PrivBoard
Bahasa Indonesia

PrivBoard Privacy Policy

Last updated: · Bahasa Indonesia

This document is a draft and has not been reviewed by a lawyer.

In short: PrivBoard is a keyboard. What you type is processed on your phone and is not sent to us or stored by us. It also has an optional translate overlay, off by default, that reads text on your screen to translate it on your phone; that text is not stored or sent either. We have no accounts. The only personal data we deal with is your subscription status (through the app stores and RevenueCat), the messages you send to support, and, if you accept analytics cookies, anonymous usage statistics on our website.

1. Who we are

PrivBoard ("we", "us") is a keyboard app for Android, and for iOS once it is released, together with the website at https://privboard.360framed.com (together, the "Service"). The data controller is Jason Pieter Kusumajaya, an individual sole trader, of Jl Taman Ubud Asri I No. 15, Tangerang, Banten 15810, Indonesia. For any privacy question or request, write to privacy@privboard.360framed.com.

2. How the keyboard handles what you type

Like every keyboard, PrivBoard receives each key you press so that it can show it in the text field. This is what it does with it:

  • It shows what you type in a preview bar on the keyboard, and it keeps the word you are typing in memory.
  • When you finish a word, it translates that word on your phone into a language picked at random from the list you chose, and writes the result to the app you are typing in.
  • It keeps a short history of the current sentence in memory so that Backspace can work. That history is cleared when you leave the text field.
  • It does not write what you type to storage, does not send it to us, and does not send it to any server.
  • Translation and word suggestions use dictionaries that are bundled inside the app. They run on your phone, need no internet connection, and learn nothing from what you type.
  • In password, email address, web address, number and phone fields, it passes your key presses straight through and does not buffer or translate them.

Optional translate overlay. PrivBoard Translate Overlay is a separate feature, off until you switch it on. It uses Android's Accessibility service, which you must enable yourself in your phone's settings after we show you a notice. When it is on:

  • It reads the text that is visible on your screen in other apps, together with where that text sits on the screen. It does not read password fields or text you type into input fields, and it does nothing in apps you put on its skip list.
  • It works out the language of each piece of text on your phone, and translates the text that is not already in the language you chose. It draws the translation over the original in a floating layer.
  • The text is held in memory only while it is being translated and shown. It is not written to storage, not logged, and not sent to us or to any server. Typed keyboard text never goes through this feature.
  • The translation uses Google's ML Kit on-device models. The language packs are downloaded once from Google, which receives a normal download request (for example your IP address). After that, translation works without internet. The text you translate is not sent to Google.
  • You can switch it off with the floating button, or by turning the service off in Android settings. The same limits apply: it hides nothing and is not encryption, and the translated text is only shown on your screen.

The app you type into receives the translated words. What that app does with them is governed by its own privacy policy. Translation hides your text from people and apps that read the field. It is not encryption, and anyone who understands the languages involved can still read it.

3. Personal data we handle

  • Stored on your device only: your settings (palette, languages, keyboard options), a cached copy of your subscription status and its end date, and, if you choose one, a background photo. The photo is chosen with the system photo picker, copied into the app's private storage and never uploaded.
  • Subscription data: the app stores sell the subscription. RevenueCat, which we use to manage subscriptions, receives an anonymous app user ID generated for your installation, the store receipt or purchase token, the product and its dates, your store country and device platform, and your IP address as part of each request. We never see your payment card or your store account password.
  • Support: if you write to us, we receive your email address and what you send.
  • Website: our host keeps server logs (IP address, time, pages requested). If you accept analytics cookies, Google Analytics 4 records aggregated usage of the website.

We do not collect the text you type or the text the translate overlay reads, contacts, location, microphone or camera data, health or biometric data, advertising identifiers, or a name or email address through the app. The app has no accounts.

4. Device permissions

  • Keyboard: you switch PrivBoard on in your phone's keyboard settings. Android warns that a keyboard can read what you type. That is true of every keyboard, and section 2 explains what ours does.
  • Accessibility service: only for the optional translate overlay. You turn it on yourself in Android settings. PrivBoard uses it to read visible text on screen for translation, as section 2 explains, and for nothing else. It does not use it to perform gestures or taps for you.
  • Photos: only when you choose a keyboard background. The system photo picker gives the app the one image you pick.
  • Internet: used by the app to take a purchase and to check your subscription. The keyboard itself sends nothing over the network. The translate overlay uses the internet only to download language packs from Google.
  • The iOS keyboard has not been released. This policy will be updated before it is, including what it asks for.

