Draft. To be reviewed by a lawyer before launch. Items in [brackets] need real details.

Privacy policy

Last updated: [DATE]. Controller for this website and for purchases: Samarkand Industries OÜ, [ADDRESS], Estonia, registry code [REGISTRY CODE], hello@ponponko.com.

The short version

PonPonKo is built so that we never receive your photos. Evidence goes from your Mac to your own private iCloud and to your iPhone. We don't run a server that stores or sees it.

The app

• Photos and incident details (time, trigger, battery, power state and, if you allow it, a location rounded to about 1 km) are stored on your Mac and in your private iCloud database, which Apple operates for you. Samarkand Industries has no access to it.
• Face detection runs on your Mac and only checks whether a face is in the frame. PonPonKo does not identify people.
• Settings such as your emergency code are stored on your Mac. The code is stored as a salted hash, never in clear.
• You decide how long anything is kept and can delete it from the app, your Mac and iCloud at any time.
• The app contains no analytics or advertising SDKs.

People photographed by PonPonKo

Photos of someone using a protected Mac are taken and kept by the Mac's owner, in the owner's own iCloud. The owner is responsible for that use. Samarkand Industries does not receive or process these photos.

This website

No cookies, no analytics, no third-party fonts or scripts. The site is hosted by Cloudflare, which processes technical request data (such as IP address) to deliver and protect it. [Link to Cloudflare's privacy policy.]

Licence check

To confirm your licence, the app sends us a licence ID and a one-way hash of your Mac's hardware ID, about once a day while online. We keep which licence is active on which (hashed) Mac. Nothing else from the app is sent: no photos, incidents, location or usage data.

Purchases

Payments are handled by Stripe. We receive your name, email, country and purchase details to deliver your licence, issue invoices and meet tax obligations. Card details go to Stripe, never to us. Legal basis: performance of a contract and legal obligations (GDPR Art. 6(1)(b) and (c)). Invoices are kept for [7] years as required by Estonian accounting law.

Your rights

You can ask for access, correction, deletion or a copy of your data, and object to processing, by emailing us. You can also complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local authority.