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KyotoTech LLC

Privacy Policy

Version 4.3 · Effective Date: October 15, 2026

Table of Contents

  1. Introduction
  2. Data Controller
  3. Information We Collect
  4. How We Use Your Information
  5. Data Sharing & Disclosure
  6. International Data Transfers
  7. Data Retention
  8. Data Security
  9. Your Rights
  10. Cookies & Tracking
  11. Newsletter (Discontinued)
  12. Third-Party Services
  13. Children's Privacy
  14. Changes to This Policy
  15. Contact Us

1. Introduction

KyotoTech LLC (合同会社KyotoTech) ("Company," "we," "us," or "our") is committed to protecting your privacy and handling your personal information responsibly.

This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our website (kyototech.co.jp), software products (including SaQura and KisoStats), and services.

KisoStats — No Data Collection

KisoStats is a macOS menu bar system monitor and disk cleanup utility. KisoStats does not collect, transmit, store, or process any personal data whatsoever. The application runs locally on your Mac. It contains no analytics or telemetry and requires no user account. The only connection it makes is the update check to kyototech.co.jp, which transmits no personal data beyond what any web request carries (IP address, app version). System metrics (CPU, RAM, SSD, network speed) are read from macOS system APIs, displayed in real-time, and are not stored or logged.

Legal Framework

As a Japanese company serving international customers, we comply with:

  • APPI - Japan's Act on the Protection of Personal Information (個人情報保護法)
  • GDPR - EU General Data Protection Regulation (for EU/EEA residents)
  • Other applicable data protection laws in your jurisdiction

In case of conflict between this Policy and applicable law, the applicable law shall prevail.

2. Data Controller Information

Data Controller

KyotoTech LLC (合同会社KyotoTech)
〒612-8083 京都市伏見区京町2丁目237-202
Kyoto, Japan
Email: support@kyototech.co.jp

EU Representative (Article 27 GDPR)

KyotoTech LLC is established outside the European Union. Where we offer services to, or monitor the behaviour of, individuals located in the European Union, we have designated a representative in the Union pursuant to Article 27 GDPR. Data subjects in the EU/EEA may contact our representative on all matters relating to the processing of their personal data and the exercise of their rights under the GDPR — in addition to, or instead of, contacting us directly:

DataRep (Data Protection Representative Limited, trading as DataRep)
Altmarkt 10 B/D, 3rd & 4th floor, 01067 Dresden, Germany
Email: datarequest@datarep.com (please mark the subject with “KyotoTech; SaQura”)
Online form: www.datarep.com/data-request
DataRep maintains contact points across the EU/EEA; please always address postal inquiries to “DataRep” so they reach us.

Data Protection Inquiries

For questions about this Privacy Policy or our data practices, please contact:

  • Email: support@kyototech.co.jp
  • Contact Form: kyototech.co.jp/#contact

3. Personal Information We Collect

Information You Provide Directly

Data Category Data Elements Purpose Legal Basis (GDPR)
Contact Information Name, Email, Phone (optional), Message Respond to inquiries Legitimate interest / Consent
License Information Email address License delivery Contract performance
Account Information Email, License Key License management Contract performance
Expert interviews (by invitation only) Your answers, name, role and organization as you choose to state them, your email address, optional photo, consent choices, record of your approval of the final text Prepare and publish the interview you approved; send you the confirmation of your approval and the link once the interview is online Consent (Art. 6(1)(a)); approval record and its confirmation by email: legitimate interest (Art. 6(1)(f))

Information Collected Automatically

Data Category Data Elements Purpose Legal Basis (GDPR)
License Activation Data License Key, Hardware ID (hashed), Machine Name (encrypted), OS/Platform, Timestamp, IP address, Browser type (User-Agent) License validation, prevent abuse Contract performance
Administrative Audit Trail Action performed, Timestamp, IP address, Browser type (User-Agent), affected record Security audit trail for administrative actions, dispute resolution Legitimate interest
Web Server Logs IP address, Browser type (User-Agent), Requested address, Access times Security — automatic detection and blocking of abusive requests — and troubleshooting Legitimate interest — deleted after 14 days

Information We Do NOT Collect

We explicitly DO NOT collect:

  • Your encryption keys or passwords created with our Software
  • Content of files you encrypt
  • Usage patterns or telemetry from the Software
  • Precise geolocation data
  • Biometric data
  • Data from children under 16
  • Sensitive personal data (racial/ethnic origin, political opinions, religious beliefs, health data, sexual orientation)