We handle personal data to provide the keyboard and your settings, to manage your subscription, to answer support requests, to keep the Service secure, and, with your consent, to understand website usage. Where the GDPR, the UK GDPR, Indonesia's Personal Data Protection Law (UU No. 27 of 2022, "UU PDP") or a similar law applies, we rely on: performance of a contract for the keyboard and subscription; legitimate interests for support, security and fraud prevention; legal obligation for tax and accounting records; and your consent for analytics cookies, which you can withdraw at any time.

We do not use personal data for advertising, we do not sell it, we do not use it to train AI models, and we do not make decisions about you by automated means that have legal or similarly significant effects.

6. Processors and recipients

  • Apple Inc. and Google LLC: sell and bill store subscriptions and verify purchases, under their own privacy policies. They are separate controllers of your purchase data.
  • RevenueCat, Inc. (United States): manages subscriptions and entitlements for us as our processor.
  • Google LLC (ML Kit language packs): supplies the on-device translation models you download for the translate overlay. It is not given the text you translate.
  • Google LLC (Google Analytics 4): website statistics, only if you accept analytics cookies.
  • Dewaweb (Indonesia): hosts the website and our email.

We share personal data only with these recipients, for the purposes above.

7. International transfers

Your data may be processed outside your country, including in Indonesia and the United States. Where personal data leaves the EEA, the UK or Indonesia for a country without an adequacy decision, we rely on appropriate safeguards such as Standard Contractual Clauses, and we require our processors to do the same.

8. Retention

  • Data on your device stays there until you clear the app's data or uninstall it.
  • Subscription records are kept by the stores and RevenueCat for as long as the subscription lasts and as the law requires for tax and accounting. We can ask RevenueCat to delete the records tied to your anonymous app user ID.
  • Support emails are kept for as long as needed to answer you and for up to 24 months after your last message.
  • Server logs are kept for the limited period set by our host.
  • Analytics data is kept for the retention period set in Google Analytics, which we configure to 14 months or less.

9. Security

Connections to our website and to the services we use are encrypted with TLS. Because typed text is processed on your phone and not stored, it is not available to be taken from our systems. If a personal data protection failure occurs, we will notify affected users and the competent authorities within the time the law requires, including within 3 x 24 hours under Article 46 of UU PDP and within 72 hours under the GDPR where it applies. Report a security issue to security@privboard.360framed.com.

10. Your rights

Subject to applicable law, you may ask to access your personal data, correct it, delete it, receive a portable copy, restrict or object to its processing, and withdraw consent. The page "Your data rights" explains how to make a request, and we answer within 30 days, sooner where the law requires.

  • Indonesia: UU PDP applies to our processing. You may complain to the personal data protection authority designated under UU PDP.
  • European Economic Area, United Kingdom and Switzerland: the GDPR, the UK GDPR and the Swiss FADP apply. You may complain to the supervisory authority where you live or work, for example the ICO in the United Kingdom.
  • California and other US states: in the preceding 12 months we have collected identifiers (the anonymous app user ID and IP address), commercial information (subscription records) and internet activity (website analytics, with consent), for the purposes in section 5. We do not sell personal information, and we do not share it for cross-context behavioral advertising. You may request to know, delete and correct, and we will not discriminate against you for doing so.
  • Brazil: if the LGPD applies to you, you may use the rights in Article 18 of the LGPD by contacting us.

11. Cookies

The app does not use cookies. The website uses cookies only as described in the Cookie Policy, and the optional analytics cookies are set only after you accept them.

12. Children

PrivBoard is not directed at children under 13, and you must be at least 13 (or the higher age of digital consent in your country) to use it. See the Children's Privacy Notice, which includes our COPPA statement.

13. Changes to this policy

We may update this policy. We will give at least 30 days' notice of material changes in the app or on our website, and the date at the top always shows the current version. A change that only adds a new optional use of data will not apply to you until you choose it.

14. Contact

Jason Pieter Kusumajaya, trading as PrivBoard, Jl Taman Ubud Asri I No. 15, Tangerang, Banten 15810, Indonesia. Email: privacy@privboard.360framed.com.