As of: May 11, 2026

1. Controller

PC-Future GmbH
Senkenweg 11
86972 Schwabniederhofen, Germany
Email: apps@pc-future.de

2. Principle: Local data storage

All notebook content is stored exclusively on your device (Apple® SwiftData). No content is transmitted to the publisher's servers or to third parties — except for the cloud connections you actively use (section 4), the iCloud synchronisation for shared notebooks (section 5), the "Student notebook viewing" feature (section 6), and the playback of embedded external videos (section 7). Even in those cases, no data is transmitted to PC-Future GmbH servers unless you actively select the NiblyNotes server for "Student notebook viewing" — in which case only end-to-end encrypted data is stored. In all other respects, the app works fully offline.

The following data is stored locally on your device:

• Notebooks (title, cover colour, folder assignment, creation date)
• Notebook pages including handwriting, text boxes, images, shapes and PDF backgrounds
• Page backgrounds (lined, grid etc.) and margin settings
• Tool settings (last used stroke widths per tool)
• Folder structure for notebooks

3. Camera and photo library access

The app optionally requires access to the camera (to capture photos directly into notebook pages) and the photo library (to insert existing images). Captured or selected photos are only embedded in the current notebook and do not leave your device without your action.

4. Cloud connections (optional)

NiblyNotes offers the option to connect to educational cloud providers to import, export files or to create backups. A connection is only established when you actively log in to a provider. Supported are:

• BayernCloud Schule (ByCS) — a service of the Free State of Bavaria. Login is handled via the official ByCS sign-in procedure.
• Nextcloud — open-source cloud. Login via the official login flow v2 with app password.
• NetMan for Schools (H+H Software) — version 6 or later, REST interface with username/password authentication.

Credentials are stored exclusively in the iOS® Keychain of your device and do not leave your device. When sending, opening or backing up to a cloud, only the file you selected is transmitted to the server you configured. The app does not communicate with any third-party services.

5. Shared notebooks (iCloud® synchronisation)

The "shared notebooks" feature lets you share a notebook with other people who can view or edit it simultaneously. This uses Apple®'s iCloud® system exclusively (CloudKit):

• Synchronised notebook data is stored in your personal iCloud® and shared via Apple's infrastructure with the devices you invite.
• The publisher of the app has no access to shared notebook content.
• All participants need an Apple® account to share and join.
• When you end a share, a local copy of the notebook remains with every participant.
• Every participant decides via a "Publish" button when local changes are transmitted.
• A share can be granted as "Read only" or "Edit"; you can change the permission at any time.

6. Student notebook viewing (encrypted server)

The "Student notebook viewing" feature lets teachers view and comment on their students' notebook pages. Transmission goes through a server, but all data is end-to-end encrypted on the device beforehand — the server cannot read the content.

Who is responsible for the server?

NiblyNotes supports two operating models:

• School-owned server: The school runs a server on its own website (standard PHP web hosting is sufficient). In this case the school authority is the controller responsible for the server. The server code is provided by PC-Future free of charge.
• NiblyNotes server in Germany: Anyone who does not want to run their own server can use the server we (PC-Future GmbH) operate. It is hosted in a data centre in Germany (GDPR-compliant hosting).

In both cases only encrypted data is transmitted to the server — see the next section.

Which data is transmitted?

• Notebook pages (encrypted) — the last X pages of notebooks shared by the student (X is set by the teacher, typically 1–20)
• Teacher annotations (encrypted) — the layer drawn with the Apple Pencil®
• Class and teacher names, student name, notebook title (encrypted) — as accompanying data for display in the other app

The server only stores encrypted data blocks and non-meaningful identifiers (random UUID strings). No clear-text names, class names or notebook titles are stored on the server.

Encryption

• Algorithm: AES-256-GCM (Authenticated Encryption with Associated Data) — industry standard, approved for the transmission of sensitive data by both the US NIST and the German BSI
• Key management: A 256-bit key is generated per class on the teacher's iPad. The key travels via the QR code directly to the iPads of the students who scan it. It does not leave the iPad through any server connection — the server never knows the key.
• Authentication: Authorisation is proven via an HMAC-SHA-256 value derived from the key (TOFU procedure). The authentication token also does not allow the server to decrypt the content.

Storage duration

Data on the server is automatically deleted after 90 days of inactivity. As soon as a class or notebook share is ended in the app, the teacher can additionally remove the corresponding data from the server manually.

