Privacy Policy

Article 1 (Purpose and Scope)

1. SEARED BONITO (hereinafter the "Studio") publishes Bonito PDF, a desktop application for macOS and Windows (hereinafter the "App"). This Privacy Policy (hereinafter this "Policy") describes how the Studio handles personal information in connection with the App, in accordance with the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, as amended; hereinafter the "APPI") and other applicable laws and regulations.
2. This Policy applies to the App and to no other product of the Studio. The website at searedbonito.com, and enquiries made to the Studio (including requests, made through the contact form on that website, to be told when the App is released, and enquiries by email), are governed by a separate, studio-wide privacy policy, referenced in Article 21.
3. Where the General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter the "GDPR") or the United Kingdom General Data Protection Regulation (hereinafter the "UK GDPR") applies, the provisions of Article 18 shall apply in addition to this Policy. Where the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq., as amended; hereinafter the "CCPA") applies, the provisions of Article 19 shall apply in addition to this Policy.

Article 2 (Definitions)

For the purposes of this Policy, the following terms shall have the meanings set out below:

1. "Personal Information" means personal information as defined in Article 2, paragraph 1 of the APPI, and, where the GDPR or UK GDPR applies, personal data as defined in Article 4(1) thereof.
2. "User" means any person who uses the App.
3. "App Store Operator" means the party that distributes the App and sells, and processes payment for, its subscription: Apple Inc. for the Mac App Store, and Microsoft Corporation (including its affiliates) for the Microsoft Store.
4. "Document Data" means the PDFs and other files that a User opens, creates, edits or saves with the App, and their content, including text the App reads by text recognition, comments, form entries and digital signatures.
5. "Operating System" means the operating system of the User's computer (macOS or Windows).

Article 3 (Identity of the Controller)

1. The entity responsible for the App and for the handling of Personal Information under this Policy is as follows:
   1. Trade name: SEARED BONITO
   2. Representative: Toshiyuki Maeda
   3. Location: 503, 5-8-4 Daizawa, Setagaya-ku, Tokyo 155-0032, Japan
   4. Contact for privacy matters: support@searedbonito.com
2. Where the GDPR or UK GDPR applies, the Studio acts as the controller within the meaning of Article 4(7) thereof in respect of any Personal Information described in this Policy, except where Article 10 provides that the App Store Operator acts as an independent controller.

Article 4 (No Collection of Personal Information)

1. The App does not collect Personal Information of any kind. In particular, the Studio does not collect, and the App does not transmit to the Studio or to any third party, a User's name, email address, location, device identifiers, Document Data, or any record of how the App is used.
2. The App does not require, and does not offer, the creation of an account with the Studio or any sign-in. The account used to buy the subscription is dealt with in Article 10.
3. The App does not incorporate software of any kind for advertising, analytics, telemetry or the collection of crash reports, and the Studio operates no server for the App. The App has no function that sends Document Data, or data about how the App is used, off the User's computer, and it has no automatic update function. Updates to the App are delivered through the App Store Operators' stores.
4. The App does not track Users across apps or websites owned by other companies, and does not use cookies or comparable technologies for tracking.
5. Where, for example, a User has chosen in the computer's settings to share with app developers the diagnostic information collected by Apple or Microsoft, the App Store Operator may, under its own privacy policy, make available to the Studio crash reports and other diagnostic information concerning the App, together with aggregated statistics on its acquisition or use. This is a feature of the Operating System or of the store; the App itself neither collects nor sends such information, and the Studio uses any such information only to find and fix defects in the App and to improve its quality.

Article 5 (Processing on Your Computer)

1. All processing of Document Data by the App takes place on the User's computer, including displaying and searching documents, organizing, combining and splitting pages, comments, form filling, text editing, digital signatures and their verification, redaction, password protection, text recognition, PDF/A validation and conversion, export to other formats, and preparing documents for printing. Text recognition uses a feature provided by the Operating System that runs on the computer (Apple's Vision framework on macOS, Windows OCR on Windows).
2. The App does not send Document Data off the User's computer and does not upload it to any server, and the Studio has no means of knowing the content of any Document Data. Where a User saves a file to a location of the User's choosing (including a folder synchronized with cloud storage), or in the cases set out in Article 9, the arrangements of that location or of that other software apply.
3. The App does not open web links contained in a PDF of its own accord, and does not run scripts embedded in PDFs.

