Privacy Policy

Article 1 (Purpose and Scope)

1. SEARED BONITO (hereinafter the "Studio") publishes the iOS and iPadOS application Bonito Scan (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 through the contact form on that website and 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 Apple Inc., which distributes the App and sells, and processes payment for, the subscription offered in it.
4. "Document Data" means the images that a User captures with the App or imports into it, and the PDFs and other data that the App creates from them, including Recognized Text.
5. "Recognized Text" means the text that the App reads, by text recognition, from the images in Document Data.

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, precise or approximate location, contacts, device identifiers, Document Data, Recognized Text, or any record of how the App is used.
2. The App does not require, and does not offer, the creation of an account or any sign-in.
3. The App does not incorporate software of any kind for advertising, analytics, or the collection of crash reports, and the Studio operates no server for the App. The App sends no usage data off a User's device.
4. The App does not track Users across apps or websites owned by other companies and does not use the advertising identifier (IDFA); it therefore never asks for permission under App Tracking Transparency. Being a native application rather than a website, the App does not use cookies or comparable tracking technologies.
5. If a User has chosen, in the device's settings, to share the analytics collected by Apple with app developers, Apple may make available to the Studio crash reports and other diagnostic information concerning the App, together with aggregated statistics on its use. This is a feature of the operating system, provided by Apple under its own privacy policy, which the User may turn on or off at any time in the device's settings. The App itself neither collects nor sends such information, and the Studio uses any such information it receives from Apple only to find and fix defects in the App and to improve its quality.
6. Accordingly, the App's privacy information on the App Store states "Data Not Collected". Purchase and subscription records held by the App Store Operator under Article 10 are not collected by the Studio and do not alter this.

Article 5 (Processing on Your Device)

1. All processing of Document Data by the App takes place on the User's device, including capturing documents, detecting the edges of a page, correcting images, text recognition, creating PDFs, naming documents after their content, and detecting the telephone numbers, email addresses, postal addresses and websites in a document (including creating a contact from a business card). Text recognition uses the Vision framework provided by Apple, which runs on the device.
2. Except where a User shares data as described in Article 9, the App does not send Document Data off the User's device and does not upload it to any server. The Studio operates no server for the App and has no means of knowing the content of any Document Data.

Article 6 (Access to Device Features)

1. The App accesses the device features listed below only when the User uses the corresponding function, and only for the purpose stated for each:
   1. Camera: to capture documents. The camera feed is analysed in the device's memory only to find the page, and is not recorded as video. Only the still images captured as pages of a document are saved (Article 7).
   2. Photos: to import photos, the App uses the photo picker provided by the operating system; the App receives only the photos the User selects and has no access to the rest of the Photos library. The App saves images to the Photos library only when the User chooses to do so, and for that purpose asks only for permission to add items (add-only access); it does not read the photos in the library.
   3. Contacts: only when the User chooses "Add to Contacts" for a business card. The operating system's standard new-contact form then opens, pre-filled with the details read from the card, and a contact is saved only once the User confirms it in that form. The App does not read the contacts already stored on the device.
   4. Files: to import files from, or export files to, other locations, the App uses the document picker provided by the operating system, and can access only the files or locations the User selects there.
2. The User may change the permissions for the camera, Photos and Contacts at any time in the device's Settings app.
3. Images saved to the Photos library and contacts saved to Contacts are kept and managed there under the User's control, including any syncing the User has turned on for them. The Studio has no access to them.

Article 7 (Information Stored on Your Device)

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

2. Owing to the design of the operating system, data in the App's private storage area cannot be accessed by other apps. PDFs are saved in the App's documents folder, from which the User can also open them in the Files app.
3. By deleting a document in the App, the User may erase at any time the data in the table in paragraph 1 that relates to that document (its original images, edits, document information, thumbnail, PDF and Recognized Text). When the App is deleted from the device, all the data described in this Article is erased, except the free-period start date: this is kept in the device's Keychain, which the operating system may retain after the App is deleted and may carry over to a new device through an encrypted backup made by the User. The free-period start date contains no Personal Information. Copies that the User has shared, exported or saved outside the App (paragraph 3 of Article 6 and Article 9) are not affected and remain under the User's control.
4. Depending on the User's settings, the operating system may include the data described in this Article in an iCloud Backup or in a backup of the device made to a computer. Such backups are made by the operating system according to the User's settings and kept where the User has chosen; the Studio has no access to them.

Article 8 (Other People's Personal Information in Documents)

1. Document Data may contain Personal Information about people other than the User, such as that appearing on business cards, invoices, receipts or identity documents. The Studio never receives Document Data, has no visibility into its content, and plays no part in deciding what is scanned, kept 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 scans, keeps or shares documents containing other people's Personal Information should handle it appropriately, as applicable law and the User's relationship with those people require.

Article 9 (Sharing and Other Apps)

1. When a User shares a PDF or an image (by AirDrop, Mail, Messages, another app, saving to Files, or any other means offered by the operating system's share function), the data is sent to the destination the User chooses, by the operating system and the service the User chooses, and is thereafter handled under the terms and privacy policy of that destination and service. The Studio is not involved and receives no copy.
2. Besides the page images, a PDF created by the App contains, where text recognition is turned on, the Recognized Text, so that the PDF can be searched and its text copied; the PDF also records the document's name and date of creation as document information. A User sharing a PDF should note that this information goes with it.
3. When the User selects a telephone number, email address, postal address or website detected in a document, the App passes it to the corresponding app on the device (such as Phone, Mail, Maps or a web browser). What happens next is governed by that app and by the terms and privacy policy of its service; the Studio is not involved.
4. When the User creates a password-protected copy of a PDF, the copy is encrypted on the User's device. The password is used only to encrypt that copy; it 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.

Article 10 (Payments and Subscription)

1. The App offers an optional auto-renewing subscription, "Bonito Scan Pro" (a yearly plan that renews every year; hereinafter "Pro"). The sale of Pro, and its payment, renewal, cancellation and refunds, are handled by the App Store Operator through the App Store. 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 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).
3. Solely to determine whether the free period is running or Pro is active, the App handles the following information on the User's device. None of it is transmitted to the Studio or to any third party:
   1. information on Pro transactions, provided to the App by the App Store Operator through StoreKit (such as the product identifier, the expiry date, the auto-renewal setting and whether a transaction has been revoked, including Pro shared through Family Sharing);
   2. the date on which the App was first obtained with the Apple Account concerned, provided to the App by the App Store Operator through StoreKit (AppTransaction); and
   3. the date and time at which the App was first launched on the device (the free-period start date described in Article 7).
4. Every User may use all features of the App for 30 days from first obtaining it, without signing up or entering payment details. The App treats the earlier of the dates in items (2) and (3) of the preceding paragraph as the start of the free period. Nothing is charged automatically when the free period ends.
5. Whether Pro is active is provided to the App by the App Store Operator through StoreKit each time it is checked, and the App keeps no separate record of it. The Studio operates no server of its own and cannot identify who has made a purchase.

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 Operator. The sale of Pro 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 data described in Article 7 is kept on the User's device until the User deletes the document concerned in the App or deletes the App, as set out in paragraph 3 of that Article; the free-period start date may remain in the device's Keychain after the App is deleted. Images saved to the Photos library, contacts saved to Contacts, and copies the User has shared remain where they were saved until the User deletes them there.

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 data described in Article 7 is protected by the security features of the operating system on the User's device, and password-protected copies of PDFs are encrypted as described in paragraph 4 of Article 9. The User is responsible for the physical and account-level security of the device.

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 (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, in particular before introducing 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 14 October 2026