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As the app developer you clearly control the means of processing, you are the data controller. You may have opted for “offline processing” which simplifies your
by isodev 2y ago
As the app developer you clearly control the means of processing, you are the data controller. You may have opted for “offline processing” which simplifies your compliance, but it is still processing under your control (and subject to change in future updates, which needs to come with a change to your data processing policy with informed user consent).
- tempfile 2y agoIt is certainly not processing under your control. You don't do anything with the data - none of your computers are involved, you never see or read or copy anyone's data whatsoever. The data subject is processing their own data, using a tool they perhaps don't understand (if the source code is unavailable, for example). The user is at liberty to start or stop the processing at any time. I don't even think this would apply in the pathological case where a bug in the app causes the personal data to be leaked. You didn't leak it, the user did.