Article 6 (Access to Files and Computer Features)

1. The App accesses files and features of the computer only in the cases listed below, and only for the purpose stated for each:
   1. Files: to open or save the files or locations the User selects in the Operating System's open or save dialog, files the User drags and drops onto the App's window, files the Operating System asks the App to open, and files the User selects from the list of recent files described in Article 7.
   2. Printing: when the User asks to print, to create images of the pages to be printed and hand them to the Operating System's printing function.
   3. Control of other applications: when the User uses the "Create PDF" function, to launch and control Microsoft Word, Excel or PowerPoint, or LibreOffice, installed on the User's computer, so that they convert the selected files to PDF. On macOS, the Operating System asks the User whether to allow the App to control those applications.
   4. Digital IDs: to read, for signing, the digital ID file (.p12 or .pfx) the User selects when signing.
2. The User may change at any time, in the Operating System's settings, the permission for the App to control other applications.

Article 7 (Information Stored on Your Computer)

1. The App stores the information described in the table below on the User's computer. The App never transmits this information to the Studio or to any third party.

2. The User may clear the list of recent files at any time from the App's Home screen. Depending on the Operating System and on how the App is removed, the App's settings folder and settings storage may remain on the computer after the App is deleted; the User may delete them.
3. The App saves Document Data only to locations the User specifies. Depending on the User's settings, the Operating System's backup function or a synchronization service the User uses may include the information described in this Article or Document Data in a backup or synchronization; this happens according to the User's settings, and the Studio has no access to it.

Article 8 (Information Contained in Documents)

1. Document Data may contain Personal Information about people other than the User. The Studio never receives Document Data, has no visibility into its content, and plays no part in deciding what is opened, edited, saved or shared.
2. The User, not the Studio, determines the purposes and means of handling any Personal Information contained in Document Data, and may be the person responsible for that Personal Information (such as a controller) under applicable law. A User who handles documents containing other people's Personal Information should handle it appropriately, as applicable law and the User's relationship with those people require.
3. When a User adds a comment to a PDF with the App, the author name in the App's settings (by default, the user name of the User's computer account, which the User can change in the Author field of the Comments list) and the date and time are recorded in the PDF with the comment. When a User signs a PDF, the information contained in the certificate of the digital ID used (such as the signer's name), the time of signing, and any reason and location the User enters are recorded in the PDF. A PDF may also contain document information (metadata), such as its date of creation. A User sharing a PDF should note that this information goes with it. The redaction function can also remove hidden information such as metadata.

Article 9 (Other Software and Sharing)

1. When a User uses the "Create PDF" function, the selected files are handed, on the User's computer, to Microsoft Office or LibreOffice, which converts them to PDF. That software handles information under its provider's own terms and privacy policy; the Studio is not involved.
2. When a User asks to print, the print data is processed by the Operating System's printing function and by the printer the User selects (including its driver).
3. When a User shares a file saved with the App by email, cloud storage or any other means, the file is sent to the destination the User chooses and is thereafter handled under the terms and privacy policy of that destination and its service. The Studio is not involved and receives no copy.
4. When a User sets a password on a PDF or opens a password-protected PDF, encryption and decryption take place on the User's computer. The password is not sent to the Studio or to any third party, and the App does not store it. The Studio therefore cannot know the password, and cannot recover it if the User forgets it.
5. The password and private key of a digital ID file used for signing are used only on the User's computer, for signing, and are not sent to the Studio or to any third party. The App does not store that password.
6. On Windows, the App displays its interface with the Microsoft Edge WebView2 Runtime provided by Microsoft. If the WebView2 Runtime is not on the computer, it may be obtained from Microsoft when the App is installed. The WebView2 Runtime is provided under Microsoft's own terms and privacy statement.

Article 10 (Payments and Subscription)

1. The App is to be offered as an auto-renewing subscription, billed monthly or annually (hereinafter the "Subscription"), through the Mac App Store and the Microsoft Store. The sale of the Subscription, and its payment, renewal, cancellation and refunds, are handled by the App Store Operator. Payment credentials, including card numbers, are entered outside the App, and the Studio neither receives nor stores them. Nor does the Studio receive the purchaser's name, Apple Account, Microsoft account or any other information that identifies the purchaser.
2. In respect of information concerning purchases, billing, renewals, cancellations and refunds, the App Store Operator acts as an independent controller (or, where the CCPA applies, as an independent business), not as an entrustee of the Studio, and handles that information under its own privacy policy (apple.com/legal/privacy, privacy.microsoft.com).
3. Where the App checks whether the Subscription is active, it handles the information the App Store Operator provides to it through the mechanisms of the Operating System or the store only on the User's computer, and does not transmit it to the Studio or to any third party. The Studio operates no server of its own and cannot identify who has made a purchase.
4. The price and other terms of the Subscription will be shown in the App Store Operator's store when sales begin.

