This document is in English.

Vaultron Privacy Policy

Last updated: 24 October 2026

1. Introduction

Vaultron is an iPhone and iPad app that keeps photos, videos, files and notes in an encrypted vault protected by an unlock pattern.

Vaultron is designed to process as little data as possible. It has no user accounts, no servers of its own, no advertising and no analytics or tracking tools. Vault content is encrypted on your device and is never sent to us.

This Policy explains what data is processed, by whom, on what legal basis and what rights you have, in line with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and applicable Portuguese law.

2. Controller

The controller of the personal data described in this Policy is:

  • Controller: Thundera Group CISO, contact: legal@thundera.eu

The controller is established in the European Union, in Portugal.

3. Data processed and legal bases

3.1 Data that stays on your device only

Your photos, videos, files, notes, thumbnails, file and folder names, encryption keys and app settings are stored on your device, encrypted with AES-256-GCM. We have no access to this data and do not receive it. The unlock pattern and the recovery phrase are not stored by the app.

Because this data is processed only by you and on your device, we are not in a position to access it, to identify it, or to provide support relating to it. Managing the files, the backups and everything stored on the user's device is the user's own responsibility.

3.2 Encrypted iCloud backup

Vaultron backup is on by default and can be switched off in the app's Settings. When on, Vaultron stores an encrypted copy of your content in the private database of your own iCloud (CloudKit), tied to your Apple account. By default, backup runs over Wi-Fi only.

  • The data is sent already encrypted. The key that opens it depends on the 24-word recovery phrase, which only you know.
  • This data is held by Apple, under your iCloud account and Apple's terms and privacy policy.
  • We have no access to this data or its key and cannot decrypt it.
  • Backup depends on your Apple account, the available iCloud storage, your connection and your settings. We have no visibility of its status and cannot check, repair or restore it for you. It is up to you to confirm that the backup has completed (the app shows the time of the last backup).

3.3 Anonymous error reports

In Settings → Diagnostics, the "Share errors anonymously" option is on by default. While it is on, iOS provides the app with crash, hang and performance reports, which Vaultron reduces on the device to only the following:

  • app and iOS version;
  • device model and processor architecture;
  • error type, code and name;
  • timings;
  • where in Vaultron's code the error happened.

Reports do not include files, notes, names, location, or any account, device or installation identifier. Dates are cut to the day.

Reports are kept on the device, protected by the system and excluded from device backups, up to a maximum of 20. They are not sent automatically. We receive them only if you tap "Send to support", which opens an email message that you can read and edit before sending. If you switch the option off, stored reports are deleted.

Legal basis: your consent (Article 6(1)(a) GDPR), given when you send the report. You can withdraw it at any time without affecting the lawfulness of earlier processing.

3.4 Support contacts

If you contact us by email, we process your email address, the content of your message and any attachments you send (including error reports), only to answer your request.

Legal bases: steps taken at your request or to perform a contract with you (Article 6(1)(b)) and, for the processing needed to manage support, our legitimate interest in answering requests and improving the app (Article 6(1)(f)).

3.5 Purchases and subscriptions

Purchases and subscriptions are processed exclusively by Apple through StoreKit. We do not receive or process your payment details, your name or your Apple account. The app only checks with the system whether you are entitled to Pro features.

Apple provides us with aggregated sales reports that do not identify you personally. Where necessary, we process transaction information to comply with legal obligations, in particular tax and accounting obligations (Article 6(1)(c)).

3.6 Private vault sharing

You can create a .vaultron file with selected items and send it to someone through the system sharing options (for example AirDrop, Messages or Files). The file is created and encrypted on your device, with a six-word passphrase that you give to the recipient, and it does not pass through any server of ours.

  • Location and capture metadata (for example GPS, device make and model, creation date) is removed from shared photos and videos. Documents are copied as they are, so metadata inside them (for example a PDF's author) stays. The app tells you this.
  • With Pro, you can set an expiry date, a maximum number of opens and whether the recipient may export items. These rules are enforced by the recipient's Vaultron app and not by encryption: a determined recipient can copy what they can see, for example with a screenshot.
  • The number of times a received vault has been opened is recorded only on the recipient's device.

You are responsible for choosing the recipients and the items you share.

3.7 Access to photos, camera and motion

  • Photos and files: the app accesses only the items you choose to import. Write access to the photo library is requested only if you turn on the option to delete originals after import.
  • Camera: captures made in the app go directly into the vault and are not saved to the photo library.
  • Shake to lock: while a vault is open, the app reads the accelerometer to detect a sharp movement and lock the vault (not the device). Each reading is checked in memory and discarded; nothing is stored or sent.

3.8 Website

The vaultron.thundera.eu website uses a strictly functional cookie (vaultron_lang) and browser local storage to remember your chosen language. The website's hosting may log usual technical connection data, such as the IP address, for security and operation (legal basis: legitimate interest, Article 6(1)(f)). The Thundera navigation bar, loaded from thundera.eu, may make a read-only request to auth.thundera.eu, a domain of ours, to check whether the visitor already has a Thundera session; Vaultron has no accounts. The "A product of Thundera Group" link in the app's Settings only opens the thundera.eu page, with no parameters or identifiers, and the app receives nothing back.

4. What we do not collect

Vaultron does not:

  • require an account, name, email address or phone number;
  • send us photos, videos, files, notes, names, patterns, keys or the recovery phrase;
  • contain advertising;
  • contain third-party analytics, tracking or advertising tools;
  • record your location or access your contacts;
  • use analytics tools on the website, beyond what is described in section 3.8;
  • sell or share personal data with third parties for commercial purposes;
  • make automated decisions or build profiles.

