No. Data processor has a special meaning (at least under GDPR) and requires you to be a separate entity from the data controller (article 4(8) of GDPR). Just be

No. Data processor has a special meaning (at least under GDPR) and requires you to be a separate entity from the data controller (article 4(8) of GDPR). Just because you process data, will not make you a data processor. A software developer is neither a controller, nor a data processor per se, but the question is why the software processes any personal data. If there is no third person on whose behalf you process data, you might still easily be a data controller and all the privacy related obligations primarily rest on this role. Controllership does not depend on sending any data to remote locations/other apps outside the phone etc., but more on whether there is any personal data processed in the app at all and if there is, the reason for that processing. If you're not processing any personal data, you'll not be a controller, but if you do, you'll be unlikely to be able to skip this responsibility altogether. Considering you'll be the only one knowing exactly what your software can and cannot do with what kind of personal data, you'd better at least explain that to the user. Surely, developers of some software (e.g. compilers) will never be data controllers even if the software can compile software to process personal data... But for many frontend software, like apps, there is no such easy way out unless not processing any personal data at all, including usage data, which is also not an easy thing to do. But that doesn't mean you can just skip the obligation towards the store manageer who says you HAVE to provide a privacy policy even if you don't process any personal data. Similarly, processing for "purely personal or household activity", even by automated means is outside the scope of GDPR in EU, but that will not save you from the privacy policy obligation towards Apple or whomever.