1. Overview
This Privacy Policy applies to Clipex (the “App”), provided by MindifyScape Technology Co., Ltd. (“we”, “us”, or “our”).
The App is a local-first clipboard management tool. We do not operate any proprietary servers, and your data is stored on your device by default.
2. Data Controller
For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), the data controller is:
⚠️ Important Notice: Although we are legally considered a “data controller”:
- Company Name: Shanghai Xinyue Xinghe Technology Co., Ltd.
- Contact Email: support@mindifyscape.com
- We do not collect, store, or access your personal data
- Your data resides only on your device or within your iCloud account
- We have no access to your data content
3. Data Collection and Processing
The App does not upload any data to developer-operated servers.
All data is processed locally on your device, including:
- Clipboard content (e.g., text, images)
- Favorites and history records
- User settings and preferences
4. Clipboard Data and Sensitive Information
The App accesses the system clipboard to provide its core functionality.
Please note:
We recommend avoiding long-term storage of sensitive information.
- Clipboard content may include sensitive information (e.g., passwords, verification codes)
- The App does not upload, analyze, or share such data
- All data remains on-device or is synced via iCloud (if enabled)
5. Data Storage and iCloud Synchronization
⚠️ All data is stored locally on your device at all times.
If you enable iCloud synchronization, your data will be synced across your devices using Apple’s CloudKit and may be stored within Apple’s iCloud infrastructure.
At no point does your data pass through or get stored on our servers.
6. Legal Basis for Processing (GDPR)
For users in the European Union / European Economic Area, data processing is based on:
- Performance of a contract (to provide App functionality)
- Legitimate interests (ensuring proper operation of the App, limited to local processing)
- User consent (when enabling iCloud synchronization)
7. Use of Data
Data is used solely for:
We do not:
- Used for: providing App functionality
- Used for: local search and management
- Used for: improving user experience
- We do not: sell or share your data
- We do not: use data for advertising or tracking
- We do not: upload data to developer servers
8. Data Storage and International Transfers
- Local data is stored on your device
- iCloud data may be processed through Apple’s global infrastructure
9. Your Rights (GDPR)
You have the right to:
Since we do not hold your data, you can manage it directly on your device or via iCloud.
- Access, correct, or delete your data
- Restrict or object to processing
- Data portability
10. Data Security
- Local data storage
- Apple iCloud security mechanisms
- No developer-side data copies
11. Third-Party Services
The App only uses:
No advertising or analytics SDKs are included.
- Apple iCloud / CloudKit
12. Payments and Transactions
The App offers subscriptions and one-time purchases.
All transactions are processed by Apple. We do not have access to your payment information.
13. Children’s Privacy
The App is not specifically directed to children.
We do not knowingly collect, store, or process personal data from users of any age.
All data remains on the user’s device or within their iCloud account.
If you are a parent or guardian and believe that a child has stored sensitive information within the App, you may manage or delete such data directly on the device or via iCloud.
14. Changes to This Policy
We may update this Privacy Policy from time to time.
Updates will be published within the App or on the App Store.