PontePrivacy Policy
At a glance
This policy explains how winterlog studio ("we", "us") handles personal data in the Ponte app and on our website (ponte.bang9.dev).
- What: the subscription check information RevenueCat receives every time you open the app (anonymous ID, device information, IP address), the text and usage records of Premium translation, and support emails.
- Why: translation, subscription checks and getting purchase and restore ready, the usage limit, abuse prevention, and records the law requires.
- Who and where: we use Cloudflare, OpenRouter, OpenAI, and RevenueCat, which mainly process data in the United States (an international transfer). We do not disclose your data to third parties for their own purposes.
- How long: we do not store the text you translate; everything else is deleted when the period in the retention table below ends.
- Most important: with Premium translation, the text you choose goes to an AI model provider in the United States. With a local model, your text never leaves your Mac.
- Your rights: ask for access, correction, deletion, or restriction using the contact details below.
Who is responsible and privacy contact
The controller of your personal data and our privacy contact (the person who handles questions and complaints about personal data) are:
- Name: winterlog studio
- Owner and privacy contact: Hyungu Kang
- Address: 5-12 Gwangmyeong-ro 347beon-gil, Jungwon-gu, Seongnam-si, Gyeonggi-do, Republic of Korea
- Email: support@bang9.dev
- Phone: +82 10 9688 1157
Purposes and legal bases
We do all of this without asking for consent, on the legal bases below.
| Purpose | Legal basis in Korea | Legal basis in the EU and UK |
|---|---|---|
| Premium translation | Performance of a contract (Personal Information Protection Act, Art. 15(1)(4)) | Performance of a contract (GDPR Art. 6(1)(b)) |
| Subscription check | Performance of a contract (Art. 15(1)(4)) | Performance of a contract (Art. 6(1)(b)) |
| Getting purchase and restore ready (when you open the app, also in local model mode) | Legitimate interests (Art. 15(1)(6)) | Legitimate interests (Art. 6(1)(f)): turning Premium on right away for subscribers and letting you buy or restore |
| Monthly usage limit | Performance of a contract (Art. 15(1)(4)) | Performance of a contract (Art. 6(1)(b)) |
| Abuse prevention and outage handling | Legitimate interests (Art. 15(1)(6)) | Legitimate interests (Art. 6(1)(f)): running the service safely and keeping translation working |
| Answering you | Performance of a contract (Art. 15(1)(4)) | Legitimate interests (Art. 6(1)(f)): answering your questions |
| Delivering and protecting the website | Legitimate interests (Art. 15(1)(6)) | Legitimate interests (Art. 6(1)(f)): running the website safely |
| Fixing bugs (if you turned on sharing with app developers) | Legitimate interests (Art. 15(1)(6)) | Legitimate interests (Art. 6(1)(f)): fixing bugs in the app |
| Keeping refund, withdrawal, and complaint records | Legal obligation (Art. 15(1)(2); Electronic Commerce Act, Art. 6) | Legitimate interests (Art. 6(1)(f)): complying with the Korean record-keeping law that applies to us |
We do not use personal data for advertising, marketing, personalized recommendations, or model training.
What we collect
| Data | When | Required? |
|---|---|---|
| The text you translate (text you select or copy, text you type in Quick Translate, text read from a screen region) and the target language | When you request a Premium translation | Required for Premium |
| Purchase check information (RevenueCat anonymous ID, App Store purchase records), device information (macOS and app version, language and region settings), IP address | Sent by RevenueCat's software in the app every time you open the app | Automatic (also in local model mode) |
| Subscription information (status, plan, end date) | From RevenueCat | Required for Premium |
| Usage records (anonymous ID, amount used, request time) | When we handle a Premium request | Required for Premium |
| Connection information (IP address) | When the app asks our server to check your subscription | Automatic |
| Email address, message, app information (app and macOS version, translation mode) | When you email us (Send Feedback fills in the app information) | Optional |
| Website connection information (IP address, browser information) | When you open the website | Automatic |
| Crash reports and app usage statistics | If you turned on sharing with app developers, Apple passes them to us through App Store Connect (used only to fix bugs) | Optional (turn off in macOS settings) |
Apple handles payment information directly.