5. Storage and security

  • Content is encrypted on the device with AES-256-GCM, with a random key per vault and per file. Keys are protected by a key derived from the unlock pattern using a slow derivation (PBKDF2-HMAC-SHA256) and are kept in the device Keychain, protected by Apple's hardware.
  • Vault files have random names and iOS complete data protection, and are not included in device backups.
  • The iCloud backup contains only encrypted data.
  • Additional protections include automatic locking, a privacy screen in the app switcher, protection against screenshots and screen recording, a delay after failed attempts, and decoy and duress vaults.
  • No system is absolutely secure. We do not guarantee that encryption will withstand every form of attack, in particular a compromised operating system, malware on the device, or direct observation of the screen or pattern.

Loss of the pattern and recovery phrase

There is no pattern reset. Because we never have access to the keys, neither we nor Apple can recover a vault without the pattern or the recovery phrase. If you lose both the pattern and the recovery phrase, or lose your device without having a backup and the phrase, the data cannot be recovered.

Losing, replacing or factory-resetting the device, or deleting the app, deletes the app's local data. A restore from iCloud may fail or be incomplete for reasons beyond our control (for example a network or iCloud failure); the app lists the vaults it could not restore, but we cannot recover what iCloud does not return.

The security of the content also depends on the device: a jailbroken device, a device with malware or an outdated operating system, or one that third parties can access (for example because they know the device passcode), may compromise the vault, and we have no technical means to prevent it. Decoy and duress vaults are privacy tools and do not guarantee the user's physical safety.

6. International transfers

The app does not send us personal data and we do not operate app servers. The vaultron.thundera.eu website is hosted on Amazon Web Services infrastructure, including its content delivery network, which may process technical connection data (such as the IP address) outside the European Economic Area, in particular in the United States, under the appropriate safeguards provided for in the GDPR.

Apple, which provides the iCloud and App Store services and is responsible for the processing it carries out, may process data in countries outside the European Economic Area, under its own policies and the appropriate safeguards provided for in the GDPR, such as standard contractual clauses. The backup data Apple holds is encrypted and we cannot decrypt it.

Emails you send us are handled through the email provider we use, which may be subject to equivalent safeguards.

7. Retention

  • Vault content and settings: kept on the device until you delete them, delete the app or use "Erase everything on this device". In some situations iOS keeps Keychain items from a previous installation; without the vault files, these items do not give access to any content.
  • iCloud backup: kept in your iCloud account until you delete it in iOS Settings → your Apple account → iCloud → Manage Account Storage. Deleting content or the app on the device does not automatically delete the backup.
  • Error reports stored on the device: up to 20, deleted when you switch the option off.
  • Support emails and reports sent to us: kept for as long as needed to answer the request and handle any complaints, and then deleted.
  • Transaction information: for the period required by applicable tax and accounting law.

8. Your rights

Under the GDPR, you have the right to:

  • access your personal data and obtain a copy;
  • have it rectified;
  • have it erased;
  • restrict processing;
  • object to processing based on legitimate interest;
  • receive the data you provided to us in a structured, commonly used format (portability);
  • withdraw consent at any time.

To exercise these rights, contact us at legal@thundera.eu. We will reply within one month, which may be extended as permitted by law. We may ask for additional information to confirm your identity.

Because we have no access to the content of your vault or your backups, we cannot access, rectify, export or delete that content, and we have no means of linking it to a person. That data can only be accessed, exported or deleted by you, on your device and in your iCloud account, and the right to portability is exercised through the app's export functions. We reply only about the few data we actually hold: the support messages and error reports you sent us. Purchase and payment data is processed by Apple, and you should contact Apple about it. If we cannot identify you in our records, we will tell you, as provided in Article 11 GDPR.

You also have the right to lodge a complaint with the supervisory authority, the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados, CNPD): www.cnpd.pt.

9. Children

Vaultron is not aimed at children and does not knowingly collect personal data from children. In Portugal, consent-based processing in information society services is valid only from age 13. In-app purchases are made through the Apple account and depend on Apple's rules and on the legal capacity to contract; minors should make purchases only with the authorisation of a parent or legal guardian. If you become aware that a minor has sent us personal data without authorisation, contact us and we will delete it.

10. Third-party services and links

Vaultron does not include third-party services, libraries or tools that process users' data. The only external services the app uses are Apple's: iCloud (CloudKit), for backup and sync, and the App Store (StoreKit), for purchases and subscriptions. Support email is sent through the user's own mail app, which shows us the sender's address. For website hosting (Amazon Web Services) and for email we use providers that process data on our behalf as processors, under a contract pursuant to Article 28 GDPR.

The app and the website contain links to Apple pages and to the thundera.eu website. We do not control the content or privacy practices of third parties.

11. Requests from authorities

We have no access to vault content, keys, patterns or recovery phrases, so we cannot provide them to anyone, even under a legal order. We can only respond to lawfully grounded requests about the few data we actually hold (for example, support messages and error reports that you sent). We also cannot help anyone, including authorities, to unlock or decrypt a vault. We will disclose the data we hold only where the law requires it, to the extent strictly necessary and, where permitted, informing the data subject. Data held by Apple, including encrypted iCloud backups, is subject to Apple's procedures.

12. Personal data breaches

If a personal data breach occurs affecting data we process, we will notify the CNPD and the affected individuals in the cases and within the time limits required by the GDPR. Because we have no access to vault content, we can only notify about the data we hold; breaches affecting the user's device, Apple account or Apple's systems are outside our control.

13. Changes to this Policy

We may update this Policy to reflect changes to the app or the law. The current version is always available at https://vaultron.thundera.eu/privacy, with the date of the last update. For material changes, we will inform users in the app or on the website before they take effect.

14. Contact

For privacy questions or to exercise your rights:

  • Controller: Thundera Group CISO, contact: legal@thundera.eu
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