name your email account shows, your message, anything you attach, and the routing information every email carries. We use it to answer you, to look into and fix what you report (including letting you know when a fix ships), and to consider any idea you suggest. We never add you to a mailing list or write to you about anything else, and we disclose your correspondence only as Section 8 describes.

Email is not end-to-end encrypted unless both you and we use a service that does this, so send only what you would put in an ordinary email. If you attach a screenshot of the App, check first that it shows nothing you would rather keep private, such as the names of your files or photos.

You can ask us to delete your correspondence at any time, by replying in the same conversation or writing to info@tothetowerlabs.com, and we will, unless we must keep a particular message to meet a legal obligation or to establish or defend a legal claim (for example, a notice under our Terms of Service). Section 10 says how long we otherwise keep it.

3.7 Our Website

When you visit our website, clutterscrub.com, it sets no cookies and runs no analytics, advertising, or third-party scripts; its fonts and images are served from the site itself, and we keep no logs or other records of your visits. Like every website, it receives your device's IP address while it sends you a page, because that is how the page reaches you. Links to Google Play and other sites take you to services governed by their own policies.

4. Legal Basis for Processing (GDPR)

Under the GDPR, a legal basis is required for processing personal data. ClutterScrub does not collect, transmit, or process personal data off your device, so the App itself involves no such processing and needs no legal basis. If you email us (Section 3.6), we process what you send to answer you and to look into what you report, on the basis of our legitimate interest in answering people who contact us and fixing the problems they report (Article 6(1)(f)); where your message concerns a purchase, to deal with it (Article 6(1)(b)); and where we must keep a message to meet a legal obligation, on that basis (Article 6(1)(c)). We use what Google Play shows us (Section 3.5) on the basis of the same legitimate interest, and our website handles your IP address only to send you the pages you request (Section 3.7), on the basis of our legitimate interest in running the site. You may object at any time (Section 11).

All scanning and analysis happens locally on your device at your direction. Data processed locally on your own device by software acting solely under your control does not involve us as a controller or processor of that data.

5. Device Permissions

ClutterScrub requests the minimum permissions its features need:

• Photos and videos, and music and audio (Android 13 and later), or storage (Android 11 and 12). Read access to your media, so the App can find and show what takes up space. Android 14 and later let you allow only the photos and videos you select; the App then sees only those, and says so. Reading is all this permission allows: every removal still needs your confirmation in Android's own dialog (Section 3.4).
• Notifications (Android 13 and later). Asked only when you turn on the weekly reminder, which notifies you when your media has grown by more than the amount you chose, or when a cleanup rule has files ready for the trash.
• Usage access (optional). A special access you turn on yourself in Android's settings; the App offers it from its storage card and never asks for it during setup. It lets the App see how much space each app takes and when you last used it (Section 3.2). Everything else works without it, and you can turn it off at any time in Android's settings.
• Seeing your apps. Android lets the App see the apps that show an icon in your launcher, to list them on its Apps screen. The App does not request the permission to see every installed app.
• Background work. The weekly reminder runs through Android's standard background job library, which declares the permissions to finish a job once it has started and to keep the reminder's schedule after the device restarts. They give the App no access to your data.
• Google Play billing (free edition only). The permission to ask the Play Store for a purchase, and the permission to check whether the device is online, which Google's billing library declares. Neither lets the App connect to the internet.

The App does not request: internet or any network access, All files access, an accessibility service, media management (which would let an app skip the confirmation dialog), location, camera, microphone, contacts, calendar, phone, SMS, or the permission to see every installed app.