4. How We Use Your Information

Purposes of Processing

Purpose Categories of Data Legal Basis (GDPR) APPI Basis
Respond to inquiries Contact information Legitimate interest Specified purpose
Deliver licenses Email, License Key Contract performance Contract fulfillment
Validate licenses Activation data Contract performance Service provision
Prevent license abuse Hardware ID (hashed) Legitimate interest Fraud prevention
Provide technical support Contact info, License data Contract performance Customer service
Improve services Aggregated analytics Legitimate interest Service improvement
Legal compliance Various Legal obligation Legal requirement
Prepare and publish expert interviews Interview answers, details you provide, email address, optional photo, approval record Consent; for the approval record legitimate interest in documenting what was approved Consent

What We Do NOT Do

  • No Selling: We DO NOT sell, rent, or trade your personal information to third parties for marketing purposes.
  • No Profiling: We DO NOT use your personal information for automated decision-making or profiling that produces legal effects.
  • No Marketing: We DO NOT send unsolicited marketing emails unless you have explicitly opted in.

5. Data Sharing & Disclosure

Service Providers

We share personal information with the following categories of service providers:

Provider Category Purpose Data Shared Location Safeguards
Payment Processor (Stripe) Payment processing Email (for receipts) USA Standard Contractual Clauses
Email Delivery (Google Workspace) Sending transactional emails Email address, message content USA Standard Contractual Clauses
Hosting Provider Website/API hosting All data processed Japan APPI compliance

WhatsApp Link

Our contact section links to WhatsApp (WhatsApp Ireland Limited, Ireland). The link does not load any content from WhatsApp. Only when you click it and message or call us there does WhatsApp process your data (including phone number, profile details and connection data) under its own responsibility; data may also be transferred to the USA. We process your message to handle your request (Art. 6(1)(b)/(f) GDPR). The WhatsApp Privacy Policy applies.

Legal Disclosures

We may disclose personal information when required by law, including:

  • Court orders or legal process
  • Requests from law enforcement agencies
  • Protection of our legal rights
  • Investigation of fraud or security incidents
  • Protection of the rights, property, or safety of our users or the public

Business Transfers

In the event of a merger, acquisition, or sale of assets, personal information may be transferred to the acquiring entity. We will notify you of any such change.

No Other Sharing

We do not share personal information with third parties except as described in this Policy.

6. International Data Transfers

Primary Storage

Personal information is primarily stored on servers located in Japan.

Cross-Border Transfers

When we transfer personal information outside Japan, we ensure adequate protection through the following mechanisms:

Destination Mechanism Safeguards
EU/EEA and United Kingdom Designation by Japan's Personal Information Protection Commission (APPI Article 28) The Commission has designated the EU/EEA and the United Kingdom as having a personal information protection system equivalent to Japan's
USA (Stripe) Standard Contractual Clauses (SCCs) Contractual data protection obligations
Other countries Case-by-case assessment Appropriate safeguards per APPI

Data Coming to Us from the EU/EEA and the United Kingdom

When personal data from the EU/EEA reaches our servers in Japan, the transfer relies on the European Commission's adequacy decision for Japan (Article 45 GDPR, Implementing Decision (EU) 2019/419). For the United Kingdom, the corresponding UK adequacy regulations for Japan apply.

Your Consent

For transfers to countries without adequate data protection, we will obtain your explicit consent where required by APPI or GDPR.

7. Data Retention

Retention Periods

Data Category Retention Period Basis
Contact form submissions 2 years after last contact Business necessity
License activation data Duration of license + 1 year Contract fulfillment
Payment records 7 years Japanese tax law requirements
Support tickets 2 years after resolution Customer service
Web server logs (incl. IP address) 14 days Security / troubleshooting
System and security logs (login attempts, blocked requests, incl. IP address) 4 weeks Security / abuse prevention
Administrative and licensing audit trail (incl. IP address) 12 months Security audit trail / dispute resolution
Expert interviews Until you withdraw consent. Material that is not or no longer published is deleted 12 months after the last activity, including after the interview has been taken offline. After any withdrawal or deletion we keep only a record without any content (date, reference number and checksums of the approved text and of your details) Consent; for the remaining record legitimate interest in documenting approvals (Art. 6(1)(f))

Deletion

After the retention period expires, personal information is securely deleted or anonymized.

