Effective Date: July 11, 2026
Last Updated: September 15, 2026
Banakai (the “Operator”) establishes this Privacy Policy (the “Policy”) to explain how information is handled in connection with the Clopass mobile application (the “App”).
This Policy applies from the date version 2.1.0 of the App becomes available.
The App is designed as a local-first application, with data primarily stored on the user’s device.
During normal use without backup or note sharing—including viewing, creating, and editing notes, studying with cloze exercises, and taking tests—the App does not transmit note content, inserted images, or study data to the Operator’s cloud services. Section 3.1 describes what happens when automatic backup is enabled.
The App does not collect user data for advertising, behavioral tracking, analytics, or marketing purposes.
The App stores the following information on the user’s device:
As a general rule, this information is stored on the user’s device. Only when the user uses backup, data restoration, or note sharing does the App transmit the data required to provide that feature to and from the cloud.
Cloud features handle encrypted data associated with the relevant feature.
When a cloud feature is used for the first time, an internal identifier may be created as necessary to provide that feature. Users are not required to register a name or email address, but the internal identifier distinguishes users of cloud features.
When cloud features are used, external service providers may process the internal identifier, communication date and time, IP address, and other communication or security-related information.
Management information for backups and shared data includes associations with internal identifiers, creation and update times, and the size of encrypted data. This information is used to provide features, prevent misuse, and identify data for deletion. It is handled separately from the encrypted note content and images themselves.
If a user contacts the Operator by email, the Operator will handle the user’s email address, inquiry details, and any other information necessary to respond.
The photo picker provides the App only with images selected by the user, not the entire photo library. Images from the clipboard are retrieved when the user performs a paste action. Imported images are stored on the device and may be resized or compressed as needed.
When the user enables automatic backup or performs a manual backup, the App compresses and encrypts eligible on-device data, including images inserted into notes, on the device before storing it in the cloud.
In backups created by this feature, note content, inserted images, and study data are not stored in the cloud in an unencrypted form.
Recovery codes and other information required to restore data are generated on the device and are not transmitted to the same cloud service that stores the encrypted backup.
Disabling automatic backup stops future automatic backups. However, backups that have already been created may remain stored until the user deletes them.
Recovery codes and other recovery information are used by the user to restore data.
When available, the App may store only the information required for recovery in Apple’s iCloud Keychain.
Note content, inserted images, study history, and test history are not stored directly in iCloud Keychain.
When the user creates a sharing link, the App encrypts the shared note’s title, content, paragraphs, cloze information, and related data on the device before storing them in the cloud.
Study history, review history, test history, app settings, and similar information are not shared.
Images inserted into notes are excluded from sharing links. In shared text, images are replaced with “［画像省略］” (image omitted), and image data is not uploaded as part of the shared data.
A sharing link allows anyone who has the link to duplicate and import the shared note. Do not post a sharing link in a place where unintended third parties may access it.
Edits made to a note after its sharing link has been created are not reflected in the existing shared copy. To share the latest version, create a new sharing link. Creating a new link invalidates the previous link.
To allow users to resume a previous study session, the App stores the last note opened, reading position, cloze and hint states, and the date and time the note was last viewed on the user’s device.
This information is overwritten with the latest state and is not added or accumulated each time the note is viewed.
This information is not included in encrypted backups or note-sharing data and is not transmitted to the Operator’s cloud services.
For users updating from an earlier version of the App, the App may retrieve and convert previously stored data only to the extent necessary to migrate that data to the current version.
The retrieved data is migrated to the on-device database and is not used for any purpose other than migration.
Notes and study data previously stored in the cloud by earlier versions may be associated with an earlier-version user identifier. Migration uses that association to retrieve the relevant data. The description of the current encrypted backup feature does not mean that data already stored by earlier versions is automatically re-encrypted.
If the data cannot be migrated successfully, the user may choose to start using the App from its initial state without importing the previous data. In this case, the previous data will not be migrated.
The App uses the following third-party services only to the extent necessary to provide its features:
These services may process information outside Japan. Information handled by each service is also subject to that service provider’s terms of service and privacy policy.
The Operator does not sell user data or disclose it to third parties for advertising purposes beyond what is necessary to provide the features described in this Policy.
The Operator handles information only for the following purposes:
Data stored on the device remains there until the user deletes it within the App or removes the App from the device.
Encrypted cloud backups, shared data, and identifiers used for cloud features are retained for as long as necessary to provide the relevant feature or until the user deletes them.
Using the App’s “Delete All Data” feature deletes data stored on the device, related data stored in the cloud, and recovery information saved by the App in iCloud Keychain. Due to processing requirements, it may take a reasonable amount of time for deletion from the cloud to be fully reflected.
Uninstalling the App alone may not automatically delete data stored in the cloud or recovery information stored in iCloud Keychain.
As a general rule, users should delete their data through the App’s “Delete All Data” feature. If you have questions about deleting data or how your data is handled, please contact us using the information at the end of this Policy. We may be unable to fulfill a deletion request if we cannot verify the requester or identify the relevant data.
The Operator does not disclose user information to third parties except in the following circumstances:
The Operator takes reasonable administrative and technical measures to protect the information it handles against unauthorized access, disclosure, loss, destruction, or alteration.
However, the Operator cannot guarantee the complete security of communications or data storage. If an incident occurs, the Operator will take the actions required under applicable law.
The App is not specifically designed for children under the age of 13, or any higher minimum age required by applicable law in the user’s jurisdiction.
The App does not require users to register their name or email address. If a child uses the App, a parent or legal guardian should supervise its use where required by applicable law.
If you believe that a child has provided personal information to the Operator through an inquiry or by other means, please contact us using the information below.
The Operator may update this Policy in response to changes in the App’s features, applicable laws, or other circumstances.
Any updated version of this Policy will be made available on this page.
For questions about this Policy, the handling of data, or data deletion, please contact:
Operator: Banakai
App: Clopass
Email:
banakai.support@gmail.com