6. On-Device Processing

All of the App's functionality runs locally on your device:

• Categories come from where a file sits and what it is called: screenshot and screen recording folders, the media folders of messaging apps, and the file's type.
• Exact copies are found by comparing the fingerprints of files of the same size, first over their first and last parts, then over their whole content.
• Similar photos, and photos that look blurry, too dark or too bright, are found from the small fingerprints and measures described in Section 3.2. The App also flags photos with a low resolution from their dimensions alone. In each group of copies or similar photos, the App suggests which one to keep (the oldest copy, preferring the camera roll, or the sharpest photo); you can choose another.
• The App does not recognize faces, people, objects or text in your photos, and it contains no machine-learning model. It compares fingerprints and measures only, and it does not create, collect, or use biometric identifiers or biometric information, such as face geometry or voiceprints.
• Your files are never modified. The App does not edit any file. It only asks Android to move a file to the trash, restore it, or delete it for good, and Android asks you to confirm each request.

7. Data Storage and Security

The App collects no data, so there is no App data on any server to secure. Email you choose to send us is kept in our business mailbox, hosted by Proton AG in Switzerland, which stores messages with zero-access encryption. The data described in Section 3.3 is stored in the App's private storage area, which Android shields from other applications, and is excluded from backups.

No method of transmitting or storing information is completely secure. Email in particular passes through your own provider and the internet before it reaches us, so we cannot guarantee its security in transit.

8. Data Sharing and Disclosure

We do not sell, rent, trade, or otherwise share personal information, and we do not use it for targeted advertising. The App gives us none. The personal information we hold is limited to email you choose to send us (Section 3.6) and what Google Play shows every developer (Section 3.5). We disclose it only: to the provider that hosts our mailbox, which handles it on our behalf (Section 7); where we believe in good faith that the law, a court order, or legal process requires it; to protect the rights, property, or safety of ToTheTower Labs LLC, our users, or others, or to enforce our Terms of Service; or as part of a merger, acquisition, financing, reorganization, or sale of all or part of our business, in which case this policy continues to apply to it. Because the App sends us nothing, no such disclosure can include your files or anything the App reads on your device, apart from what you have chosen to send us yourself.

The App hands something to another app only when you ask it to: a file you open from a review screen goes to the viewer app you pick, with permission to read that one file; a row on the Apps screen, the Usage access offer and the App's Open Settings button each open the matching page of Android's settings; and a link in this policy or in the Terms of Service opens in your browser. The app you pick receives what it is handed under its own privacy policy.

9. International Data Transfers

The App transfers no data internationally, or anywhere, because no data leaves your device. If you email us, your message is stored by our email provider, Proton AG, in Switzerland, and read and answered by us in the United States, where ToTheTower Labs LLC is based. It travels there because you sent it to us, and it is used only as Section 3.6 describes. Our website is delivered from servers our hosting provider operates, which may be in a country other than yours.

10. Data Retention and Deletion

• Your files: never retained by us in any form, unless you attach one to an email you send us, which we keep only as that email is kept (below). Files you move to the trash stay in Android's trash until you restore them or Android deletes them (Section 3.4).
• The scan index: kept on your device and refreshed at every scan; an entry for a file that is gone is dropped then.
• Settings and cleanup rules: kept on your device until you change or delete them in the App, or uninstall it.
• Email you send us: kept in our mailbox only until the matter you wrote about is closed (for example, once a problem you reported is fixed and we have told you), then deleted; deleted sooner whenever you ask, with the exceptions in Section 3.6. Notes we keep to track a reported problem describe the problem and the device, never your name or email address.
• Purchase records: maintained by Google Play under your Google account, per Google's policies. The free edition's local record of your Pro purchase is deleted on uninstall and restored on demand through "Restore purchases."

To delete everything the App has stored, uninstall the App or clear its storage in Android's settings. Neither reaches email you have sent us; to have that deleted, ask us (Section 11).

11. Your Privacy Rights

Privacy laws such as the GDPR (EU/UK), CCPA/CPRA (California), and similar laws elsewhere grant rights including access, correction, deletion, restriction of processing, portability, and objection to processing.

Apart from email you choose to send us (Section 3.6) and what Google Play shows every developer (Section 3.5), we hold no personal data about you, so for everything the App does, every right these laws protect is satisfied structurally: your data stays with you. For email you have sent us, you can ask for a copy, a correction or deletion, or object to our keeping it.