8. Data Security

Technical Measures

We implement appropriate technical security measures, including:

  • Encryption of data in transit (TLS 1.3)
  • Encryption of sensitive data at rest
  • Secure password hashing for authentication
  • Regular security updates and patches
  • Access controls and authentication requirements
  • Network security measures (firewalls, intrusion detection)

Organizational Measures

  • Limited access to personal information on a need-to-know basis
  • Employee training on data protection
  • Incident response procedures
  • Regular security assessments

No Guarantee

While we implement reasonable security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

Breach Notification

In the event of a data breach that affects your personal information, we will notify you and the relevant authorities as required by applicable law (APPI, GDPR).

9. Your Rights

Rights Under APPI (Japan)

Under Japan's Act on the Protection of Personal Information, you have the following rights:

Right Description
Access (開示請求) Request disclosure of your personal information
Correction (訂正請求) Request correction of inaccurate information
Deletion (削除請求) Request deletion of your personal information
Suspension of Use (利用停止請求) Request cessation of use of your information
Third-Party Disclosure Request information about third-party disclosures

Additional Rights Under GDPR (EU/EEA Residents)

If you are located in the EU/EEA, you additionally have the right to:

Right Description
Data Portability Receive your data in a structured, machine-readable format
Restriction of Processing Request limitation of processing in certain circumstances
Object to Processing Object to processing based on legitimate interests
Withdraw Consent Withdraw consent at any time (where processing is based on consent)
Lodge a Complaint File a complaint with a supervisory authority

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

  • Email: support@kyototech.co.jp
  • Contact Form: kyototech.co.jp/#contact

Response Time

  • APPI: Without delay, and in any case within 2 weeks
  • GDPR: Within 1 month (extendable by 2 months for complex requests)

Verification

We may require verification of your identity before processing requests.

No Fee

We will not charge a fee for reasonable requests, except as permitted by law for manifestly unfounded or excessive requests.

10. Cookies & Tracking

Cookies We Use

This website sets no cookies. Your language and display theme are remembered in your browser's local storage. They stay on your device and are not sent to us.

What We Do NOT Use

  • Third-party advertising cookies
  • Cross-site tracking
  • Social media tracking pixels
  • Fingerprinting technologies

Analytics

We measure reach with two systems. Both run on infrastructure we operate ourselves; neither involves an external analytics provider.

  • Umami — a self-hosted, cookieless analytics tool on our server in Germany, active across this website. It records aggregated, non-identifying information only: page visited, hostname, referrer, approximate country derived from the IP address, browser, operating system, device class, screen size and language. No cookies are set and IP addresses are not stored persistently.
  • In-house page measurement — a small script on selected pages that sends the page path, referrer, screen size, browser language and time zone offset to our own API at main.kyototech.co.jp. Your IP address is truncated on our server before it is stored: the last block is removed, so only a coarse network range such as 203.0.113.xxx is kept, never the full address. From that truncated range we derive a pseudonym that changes every day, which lets us count repeat page views within one day without recognising you on a later day. No cookies, no user account.

Download counter: when you download a file from a product page, the page sends the product name and the file name to our own API so that we can count downloads. It uses no cookies and no user account.

Neither system:

  • Uses cookies
  • Tracks individual users across websites
  • Collects data that identifies you personally, or builds a profile of you
  • Shares data with third parties

Legal basis: Art. 6(1)(f) GDPR — legitimate interest in understanding how our website is used, balanced against the minimal, non-identifying data collected.

11. Newsletter (Discontinued)

We discontinued our newsletter on September 29, 2026. Subscription is no longer offered on this website, and no further newsletters will be sent.

The newsletter data has been removed from our live systems: the email addresses of all subscribers, the associated confirmation and consent records, the delivery log, and the anonymous open and click statistics. Remaining backup copies are being deleted. We no longer use any of this data.

If you have questions about this, please contact support@kyototech.co.jp.

12. Third-Party Services

Payment Processing (Stripe)

We use Stripe for payment processing. When you make a purchase:

  • Your payment information is processed directly by Stripe
  • We do not receive or store your credit card information
  • Stripe is PCI DSS compliant
  • Stripe's privacy policy applies: stripe.com/privacy

Email Delivery (Google Workspace / Gmail SMTP)

Transactional emails are delivered via Google Workspace (Gmail SMTP), operated by Google LLC (United States):

  • Recipient email address and message content are processed by Google for delivery
  • International transfer is covered by the EU Standard Contractual Clauses
  • Google's privacy policy applies: policies.google.com/privacy

NuGet Package Distribution

Our Software is distributed via NuGet (nuget.org):

  • NuGet's privacy policy applies to package downloads
  • We do not receive personal information from NuGet downloads

Links to External Sites

Our website may contain links to external sites. We are not responsible for the privacy practices of other sites. We encourage you to read their privacy policies.

13. Children's Privacy

Age Restriction

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children under 16.