Article 11 (No Provision to Third Parties)

Because the App collects no Personal Information, the Studio has none to provide, sell, or disclose to any third party in connection with the App, and does not do so.

Article 12 (Entrustment)

The Studio entrusts the distribution of the App to the App Store Operators. The sale of the Subscription and the processing of its payment are carried out by the App Store Operator as an independent controller, as set out in Article 10, and not on the Studio's behalf. The Studio does not entrust any handling of Personal Information to any other party in connection with the App, as none is collected.

Article 13 (Retention and Deletion)

The Studio retains no Personal Information in connection with the App, and accordingly no retention period applies. The information described in Article 7 is kept on the User's computer until the User deletes it, as set out in paragraph 2 of that Article; temporary print files are deleted when printing ends. Document Data is kept where the User saved it until the User deletes it.

Article 14 (Security)

The App is designed so that no Personal Information is created or handled by the Studio in the first place, which the Studio considers the most effective safeguard available. The information described in Article 7 and Document Data are protected by the security features of the Operating System on the User's computer, and passwords and digital IDs are handled as described in paragraphs 4 and 5 of Article 9. The User is responsible for the physical and account-level security of the computer.

Article 15 (Rights of Users)

Because the Studio holds no Personal Information in connection with the App, there is no Retained Personal Data, within the meaning of Article 16, paragraph 4 of the APPI, in respect of which to exercise a right of disclosure, correction, or deletion under Articles 33 to 35 of the APPI. A User who nonetheless has a question about this Policy, or believes the App has behaved otherwise than as described here, may contact the address in Article 21 at any time, free of charge.

Article 16 (Children's Privacy)

The App is not directed at children under the age of thirteen (13) and, as described in Article 4, collects no Personal Information from a User of any age.

Article 17 (Special Provisions for Residents of Japan)

A User resident in Japan may lodge a complaint with the Personal Information Protection Commission (ppc.go.jp), in addition to contacting the Studio under Article 21.

Article 18 (Special Provisions for Residents of the EEA and the United Kingdom)

1. Because the App collects no Personal Information, the Studio processes none on which the rights of access, rectification, erasure, restriction, objection, or data portability under Articles 15 to 21 of the GDPR or UK GDPR could operate.
2. A User nonetheless has the right to lodge a complaint with the supervisory authority of the User's habitual residence, place of work, or place of the alleged infringement, including the Commission nationale de l'informatique et des libertés in France (cnil.fr) and the Information Commissioner's Office in the United Kingdom (ico.org.uk).

Article 19 (Special Provisions for Residents of California)

Because the App collects no personal information within the meaning of the CCPA, the Studio has none in respect of which the rights to know, delete, or correct under the CCPA could be exercised. The Studio does not sell or share personal information within the meaning of the CCPA, and has not done so in the preceding twelve (12) months.

Article 20 (Governing Law and Jurisdiction)

This Policy is governed by the laws of Japan, without regard to its conflict-of-laws principles. The Tokyo District Court shall have exclusive jurisdiction as the court of first instance over any dispute arising out of or in connection with this Policy or the handling of personal information in connection with the App, except where applicable consumer protection or data protection law mandatorily grants the User the right to have the law of the User's own jurisdiction applied, to bring proceedings in that jurisdiction, or to lodge a complaint with a supervisory authority, in which case that law applies instead.

Article 21 (Contact)

Enquiries and complaints concerning the App or this Policy shall be addressed to:

Information that a User provides when contacting the Studio by email or through the contact form on searedbonito.com (including a request to be told when the App is released), such as the User's name, email address and the content of the enquiry, is handled under the studio-wide privacy policy, not under this Policy. The same applies to matters concerning searedbonito.com itself.

Article 22 (Amendment of this Policy)

The Studio may amend this Policy and, where necessary, shall do so before it begins selling the Subscription or introduces a feature that would change the information described in Articles 4 to 10. Where an amendment is made, the Studio shall post the amended Policy on this page and update the date of last amendment stated above and, where the amendment materially affects the handling of Personal Information, shall give notice within the App or on this page prior to the amendment taking effect.

Established 16 October 2026