To make any privacy request, write to info@tothetowerlabs.com, or simply reply in the conversation you started at support@tothetowerlabs.com. To protect your correspondence, we act on a request about an email address only when it comes from that address. We will respond within the time required by applicable law (one month under the GDPR, extendable where the law allows; 45 days under the CCPA/CPRA). For information Google holds, such as a review you posted, Google's own tools and privacy policy apply.

California residents: The CCPA/CPRA applies only to businesses that meet thresholds of revenue or data volume. Whether or not it applies to us, we describe our practices here. We do not sell or share personal information as defined by the CCPA/CPRA, and we have not done so in the preceding 12 months. The App collects no personal information. If you email us, we collect from you the personal information you choose to send: identifiers (your name and email address as your email shows them) and the contents of your message, which may include device information, commercial information if you write about a purchase, and files you attach. We use it for the purposes in Section 3.6, disclose it only as Section 8 describes, and keep it as Section 10 describes. Our website keeps no record of your visits (Section 3.7). Through Google Play's developer tools (Section 3.5) we also see the postal code, state and country Google records for a purchase, and the name and device details shown with a public review; Google collects these, and we use them only as Section 3.5 describes. We do not use or disclose sensitive personal information for any purpose that would give you a right to limit it. You will not be discriminated against for exercising privacy rights.

EU/UK residents: You have the right to lodge a complaint with your national supervisory authority. The European Data Protection Board keeps a directory of the EU authorities; the UK authority is the Information Commissioner's Office.

12. Children's Privacy

The App is intended for people aged 16 and older (see our Terms of Service), and it is not directed at children under 13 (or the equivalent minimum age in your jurisdiction). The App collects no data at all, so no child's personal information can be collected through it. If we learn that an email came from a child under 13 (or that equivalent age), we use it only to reply and then delete it; a parent or guardian may also ask us to delete it at any time.

13. Third-Party Services Summary

• Google Play. Sells the App, or processes the optional one-time Pro upgrade in the free edition. Payment is handled entirely by Google; the App receives at most a confirmation of the Pro purchase (Section 3.5).
• Google Play Console (Google's developer tools). Shows us public reviews, crash and freeze reports, and purchase records, which Google collects under its own privacy policy (Section 3.5).
• Proton Mail (our email provider). Hosts our support and info mailboxes, which hold email you choose to send us, stored encrypted in Switzerland (Section 7).
• Our website's hosting provider. Serves the pages of clutterscrub.com, which keeps no record of your visits (Section 3.7).

That is the complete list. The App itself contains no analytics SDK, no crash-reporting SDK, no advertising SDK, and no other third-party service.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated "Last Updated" date and, where appropriate, notice in the App or its store listing. Because the App cannot transmit data, no change to this policy can retroactively affect data already on your device: there is nothing to re-purpose. Email you have already sent us will not be used for a new purpose under a revised policy without your consent.

If you keep using the App after a change takes effect, the revised policy applies to your use.

15. Contact

To reach us:

ToTheTower Labs LLC
2108 N ST #15629
Sacramento, CA, United States
Email: info@tothetowerlabs.com, for privacy questions and requests, and legal notices
Support: support@tothetowerlabs.com, for help with the App, problem reports and ideas

We read both, so a privacy request sent to either will be handled.

16. Supplemental Notices

Do Not Track: The App and our website do not track you over time or across other apps and websites, so they respond to Do Not Track and Global Privacy Control signals in the same way as to any other visit: there is no tracking for such a signal to turn off.

Nevada residents: We do not sell covered information as defined by Nevada Revised Statutes Chapter 603A.

Virginia, Colorado, Connecticut, Utah, and other US state residents: The App does not collect personal data as defined by your state's consumer privacy law. Beyond what you choose to send us (Section 3.6) and what Google Play shows every developer (Section 3.5), we process no personal data, and we never sell or share it or process data for targeted advertising or profiling.

Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act): The statements in this policy apply globally: the App collects no personal data regardless of your jurisdiction, and what reaches us is handled as Sections 3.5 and 3.6 describe.