What stays on your Mac
The following is handled only on your Mac and never sent to our server.
- Settings: target language, shortcuts, translation mode, local model name, open at login, and app language. They are removed when you delete the app.
- Screen region images: text is read on your Mac with Apple Vision, and the image is never sent.
- Local model mode: text goes only to the model server on this Mac.
- Selected and copied text: Ponte never reads other apps' text on its own. Selected text is received only when you send it with the macOS service "Translate with Ponte" or its shortcut, and copied text only when you press the Copied Text Translate shortcut. Content marked as concealed is never read.
- Screen Recording permission: used only to capture the region you select in Screen Region Translate.
Retention and deletion
| Data | Purpose | Retention period |
|---|---|---|
| The text you translate and the translation | Premium translation | Not stored (only while the request is processed) |
| Connection information (IP address) or anonymous ID with request time | Abuse prevention and outage handling | 2 hours at most |
| Subscription information | Subscription check | 30 days after the subscription ends |
| Usage records | Monthly usage limit | 13 months (monthly totals from the end of the month) |
| Purchase check information kept by RevenueCat | Subscription check, getting purchase and restore ready | Until you ask us to delete it |
| Support emails | Answering you | 3 years after our last exchange |
| Refund and withdrawal requests, complaint emails, and handling records | Keeping records (Electronic Commerce Act, Art. 6, and its Enforcement Decree, Art. 6) | 3 years after our last exchange |
| Crash reports and app usage statistics | Fixing bugs | The period Apple sets |
| Settings | App settings | Only on your Mac |
When a period ends, we destroy the data so it cannot be recovered: server records automatically, emails by permanent deletion from the mailbox. If you ask us to delete your data, we delete the records for that anonymous ID even before the period ends and ask RevenueCat to delete them too. However, refund and complaint records the law requires us to keep stay, stored apart, until their period ends, even if you ask us to delete them. Apple keeps payment and tax records.
Processors and international transfers
We use the companies below as processors. They must use personal data only for the work we give them. Cloudflare, RevenueCat, and OpenRouter are bound by the data processing agreement (DPA) in their terms, which covers using data only for our work, security measures, and managing sub-processors; OpenAI is a sub-processor of the company that forwards the request, Cloudflare (normally) or OpenRouter (when Cloudflare fails), and each manages it under its own agreement with OpenAI; NAVER Mail is bound by NAVER's terms of service and privacy policy.
| Company | What they do for us | Country |
|---|---|---|
| Cloudflare (Cloudflare, Inc.) | Runs our translation server, forwards Premium translation requests to the model provider, stores our database (subscription status, usage, and request records), hosts the website, and forwards support email | United States |
| 네이버 메일 (NAVER Corp.) | Hosts our support mailbox | Republic of Korea |
| OpenAI (OpenAI, L.L.C.) | Runs the translation model | United States |
| OpenRouter (OpenRouter, Inc.) | Forwards Premium translation requests that Cloudflare failed to the model provider | United States |
| RevenueCat (RevenueCat, Inc.) | Checks your App Store subscription and gets purchase and restore ready | United States |
Apple, as merchant of record (reseller), handles payment information under its own privacy policy and is not our processor. If we change or add a provider, we update this table first.
International transfers We transfer the personal data below to the United States over an encrypted internet connection.