Parental Notice

If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.

Contact Us

If you believe we have collected information from a child under 16, please contact us immediately at support@kyototech.co.jp.

14. Changes to This Policy

Right to Update

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

Notification

We will notify you of material changes by:

  • Posting the updated Policy on our website
  • Updating the "Effective Date" at the top
  • For significant changes, sending email notification to affected users

Review

We encourage you to review this Policy periodically.

15. Contact Us

Privacy Inquiries

For any questions, concerns, or requests regarding this Privacy Policy or our data practices:

  • Email: support@kyototech.co.jp
  • Contact Form: kyototech.co.jp/#contact

Postal Address

KyotoTech LLC (合同会社KyotoTech)
〒612-8083 京都市伏見区京町2丁目237-202
Kyoto, Japan

Supervisory Authorities

Japan (APPI):

Personal Information Protection Commission (個人情報保護委員会)
www.ppc.go.jp

EU/EEA (GDPR):

You have the right to lodge a complaint with a supervisory authority in your country of residence.

Version History

Version Date Changes
4.3October 15, 2026Added expert interviews (by invitation only): data collected, purpose, consent as the legal basis, the approval record, retention of 12 months for unpublished material and the content-free record kept after withdrawal. Section 6 now names the basis for data coming to us from the EU/EEA and the United Kingdom (adequacy decision (EU) 2019/419 and UK adequacy regulations).
4.1October 4, 2026KyotoTech Vault is no longer offered on this website; its sections were removed. Updated the KisoStats section (update check), added Loki Radar, and corrected the overview of browser storage and the list of recipients, and described the download counter.
4.0September 29, 2026Newsletter discontinued. Subscription is no longer offered, and all newsletter data (subscriber email addresses, consent records, delivery log and anonymous open and click statistics) was removed from our live systems; remaining backup copies are being deleted. Section 11 now documents the discontinuation; the Gmail SMTP entry in section 12 now covers transactional emails only.
3.9July 31, 2026Replaced the generic "Security logs — 1 year" retention entry, which did not match reality in either direction, with accurate entries: system and security logs are kept for 4 weeks, and the administrative and licensing audit trail for 12 months. Disclosed the administrative audit trail as a separate category of automatically collected data, and completed the license activation entry, which had omitted the IP address and browser type that are in fact recorded.
3.8July 30, 2026Corrected and completed the description of our logs and page measurement. Web server logs are now described accurately: they contain the full IP address, are used to detect and block abusive requests, and are deleted after 14 days — the previous entry described them as anonymized, which was not correct. Added a matching retention entry. For the in-house page measurement, we now state explicitly that the IP address is truncated on our server before storage and never stored in full, and that the pseudonym derived from it changes daily.
3.7July 28, 2026Named the analytics tools used on this website: Umami (self-hosted, cookieless, server in Germany), now active across the site, alongside the existing in-house page measurement on selected pages. Listed the categories of data each records and stated the legal basis (Art. 6(1)(f) GDPR).
3.6June 18, 2026Published the appointed EU representative under Art. 27 GDPR: DataRep (Data Protection Representative Limited), Dresden, Germany, replacing the prior placeholder.
3.5June 15, 2026Clarified the named newsletter consent regimes as EU/EEA (GDPR), Switzerland (revDSG) and Japan (APPI); the UK is no longer listed as a separately targeted regime, as we do not target or expect subscribers in the United Kingdom. Subscribers outside the named regions continue to receive the conservative double opt-in default.
3.4April 18, 2026Added newsletter analytics: anonymous open-pixel and click-redirect aggregation (slug, country from GeoIP, language, device class, timestamp). No subscriber identifier, no cookies, no IP storage. Retention 24 months. Legal basis Art. 6(1)(f) legitimate interest.
3.3April 18, 2026Newsletter consent process is now region-dependent: double opt-in for EU/EEA/UK/CH and German-language signups, single opt-in for Japanese IP addresses (APPI). Documented derived country, language and consent_method as audit data; clarified that the IP address itself is not stored.
3.2April 16, 2026Added newsletter subscription processing: double opt-in, data collected, Google Workspace SMTP delivery, retention, withdrawal rights
3.1March 17, 2026Added KisoStats: explicit no-data-collection statement for macOS system monitor utility
3.0March 13, 2026Added KyotoTech Vault: file storage, collaboration spaces, guest access, audit logging, virus scanning, uploaded content liability disclaimer
2.0December 31, 2025Major update: Added GDPR/APPI compliance details, international transfers, data retention, expanded rights
1.0January 2025Initial release
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