Privacy Policy

1. Who We Are

LochKeys is a technology company based in Glasgow, Scotland. We build platforms and apps for content creators, media management, and beyond. You can contact us at contact@lochkeys.com.

2. Cullen iOS App — Privacy

What Cullen does

Cullen is a swipe-based photo and video library management app for iPhone. It reads your local photo library so you can swipe to keep, delete, or optimise your media. You can browse all media, filter by month, or explore photos taken on a specific date across all years in your library.

Data accessed by Cullen

• Photos & Videos: Cullen requests access to your photo library through the standard iOS Photos framework. This access is used solely to display your media on-screen so you can make decisions about it. Your media is never uploaded, copied to external storage, or shared with anyone.
• Deletions & saves: When you swipe to delete or keep a photo or video, that action is carried out directly in your iOS Photos library by the operating system. LochKeys receives no record of what you deleted or kept.

What Cullen does NOT do

• Collect any personal information
• Track your behaviour or usage patterns
• Use analytics SDKs (e.g. Firebase, Mixpanel, Amplitude)
• Show advertisements or use advertising identifiers (IDFA)
• Connect to any LochKeys or third-party server
• Store any data outside your device or iCloud (which is managed entirely by Apple and your own iCloud settings)
• Require an account or any sign-in
• Contain in-app purchases or subscription tracking

Apple frameworks & OS-level data

Cullen is built with Apple's native frameworks and runs exclusively on iOS. Apple may independently collect certain diagnostic or crash data as part of your iOS settings (e.g. if you have opted in to share analytics with app developers via iOS Settings → Privacy → Analytics & Improvements). Any such data collection is governed solely by Apple's Privacy Policy, not by LochKeys. LochKeys does not opt in to, access, or process any Apple-provided crash or analytics data.

3. LochKeys Website (lochkeys.com)

Hosting & logs

This website is hosted on Vercel. As with any web hosting provider, standard server access logs may temporarily record your IP address, browser type, and the pages you request. These logs exist for security and operational purposes and are not used to profile, track, or identify visitors.

Cookies & tracking

This website does not use advertising cookies, third-party tracking scripts, or analytics platforms. We do not build profiles of visitors, and we do not share any visitor data with third parties for marketing purposes.

Contact forms & email

If you contact us by email at contact@lochkeys.com, we will use the information you provide solely to respond to your enquiry. We do not add you to any mailing list, share your details with third parties, or store your information beyond what is necessary to handle your request.

4. Children's Privacy

Neither the LochKeys website nor the Cullen app are directed at children under the age of 13. We do not knowingly collect any personal information from children. If you believe a child has provided us with personal information, please contact us and we will take prompt steps to delete it.

5. Your Rights

Because Cullen collects no personal data from you, there is nothing for us to provide, correct, or delete on your behalf in relation to the app.

If you have contacted us by email and would like us to delete your correspondence, please email contact@lochkeys.com and we will do so promptly. As we are based in the United Kingdom, your rights under the UK GDPR apply where personal data is involved.

6. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last updated” date at the top of this page. We encourage you to review this page periodically. Continued use of our website or apps after any changes constitutes your acceptance of the updated policy.

7. Contact Us

If you have any questions about this Privacy Policy, please contact us: