Privacy Policy
Last revised: 26 June 2026
We take the protection of your personal data seriously. This Privacy Policy explains what data we process when you use the Be The Meme app (the "App") and website (https://bethememe.app), and your rights under the EU General Data Protection Regulation (GDPR).
1. Controller
The controller responsible for data processing is:
Kochhannstr. 30, 10429 Berlin, Germany
Email: support@bethememe.app
We are not legally required to appoint a Data Protection Officer.
2. The short version
- Your photos, camera captures, audio recordings, and the meme clips you create are stored on your device. We do not upload them, and we cannot see them.
- We do not sell your data, show third-party ads, or track you across apps or websites. We do not use the Advertising Identifier (IDFA).
- The only data that leaves your device does so to (a) process a purchase, (b) download additional meme packs, and (c) submit a content report if you choose to.
3. Data we process
3.1 On-device content (not collected by us)
Your camera captures, microphone audio, best-frame stills, composed clips and reels are created and stored locally on your device (in the App's storage and, only when you choose "Save", in your Photos library). We have no access to this content. Granting Camera, Microphone and Photos permissions enables features on your device; it does not transmit anything to us.
3.2 Device & settings data (on-device)
The App stores your settings and progress locally (e.g. sound/haptics preferences, streak and progression counters, your optional @handle for watermarks). A random, anonymous installation identifier is generated and stored on your device to operate the App. This stays on your device unless an enabled service below requires it.
3.3 Purchases — RevenueCat & Apple
When you buy a subscription or the lifetime upgrade, the transaction is processed by Apple (App Store). We use RevenueCat, Inc. as our subscription-management processor to validate your purchase, determine your entitlement (Premium vs free), and enable "Restore Purchases". RevenueCat receives your purchase/transaction data and an anonymous app-user ID. We do not receive your Apple ID, name, or payment-card details. (RevenueCat privacy: revenuecat.com/privacy)
3.4 Content delivery — Cloudflare
Additional meme packs and images are delivered from our content storage on Cloudflare R2 / CDN. When the App downloads content, Cloudflare processes standard technical connection data (e.g. IP address, request headers) to serve the files and for security. (Cloudflare privacy)
3.5 Content reports
If you choose to report content (e.g. a copyright or inappropriate-content complaint), the App opens a pre-filled email to us. When you send it, we receive the report reason, your optional note, any content identifier or pack/meme name included in the email, the App version and your device's anonymous installation ID — plus your email address, since you send it from your own mail app — which we use to review and act on the report.
3.6 Analytics
The App does not include a third-party analytics or tracking SDK. We do not collect in-app behavioural analytics, and we do not use advertising tracking or the Advertising Identifier (IDFA). For overall performance we rely only on the aggregate, anonymised statistics that Apple (App Store Connect) and RevenueCat already provide from app distribution and purchases; we receive these as reports, and they do not involve any tracking code running on your device. If we later add privacy-friendly product analytics (for example PostHog Cloud EU, using anonymous events only), we will update this Policy first and obtain any consent required by law before enabling it.
3.7 Website
Our website (https://bethememe.app) is hosted on Cloudflare Pages, which processes standard server and connection data (e.g. IP address, request headers) to deliver the pages and for security. To understand aggregate traffic (such as page views, referrers, country and browser type) we use Cloudflare Web Analytics, which is privacy-friendly and cookieless: it does not set cookies, does not store or read information on your device, and does not track you across websites or build a profile of you. Our website does not set advertising or tracking cookies.
4. Purposes and legal bases (GDPR Art. 6)
| Processing | Purpose | Legal basis |
|---|---|---|
| Operating the App on your device | Provide the Service you requested | Art. 6(1)(b) — contract |
| Purchases / entitlements (Apple, RevenueCat) | Process and restore purchases | Art. 6(1)(b) — contract |
| Content delivery (Cloudflare) | Deliver meme packs you requested | Art. 6(1)(b) — contract |
| Content reports | Review and act on reports; protect rights | Art. 6(1)(c)/(f) — legal obligation / legitimate interest |
| Security & abuse prevention | Keep the Service safe | Art. 6(1)(f) — legitimate interest |
| Website analytics (Cloudflare, cookieless) | Understand aggregate website traffic | Art. 6(1)(f) — legitimate interest |
Where local law requires consent for analytics, we will obtain it via an in-app prompt before enabling it.
5. Recipients / processors
We use the following service providers, who process data on our behalf or as independent controllers for their part of the service: Apple (app distribution, payments), RevenueCat (subscription management), and Cloudflare (content storage/CDN, website hosting, and cookieless website analytics). We conclude data-processing agreements where required. We do not sell personal data and do not share it with advertising networks. We do not currently use a third-party product-analytics provider in the App.
6. International transfers
Some providers may process data outside the EU/EEA (e.g. in the USA). Where they do, transfers are safeguarded by appropriate measures such as the EU Standard Contractual Clauses and/or the EU–US Data Privacy Framework.
7. Retention
On-device data remains until you delete it or uninstall the App. Purchase/entitlement records are retained by Apple and RevenueCat per their policies and for as long as needed to provide Premium and meet legal/accounting obligations. Content reports are retained as long as needed to handle them and document our response. Anonymous analytics are retained in aggregate.
8. Your rights
Under the GDPR you have the right to access, rectification, erasure, restriction, data portability, and objection, and the right to lodge a complaint with a supervisory authority. Because most data stays on your device, you can exercise erasure directly by deleting clips in the App or uninstalling it. For requests concerning data held by us or our processors, contact support@bethememe.app. You can withdraw any consent at any time with future effect.
You can manage device permissions (Camera, Microphone, Photos, Notifications) at any time in iOS Settings. You can manage or cancel subscriptions in your Apple ID Account Settings.
9. Children
Be The Meme is not directed to children under the age required by the App Store age rating in your region. We do not knowingly collect personal data from children.
10. Changes to this policy
We may update this Privacy Policy to reflect changes in the App or the law. The current version is always available at https://bethememe.app/privacy.