| Recipient (contact) | Country | Data | When and how | Purpose | How long they keep it |
|---|---|---|---|---|---|
| Cloudflare (Cloudflare, Inc.) Privacy contact: dpo@cloudflare.com Privacy policy | United States | Text to translate (passed through only), anonymous ID, subscription status record, usage records, IP address, email | Each time the app calls our server, when you open the website, and when an email arrives | Running the service | The periods in the retention table |
| OpenAI (OpenAI, L.L.C.) Privacy contact: privacy@openai.com Privacy policy | United States | Text to translate, target language | Each Premium translation request (through Cloudflare or OpenRouter) | Translation | At most 30 days, for abuse monitoring; never used for training |
| OpenRouter (OpenRouter, Inc.) Privacy contact: privacy@openrouter.ai Privacy policy | United States | Text to translate, target language | When Cloudflare could not handle a Premium translation request | Translation | While the request is processed (can be kept briefly to watch for abuse) |
| RevenueCat (RevenueCat, Inc.) Privacy contact: compliance@revenuecat.com Privacy policy | United States | Anonymous ID, App Store purchase records, device information (macOS and app version, language and region), IP address | Every time you open the app (even in local model mode) and when your subscription is checked | Subscription check, getting purchases ready | Until you ask us to delete it |
- Basis under Korean law: transfers to processors needed to perform our contract, disclosed in this policy (Personal Information Protection Act, Art. 28-8(1)(3)).
- Basis under EU and UK law: we are in the Republic of Korea, which has an EU adequacy decision; for US providers we rely on the Standard Contractual Clauses (SCCs) and the UK Addendum in our data processing agreements, and for OpenAI on Cloudflare's and OpenRouter's contracts with OpenAI. Ask Who is responsible and privacy contact for a copy.
- Saying no, and what happens: with only a local model your text never leaves your country, but you cannot use Premium. The data that goes to RevenueCat (United States) when you open the app cannot be turned off; if you do not want it, do not use the app.
AI translation
- What we send: only the Premium translation text and the target language. What comes back is the translation.
- Who handles it: Cloudflare, Inc. (United States) forwards the request (if Cloudflare fails, OpenRouter, Inc. (United States) forwards it instead) and a model of OpenAI, L.L.C. (United States) translates it.
- How long: we do not store it. OpenRouter and OpenAI can keep requests for the period in their terms to watch for abuse.
- Training: we use only providers set not to train on or collect your text.
- Saying no: with a local model, nothing goes to an AI provider.
Translate text that contains special category data (such as health, beliefs, or biometrics) or other people's personal data with a local model.
Children
Ponte is not directed at children, and we do not knowingly collect personal data from anyone under 13 (under 14 in Korea). We have no parental consent process, so if you learn that a child has sent us personal data, tell Who is responsible and privacy contact and we will delete it right away. We do not show ads targeted at children.
Your rights
You can ask at any time for access and a copy, correction, deletion, restriction and objection to processing based on legitimate interests, portability (in a machine-readable format), and an explanation of automated decisions.
How to ask: email Who is responsible and privacy contact. Because we do not know your name or Apple ID, we may ask for the order ID on your App Store receipt. A legal guardian or someone you authorize can also ask.
When we reply: within 10 days of receiving your request (deadlines by country are in the "Country-specific information" table). Requests are free, and if we turn one down we will tell you why and how to challenge it.
Where to get help: Personal Information Dispute Mediation Committee (1833-6972, www.kopico.go.kr), Personal Information Infringement Report Center (KISA, 118, privacy.kisa.or.kr), Korean National Police Agency cybercrime reports (182, ecrm.police.go.kr).
How we keep data safe
- Communication between the app, our server, and the website is encrypted.
- Access to the server and its dashboards is limited to our owner.
- Expired records are deleted automatically.
Changes to this policy
This policy (version 1) was announced on 2026-10-10 and takes effect on 2026-10-10. If we change this policy, we'll announce it on this page before the change takes effect (on the effective date at the latest) and show what changed side by side with the previous version. If a new purpose or a new recipient is added, we'll announce it on this page before that processing starts and ask for your consent where the law requires it.
Language
This document was originally written in Korean. Translations are provided for convenience. If they differ, the original prevails, unless the law of the country where you live says otherwise.
