This Privacy Policy (the “Policy”) describes what data is processed when using the visa-vis mobile application for iOS and its web version, provided as a PWA (together, the “App” or the “Service”), as well as the User’s rights with respect to that data.
This Policy is an integral part of the User Agreement and applies together with it.
Operator: Aleksei Sinkov
Email: ao.sinkov@gmail.com
App identifier: app.visavis.ios
1. General Provisions
1.1. This Policy is drafted as a single document applicable to Users regardless of their country of location, since the Service is distributed through an international platform (the App Store) without geographic restrictions.
1.2. Where the law applicable to a particular User (including data protection law of the User’s country) establishes additional or stricter requirements than those set out in this Policy, such requirements apply — to the extent binding on the Operator — in addition to this Policy.
1.3. By using the Service, the User confirms that they have read this Policy.
2. Key Feature of Data Processing in the Service
2.1. The Service is designed as a predominantly offline app: the bulk of the User’s data (profile, passports, trips, visas, tickets, settings) is stored locally on the User’s device and is not transmitted to the Operator or to any server as part of the normal use of these features.
2.2. Account registration is not required and is not offered for the Service’s core features.
2.3. The Service does not use third-party advertising trackers or analytics SDKs to track User behavior, unless otherwise expressly stated in the current version of this Policy.
2.4. The only regular network activity built into the Service’s core logic is the optional download of reference catalogs (see Section 4.3). Any other network requests (should they appear in future versions, for example for paid features) will be described in an updated version of this Policy before being introduced.
2.5. The public website of the Service (separate from the iOS App) may, after the visitor consents, use a Google Analytics cookie solely to count visits to the website. The iOS App does not use cookies or Google Analytics. The visitor may refuse the cookie; in that case the website does not set it.
3. What Data Is Processed
3.1. Data the User enters themselves, stored locally
- profile data: name, citizenship, country of residence;
- data for up to two passports: number (if entered by the User), issue and expiry dates;
- trip data: entry/exit dates, country, city, mode of transport, border crossing point, notes, intermediate stops;
- visa data: type, validity period, number of entries, day limit;
-
ticket and boarding-pass data, including data obtained by scanning a barcode with the
camera, from a photo, from booking text, or from an Apple Wallet
.pkpassfile; - user settings: interface language, enabled reminders, demo mode.
All of the data listed above is entered, edited, and deleted by the User themselves and, by default, does not leave the User’s device.
3.2. Technical data related to network requests
When the User uses the reference-catalog download feature (Section 4.3), the server from which the download is made may record standard technical request data, including:
- IP address;
- User-Agent and other technical characteristics of the request;
- the date and time of the request;
- the fact and type of catalog requested.
Such data is recorded at the level of the server/hosting infrastructure as part of its normal operation (request logs), is used to ensure the operability and security of that infrastructure, and is not linked by the Operator to the User’s profile, passport data, trips, or other information stored locally on the User’s device.
3.3. Data the Service does not collect
The Service does not request or use the User’s geolocation. The Service does not collect data for advertising targeting purposes and does not use third-party analytics SDKs, unless otherwise expressly stated in the current version of this Policy.
4. Purposes of Data Processing
4.1. The data referred to in Section 3.1 is processed exclusively locally on the User’s device for the purpose of providing the Service’s functionality: tracking passports, trips, visas, and tickets; calculating length of stay; and generating reminders and statistics.
4.2. The technical data referred to in Section 3.2 is processed for the purposes of:
- ensuring the operability and availability of the reference catalogs;
- protecting the server infrastructure from abuse and technical failures.
4.3. Downloading reference catalogs (the extended catalog of visa rules, the Passport Index slice for the selected passport) is performed at the User’s initiative or in the background to update the built-in rules, and does not require transmitting to the Operator any data about the User’s profile, passports, trips, or other locally stored information — the request is limited to obtaining reference data.
5. Legal Bases for Processing
5.1. Processing of the data referred to in Section 3.1 is based on the fact that the User independently enters this data in order to use functionality they themselves choose, and the data does not leave the User’s device.
5.2. Processing of the technical data referred to in Section 3.2 is carried out on the basis of the legitimate interest of the Operator and the operator of the server infrastructure in ensuring the operability, stability, and security of the reference catalogs provided.
5.3. Where applicable law requires a different legal basis for particular processing operations, the Operator ensures an appropriate basis to the extent necessary to comply with such law.
6. Device Permissions (iOS)
For certain features, the Service may request the following permissions. Each permission is requested only when the User attempts to use the corresponding feature, and the User may decline the permission, thereby limiting the use of that feature.
6.1. Camera
Used to scan boarding-pass barcodes. The Service does not save or transmit the camera image itself outside the device; data obtained through scanning is processed as data referred to in Section 3.1.
6.2. Calendar
Used to add events and reminders to a separate “visa-vis” calendar on the device, if the User has enabled the corresponding feature. The Service does not read or analyze other calendar events of the User that are unrelated to “visa-vis.”
6.3. Notifications
Used to display local reminders (passport expiry, visa expiry, the departure date under a limit, an upcoming flight). Such reminders are generated and displayed locally on the device, without the involvement of the Operator’s server.