Responsibilities of the deploying school

For pedagogical use with minor students, the data-protection responsibility for obtaining the necessary consents — and for choosing a suitable server — lies with the deploying teacher or the school authority. In this constellation, PC-Future GmbH is either a processor (when our NiblyNotes server is used) or not involved at all (when a school-owned server is used).

On request, PC-Future GmbH provides a data processing agreement (DPA) for the operation of the NiblyNotes server.

7. Embedding External Videos (e.g. YouTube)

NiblyNotes lets users embed references to external videos in a notebook, in particular from the YouTube platform. The videos themselves are neither stored on PC-Future GmbH's servers nor processed by the app.

When inserting a video link, only a neutral placeholder is created on the notebook page. At this point, no connection is made to YouTube or Google. Inserting the link is privacy-neutral.

When playing a video, your iPad establishes a direct connection to the video provider. In doing so, personal data — in particular your IP address — is transmitted to the provider. Data processing by the provider is governed by its own privacy policy. PC-Future GmbH has no influence over what data the provider collects or how it is processed.

For YouTube, NiblyNotes uses the most privacy-friendly embed mode the provider offers — the so-called "Privacy-Enhanced Mode" via the domain youtube-nocookie.com. In this mode, no tracking cookies are set before active playback. The connection is only established when the user taps "Play".

Before the first external video is inserted, the app displays a privacy notice that must be actively confirmed by the user.

Transmission to external displays

If you have a projector or Apple TV® connected and stream the video to the external display via the full-screen button in the player, the data connection still runs only through your iPad.

Synchronisation in shared notebooks

When a notebook containing embedded videos is shared between multiple devices via the sync feature, only the video metadata is transmitted (provider, video ID, original URL, placeholder position and size). The video itself is not transmitted — it resides with the provider.

Trademark notice

YouTube and Google are trademarks of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. PC-Future GmbH and NiblyNotes have no business relationship with Google LLC or any of its subsidiaries.

Google/YouTube privacy policy: policies.google.com/privacy

8. Own file formats

NiblyNotes uses two custom file formats for export and exchange:

• .nibly — complete notebook with all pages
• .niblypg — single page for targeted exchange

When sending these files via AirDrop®, email or cloud upload, only the content of the selected notebooks or pages is transmitted.

9. Backup

The app offers an optional backup function to automatically back up your notebooks to one of the cloud solutions mentioned in section 4. The backup function only runs against the cloud provider you set up — never against the publisher's servers.

10. Tracking, analytics, advertising

No analytics services, no advertising and no tracking SDKs are used. The app does not connect to any external push notification service and does not transmit usage data to the publisher.

11. Data transmission to publisher servers

There is no transmission of personal content, notebook data, usage data or telemetry to PC-Future GmbH servers. Exception: If you select the NiblyNotes server we operate in Germany for the "Student notebook viewing" feature (see section 6), the relevant data is stored there — but only end-to-end encrypted. We cannot view the content because the key never leaves the teacher's iPad over a server connection.

12. Your rights (Art. 15 ff. GDPR)

Since no personal data is transmitted to us, we cannot provide information about notebook content itself. For your cloud providers and Apple® services, the respective privacy policies of the providers apply.

For your rights vis-à-vis:

• Apple® (iCloud®, CloudKit, App Store®): apple.com/legal/privacy
• BayernCloud Schule: information at bycs.de
• Nextcloud: information from your respective Nextcloud operator
• NetMan for Schools: information from your school authority or H+H Software GmbH
• NiblyNotes server (PC-Future GmbH, optional for "Student notebook viewing"): requests at apps@pc-future.de. Since only encrypted data without any clear-text reference to a person is stored on our server, access and deletion can only be carried out via the app itself (end the class / share → data is deleted from the server).

13. Trademark notices

All product names, logos and trademarks mentioned are the property of their respective owners. They are mentioned solely for the purpose of describing compatibility and do not represent support or official partnership with the respective providers. In particular:

• Apple, Apple Pencil, iPad, iPadOS, iCloud, AirDrop, AirPrint and App Store are trademarks of Apple Inc.
• Microsoft, Word, PowerPoint and Excel are trademarks of Microsoft Corporation.
• Nextcloud is a trademark of Nextcloud GmbH.
• NetMan for Schools is a trademark of H+H Software GmbH.
• BayernCloud Schule is a service of the Free State of Bavaria.
• YouTube and Google are trademarks of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

NiblyNotes is not affiliated with, endorsed by or officially certified by these providers. Integration is carried out exclusively via the publicly documented interfaces.

14. Contact

For questions about data processing in NiblyNotes please contact us at apps@pc-future.de.