PRIVACY POLICY CUNNING CLIPBOARD

Effective Date: January 30, 2025
Version: 1.0

Cunning GmbH Software (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Cunning Clipboard application (“Application”, “Service”). Please read this Privacy Policy carefully.

1. INFORMATION WE COLLECT

1.1 Information You Provide
– Email address (for account registration and authentication)
– Payment information (processed by Paddle.com, we do not store payment details)
– Support inquiries and feedback

1.2 Information Collected Automatically
– Application version and platform (Windows, macOS, Linux)
– Error logs and crash reports (anonymized)
– Usage analytics (feature usage statistics, anonymized)
– Device information (operating system version, screen resolution)

1.3 Information We DO NOT Collect
– Clipboard content (stored locally only)
– Scratch pad content when not in collaboration mode. In collaboration mode all data is clientside encrypted. It is impossible to read your data.
– File contents accessed through the Application
– Keystrokes or screen recordings
– Personal documents or sensitive data

2. LOCAL DATA STORAGE

2.1 Clipboard Data
ALL clipboard items captured by the Application are stored EXCLUSIVELY on your local device. This data:
– Never leaves your computer unless you explicitly enable collaboration mode
– Is encrypted using AES-256-CBC when stored locally
– Can be deleted at any time through the Application settings

2.2 Scratch Pad Data
Scratch pad items are:
– Stored locally on your device only
– Only transferred encrypted and stored client side encrypted on our server.
– Fully under your control

2.3 Application Settings
Your preferences and settings are stored locally and include:
– Hotkey configurations
– UI preferences
– Collaboration settings
– EULA acceptance status

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:
– Authenticate your account and manage subscriptions
– Process payments through our payment processor (Paddle.com)
– Send important service updates and security alerts
– Respond to support requests
– Improve the Application’s performance and features
– Comply with legal obligations

4. DATA SHARING AND DISCLOSURE

4.1 We DO NOT:
– Sell, rent, or trade your personal information
– Share your clipboard or scratch pad data with anyone
– Access your local data for any purpose

4.2 We MAY share information:
– With Paddle.com for payment processing (email and subscription data only)
– When required by law or to respond to legal process
– To protect our rights, privacy, safety, or property
– With your explicit consent

5. COLLABORATION MODE

When you enable collaboration features:
– Data is shared ONLY between devices you explicitly authorize
– All shared data is end-to-end encrypted
– WebSocket connections are established directly between your devices
– No clipboard or scratch pad data is stored on our servers
– Only authentication tokens are transmitted through our infrastructure

6. DATA SECURITY

We implement appropriate technical and organizational measures to protect your information:
– AES-256-CBC encryption for local data storage
– End-to-end encryption for collaboration features
– Secure WebSocket connections (WSS)
– Regular security audits and updates
– Minimal data collection principle

7. DATA RETENTION

7.1 Account Data
– Active accounts: Retained while your account is active
– Inactive accounts: Deleted after 12 months of inactivity
– Upon account deletion: All associated data removed within 30 days

7.2 Local Data
– Clipboard and scratch pad data: Retained until you delete it
– Application logs: Automatically purged after 30 days
– Settings: Retained until you uninstall the Application

8. YOUR RIGHTS AND CHOICES

You have the right to:
– Access your account information
– Update or correct your email address
– Delete your account and associated data
– Export your data (local data can be exported through the Application)
– Opt-out of non-essential communications
– Disable analytics collection

9. CHILDREN’S PRIVACY

The Application is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete it.

10. INTERNATIONAL DATA TRANSFERS

If you use the Application from outside the United States, please note that your information may be transferred to, stored, and processed in the United States where our servers are located. By using the Application, you consent to such transfer.

11. THIRD-PARTY SERVICES

11.1 Payment Processing
We use Paddle.com for payment processing. Their privacy policy governs the collection and use of your payment information. We recommend reviewing Paddle’s privacy policy at https://paddle.com/privacy

11.2 Analytics
We use privacy-respecting analytics to improve the Application. This data is anonymized and cannot be traced back to individual users.

12. PLATFORM-SPECIFIC PRIVACY CONSIDERATIONS

12.1 Windows
– May require administrative privileges for certain features
– Clipboard access through Windows APIs
– Local data stored in user’s AppData directory

12.2 macOS
– May require accessibility permissions
– Clipboard access through macOS APIs
– Local data stored in user’s Application Support directory
– Complies with App Sandbox requirements where applicable

12.3 Linux
– Clipboard access through X11 or Wayland protocols
– Local data stored in user’s home directory
– Respects XDG Base Directory specification

13. PRIVACY POLICY UPDATES

We may update this Privacy Policy from time to time. We will notify you of any material changes by:
– Posting the new Privacy Policy in the Application
– Sending an email to registered users
– Updating the “Effective Date” at the top of this policy

14. DO NOT TRACK

The Application does not respond to Do Not Track signals as all data processing occurs locally on your device.

15. CALIFORNIA PRIVACY RIGHTS

California residents have additional rights under the California Consumer Privacy Act (CCPA):
– Right to know what personal information is collected
– Right to delete personal information
– Right to opt-out of the sale of personal information (we do not sell personal information)
– Right to non-discrimination

16. GDPR COMPLIANCE

For users in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR):
– Legal basis: Contract performance and legitimate interests
– Data portability: You can export your local data
– Right to erasure: You can delete your account and local data
– Data Protection Officer: Contact privacy@cunning.biz

17. DATA BREACH NOTIFICATION

In the unlikely event of a data breach that affects your personal information, we will:
– Notify affected users within 72 hours
– Provide information about the breach and potential impact
– Offer guidance on protective measures
– Work with authorities as required by law

18. CONTACT US

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

Cunning Software
Email: privacy@cunning.biz
Website: https://cunning.biz
Data Protection Officer: dpo@cunning.biz

For privacy-related requests, please include “Privacy Request” in the subject line.

19. PRIVACY COMMITMENT

We are committed to:
– Minimizing data collection
– Keeping your clipboard data local and private
– Being transparent about our practices
– Giving you control over your information
– Continuously improving our privacy protections

BY USING THE CUNNING CLIPBOARD APPLICATION, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.