6.4. Location
Not requested and not used.
7. Disclosure of Data to Third Parties
7.1. The Operator does not sell User data to third parties.
7.2. Because the User’s core data (Section 3.1) is stored locally, it is not, by default, disclosed by the Operator to third parties.
7.3. Technical request data (Section 3.2) is processed by the infrastructure that supports the reference catalogs, including a hosting provider and/or a content delivery network (CDN) provider, to the extent necessary for the technical operation of that infrastructure.
7.4. The reference catalogs downloaded by the User may be compiled from open and/or aggregated sources of visa-requirement data. Such downloading is one-directional (the User receives reference data) and does not involve transmitting the User’s personal data to the owners of those sources.
7.5. Because the App is distributed through the Apple App Store, Apple Inc. may independently process certain data (for example, installation, purchase, and device technical data) during the installation, update, and operation of the App, in accordance with Apple’s own privacy policy, which is not governed by this document.
7.6. The public website may disclose technical visit data to Google LLC through Google Analytics if the visitor consents, as described in Section 2.5. The iOS App does not.
7.7. Except as set out in this Section, the Service does not disclose User data to other third parties, advertising networks, or analytics services.
8. International Data Transfers
8.1. The server infrastructure that supports the reference catalogs may be located in a country other than the User’s country of location.
8.2. When reference catalogs are downloaded, the technical request data (Section 3.2) may accordingly be processed on servers located outside the User’s country. The Operator takes reasonable measures to ensure that such processing is consistent with the purposes described in this Policy.
8.3. The data referred to in Section 3.1 is stored locally on the User’s device and is not subject to cross-border transfer by the Operator, unless the User independently transmits it (for example, by exporting a backup file and forwarding it on their own initiative).
9. Data Retention and Deletion
9.1. The data referred to in Section 3.1 is stored on the User’s device until the User deletes it themselves, uses the clearing feature within the App, or deletes the App from the device.
9.2. The feature for clearing trips, visas, and tickets within the App deletes the corresponding data but does not delete the profile and passport data, unless the User separately deletes it by other means.
9.3. Deleting the App from the device results in the deletion of all locally stored User data, unless the User has previously created a backup via the export feature. The Operator has no technical means of recovering such data, as it is not stored on the Operator’s side.
9.4. Technical request data (Section 3.2) is retained for the period necessary for the purposes referred to in Section 4.2, in accordance with the standard log-retention practices of the hosting provider and/or CDN provider.
10. User Rights
10.1. Because the User’s core data (Section 3.1) is stored locally and remains under the User’s direct control, most typical data rights are exercised by the User directly, through the App’s functionality:
- access and review — the User can view all entered data within the App at any time;
- correction — the User can edit any data they have entered;
- deletion — the User can delete individual records, use the clearing feature (Section 9.2), or delete the App entirely (Section 9.3);
- export (portability) — the User can create a backup in JSON format and transfer the data as needed.
10.2. With respect to technical request data (Section 3.2), which the User cannot modify directly through the App’s interface, the User may contact the Operator using the contact details in Section 13 with questions about the scope and retention period of such data.
10.3. If the law applicable to the User provides for additional rights regarding the processing of personal data (for example, the right to restrict processing, the right to object, or the right to lodge a complaint with the data protection authority of the User’s country), the User may exercise such rights to the extent provided by that law by contacting the Operator using the contact details in Section 13.
11. Children
11.1. The Service does not impose age restrictions on use beyond those that may be set by the App’s age rating in the App Store and by applicable law governing the User’s legal capacity (see also Section 16 of the User Agreement).
11.2. Because the Service, by default, does not require registration and does not collect the User’s data on the Operator’s server, any data entered by a child is stored locally on the device and remains under the same controls described in Section 10 — including the control of a parent or legal guardian, where the device is used under their supervision.
11.3. A parent or legal guardian who believes that a child has entered data into the App raising privacy concerns may delete the relevant data directly within the App (Section 10.1) or contact the Operator using the contact details in Section 13.
12. Security
12.1. Because the User’s core data is stored locally, its protection substantially depends on the security measures of the User’s own device — screen lock, device encryption, and the safekeeping and protection of any backup the User has independently created (Section 8.7 of the User Agreement).
12.2. The Operator takes reasonable organizational and technical measures to protect the technical data processed by the server infrastructure (Section 3.2) from unauthorized access, alteration, disclosure, or destruction.
12.3. No method of data storage or transmission is completely secure. The Operator cannot guarantee absolute protection of data against all possible threats.
13. Contact Information
For questions regarding this Policy, data processing, or the exercise of the rights referred to in Section 10:
visa-vis
Identifier: app.visavis.ios
Operator: Aleksei Sinkov
Email: ao.sinkov@gmail.com
Website:
https://travel-kappa-green.vercel.app/
14. Changes to This Policy
14.1. The Operator may amend this Policy, including in connection with changes to the Service’s functionality or applicable law.
14.2. A new version will be published in the App, on the website, or by other available means, indicating the revision date.
14.3. Continued use of the Service after a new version takes effect constitutes agreement with the amended Policy, unless otherwise provided by applicable law.
Effective date: 2026.09.18