Country-specific information
You can exercise the rights below by contacting Who is responsible and privacy contact. Data is processed in the United States (providers) and the Republic of Korea (us).
| Country | Law | Rights | When we reply | Where to complain |
|---|---|---|---|---|
| EU, EEA, UK, Switzerland | GDPR, UK GDPR, Swiss Federal Act on Data Protection | Access, correction, deletion, restriction, objection, portability | One month; if complex, we tell you within that month that we need up to two more months, and why | The supervisory authority where you live, work, or think the problem happened (in Switzerland, the FDPIC). In the UK, complain to us first; if we cannot resolve it, the ICO |
| United States | State privacy laws (California and others) | To know, delete, correct, opt out of sale or sharing, and not be discriminated against | 45 days; appeals of a denial, 60 days | Appeal by replying to the same email |
| Japan | Act on the Protection of Personal Information | Disclosure, correction, suspension of use | — | Us |
| Brazil | LGPD | Rights under Art. 18 (confirmation, access, correction, anonymization, blocking, deletion, portability, information about who we share with, information about refusing consent, and more) | — | ANPD |
| Mexico | LFPDPPP | Access, correction, cancellation, objection (ARCO) | 20 days | — |
| Colombia | Law 1581 of 2012 | To know, update and correct, delete, ask for proof of the basis for processing | Queries 10 business days, claims 15 business days | SIC |
| Chile | — | Access, correction, deletion, objection, portability, blocking | — | — |
| Argentina | Law 25,326 | Free access (see below) | — | AAIP |
| Australia | APP | Complaints | 30 days | OAIC |
| India | — | Access, correction, erasure, grievance redress, nominating someone to act for you | — | Grievance officer (our owner) |
| Vietnam | — | Access, correction, deletion, restriction, objection | — | — |
| Türkiye | KVKK | Rights under Article 11 | — | — |
| Indonesia | — | Access, correction, deletion, stopping processing | — | — |
- All countries: we make no decisions or profiling based solely on automated processing of your personal data that have legal or similarly significant effects. Whether you must give data is in the "Required?" column of the data table.
- EU, UK, Switzerland: you can object at any time to processing based on legitimate interests; if you do, we stop unless we have compelling legitimate grounds. For transfers from Switzerland to the United States we rely on the Swiss-U.S. Data Privacy Framework or standard contractual clauses recognized by the FDPIC.
- United States: we do not track you across other sites or apps and do not let others track you on our website, so we do not respond differently to Do Not Track signals (CalOPPA). In the past 12 months we collected identifiers (anonymous ID, IP address), commercial information (subscription status), internet activity (request records), and text you wrote. We do not sell personal information or share it for targeted advertising, do not collect sensitive personal information, and do not sell or share the information of anyone under 16. We confirm that agents are authorized.
- Japan: we set our security measures after understanding the privacy systems of the United States and the Republic of Korea. For the US providers, instead of consent we rely on each provider having a system, under its data processing agreement, to keep taking protective measures at the level Japanese law requires (Art. 28(1)). On request, we will tell you about that system, the providers' measures, and how and how often we check them (Art. 28(3) and Rule 18 of the Enforcement Rules).
- Brazil: the controller is winterlog studio, and the data protection officer (encarregado) is our owner. The legal bases are performance of a contract (Art. 7, V) and legitimate interests (Art. 7, IX); international transfers (Art. 33) are in the Brazil notice below.
- Mexico: every purpose is necessary to provide the service, with no secondary purposes. International transfers go to processors and do not require separate consent.
- Argentina: you can access your data free of charge every six months, or more often if you show a legitimate interest (Law 25,326, Art. 14(3)). The Agency for Access to Public Information (AAIP), the authority for Law 25,326, receives complaints about breaches of that law.
- Canada (including Quebec): personal information transferred outside Quebec goes to the places in the international transfers table, and we assessed its protection before the transfer.
International Transfers of Personal Data (Brazil)
We provide this notice under ANPD Resolution 19/2024.
- How: transfers to processors needed to perform our contract, protected by the Standard Contractual Clauses (SCCs) in our data processing agreements. The ANPD standard contractual clauses are not yet part of those agreements.
- Country, recipients, purpose, duration: the United States; the providers, purposes, and retention periods in the international transfers table.
- Responsibility: winterlog studio is responsible as controller.
- Your rights: the Brazil rights under "Country-specific information".
- Onward transfers: when a provider transfers data onward to its sub-processors, we require the same protection.