Privacy policy
Effective 24 October 2026This policy explains what personal data is handled when you visit markcluster.com, buy a license and use the MarkCluster app. It is written to meet the EU General Data Protection Regulation (GDPR), the UK GDPR, the Swiss Federal Act on Data Protection (FADP) and Japan's Act on the Protection of Personal Information (APPI).
The controller is FUJIMORI Tomotaka, an individual sole proprietor in Japan who makes MarkCluster (“we”). Privacy contact: [email protected].
The MarkCluster app
- Your notes and settings are stored on your own computer. The app does not send your notes or any usage data to us, and it contains no analytics, tracking or advertising.
- Your license key is checked on your computer; the app does not contact us to do so. The key contains the licensee's name and email address and the order number, and is stored in the app's settings folder on your computer.
- If you turn on the AI features, the text you choose is sent directly from your computer to the provider you configure (Anthropic or OpenAI, both in the United States), under that provider's terms and privacy policy and using your own account. We never receive it, and we are not the controller of that processing.
- Printing and saving as PDF use the web browser on your computer.
This website and cookies
- We set no cookies and use no analytics, advertising or tracking tools. Fonts and images are served from this website, not from third parties.
- The site is hosted by Cloudflare, which processes technical data such as your IP address and browser type to deliver the site and protect it from abuse (see Cloudflare's privacy policy).
- On pages with a buy button, your browser loads Paddle's script from Paddle's servers so that the price can be shown in your currency, with the taxes of your country. Paddle receives your IP address to determine your country.
- When you open the checkout, Paddle may use cookies that are strictly necessary for the payment you asked for.
Purchases
Paddle.com is the merchant of record. It processes your payment and billing details as an independent controller under Paddle's privacy notice. We never see your card details. Paddle shares with us only the data we need to deliver and support your license: your name, email address, preferred language, customer ID, order number and what you bought. Your name and email address are needed to issue and send your license key; without them we can't deliver it.
Why we use your data, and our legal bases
| Purpose | Data | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Issuing your license key, emailing it to you and resending it on request | Name, email, language, order number, license ID | Performance of our contract with you (Art. 6(1)(b)) |
| Telling you about important security updates for the version you bought | Email, license ID | Our contract with you and our legal obligation to inform you about updates (Art. 6(1)(b) and (c)) |
| Answering your emails and support requests | What you write to us, your email address | Contract (Art. 6(1)(b)), or our legitimate interest in answering you (Art. 6(1)(f)) |
| Handling refunds and chargebacks, and deactivating keys that were shared, published or obtained fraudulently | Order number, license ID, refund status | Legitimate interest in preventing fraud and misuse (Art. 6(1)(f)) |
| Delivering and protecting this website; showing prices in your currency with the correct taxes | IP address, browser data | Legitimate interest in a secure website and correct price information (Art. 6(1)(f)) |
We do not use your data for marketing, profiling or automated decision-making, and we don't sell it or share it for advertising.
Recipients
- Paddle.com — merchant of record (payments, taxes, invoices, refunds); an independent controller.
- Cloudflare — website hosting and delivery; processes data on our behalf.
- Our email delivery provider — sends your license key and update notices on our behalf.
- Our server hosting provider — hosts the server that issues license keys, on our behalf.
Our service providers may only process your data on our instructions and under a data processing agreement.
International transfers
We are based in Japan. The European Commission has decided that Japan provides an adequate level of data protection (Commission Implementing Decision (EU) 2019/419), and the UK recognises Japan as adequate too, so your data may be transferred to us on that basis. Where our service providers process data in other countries, such as the United States, we rely on an adequacy decision (for example, the EU–US Data Privacy Framework) or on the European Commission's Standard Contractual Clauses (with the UK Addendum and Swiss amendments where they apply). You can ask us for a copy of these safeguards.
Retention
- Order and license records (name, email, language, order number, license ID): for the life of your license, so that we can resend your key and confirm your purchase. If you ask us to delete them, we erase your name, email address and key and keep only the license ID and order number, which we need to prevent misuse of the key.
- Purchase notifications that Paddle sends to our server: deleted 30 days after they are processed (at most 90 days after we receive them).
- Support emails: up to 3 years after the conversation ends.
- Paddle keeps payment and tax records according to its own privacy notice and tax law.
Security
License records are kept on a server we operate, reachable only over encrypted connections, with access limited to us; the database can be read only by the license service. License keys are signed with a private key that never leaves that server. If a personal data breach occurs, we will notify the competent supervisory authority and, where required, you.
Your rights
Under the GDPR, the UK GDPR and the FADP you have the right to:
- access your data and get a copy of it, in a portable format (Art. 15 and 20);
- have inaccurate data corrected (Art. 16) and have your data erased (Art. 17);
- restrict our processing (Art. 18); and
- object at any time to processing based on our legitimate interests, on grounds relating to your particular situation (Art. 21).
To use these rights, write to [email protected]. We answer within one month and may ask for your order number to confirm that the data is yours. You also have the right to lodge a complaint with a data protection supervisory authority — in particular in the EU or EEA country where you live or work, with the UK Information Commissioner's Office (ICO), or with the Swiss Federal Data Protection and Information Commissioner (FDPIC). Under Japan's APPI you can likewise ask us to disclose, correct, stop using or delete your data.
Children
MarkCluster is not directed at children under 16, and we don't knowingly collect their data.
Changes
If we change this policy, we'll update the date above. Significant changes will be announced on this website.