CROFTLY App Privacy Notice English version dated 5 November 2026 This notice describes data processed when using Croftly for macOS and its licensing and support services. It applies to Free, Premium and trials, according to the features available and enabled. Documents, Crofts and imported email are processed mainly on your Mac and are not automatically uploaded to Croftly services. Email connections, purchases, updates, web search, voice input and sharing involve the processing described below. Browsing web pages is covered by the Croftly Website Privacy Notice. Invitees to the preview website are also covered by the Restricted Preview Website Access Privacy Notice. Website credentials are separate from the app licence. 1 Controller and contacts The data controller is Giuseppe Domenico La Fauci, a self-employed professional, Italian VAT number 03758170835, with a professional address at Strada Panoramica dello Stretto 1416 G9, 98168 Messina, Italy. For information or to exercise data protection rights: support@croftly.com. The Controller manages data for online services, licences and support. Installing the app does not give him general remote access to content on your Mac. If you use Croftly in your business to process other people’s data, you remain responsible for obligations relating to your purposes, authorisations and notices. 2 Scope and sources of data Data may be provided directly by you, generated by requested operations, received from an email provider you authorise, communicated by the seller to manage a purchase, or technically generated by connections to online services. The integrations described apply only when available in the version used and enabled by the User. 3 Local content files and search Croftly stores Land, Croft and module content on your Mac, such as text, notes, tables, relationships and file references. To support search, it may extract text and metadata and retain them in local indexes. Spotlight integration may make content searchable through macOS. Backups, synchronisation and shared folders configured by the User may create additional copies or transfers to chosen services. Linked files remain in your chosen locations. Croftly retains references and permissions needed to find them; linking does not upload them to a Croftly server. Archives, indexes, previews and caches may contain personal data. Their protection also depends on permissions, encryption and access configured on the Mac. 4 Email and credentials Only after an account is connected with authorisation does Croftly process the email address, provider, account identifiers, selected folders and data needed to import messages. These may include message identifiers, senders, recipients, subjects, dates, text, attachments and technical metadata. Imported copies, attachments and extracted text support viewing, searching and organising email and requested local processing, such as summaries and comparisons. An import date filter does not automatically delete messages already imported. Connections go directly from the Mac to the provider, which receives requests and network data under its own privacy notice. The mailbox does not pass through a Croftly server. For Microsoft, sign-in takes place with the provider: Croftly receives access authorisations without obtaining the main password. Gmail connects through IMAP using an app password generated by the User in their Google Account settings, where their account permits this; the main password is not requested. Other supported IMAP accounts use the credential required by their provider. Credentials are stored in the macOS Keychain. Stored credentials allow enabled email updates without signing in each time. Viewing features do not send messages or delete originals on the server. For Gmail, Croftly uses the app password to read email over an encrypted connection; the password is not a Google authorisation restricted to read-only access. Croftly’s operations are limited to the features described in this notice. Opening links or external content may send requests to the relevant websites. Including email text in a web search discloses it to the chosen search engine. 5 Use of email data Data obtained from email providers are used solely for the visible features requested by the User and described in this notice. These data are not sold, used for advertising or commercial profiling, disclosed to data brokers or used to assess creditworthiness. They are not used to create, train or improve general-purpose artificial intelligence models. These limits also cover derived, aggregated or anonymised data. Synchronisation does not transmit email to Croftly licensing, payment or support services. The developer has no ordinary access to messages: for support, he may examine only specific content you knowingly choose to send, within the scope of your request. Any other access or disclosure needed for security or legal obligations must fall within exceptions permitted by policies and law. Any disclosures and access by collaborators or suppliers follow the same limits. Prior consent is obtained for transfers connected with a business transfer where required by Google policies. Providers’ own privacy notices and the terms applicable to the chosen connection method govern their independent processing. 6 Artificial intelligence OCR voice and web search Natural-language search, summary and comparison features based on Apple Intelligence process selected content, including email, on the Mac. For these features, Croftly does not send content to a remote artificial intelligence service or use it to train models. Built-in OCR processes images locally. If you configure external OCR tools, files pass through your chosen folder and may produce copies, text and processing logs. Synchronisation or online features of chosen tools follow the processing rules of those services. Voice input is optional and requires microphone and speech recognition permissions. It uses on-device recognition when available; otherwise, audio may be sent to Apple services for transcription under applicable notices and settings. You can enter text without enabling the microphone. Web search through Kagi is optional and requires your API key, stored in the Keychain. Choosing Web or Both sends Kagi the query and, when needed, URLs of pages to extract, together with connection data and information needed for authentication. Text you enter in a query may include personal data. Web search does not automatically upload your Croft archive or mailbox. You choose what to put in the query. Kagi’s privacy notice and API terms for your account apply; local features remain available without web search. 7 Purchases licences and devices Paddle handles sales, payments, invoicing, taxes and fraud prevention under its own terms. The relevant entity is identified at checkout and in transaction documents. Croftly receives email, customer and purchase references, payment and subscription status to issue and manage licences. The activation service does not receive full card details. When you request Premium supply during the withdrawal period, we record the declaration’s text and version, language, time of choice, plan and order references. We send confirmation to the purchase email address and retain evidence needed to document the relationship and protect rights under the retention criteria for licences and transactions. This contractual choice is not general consent to personal data processing. You can recover licences using the email address used for purchase, even without the previous browser session. The link can be used once and expires after 15 minutes. To handle the request and prevent abuse we process email, language, verification references and technical identifiers derived from the email address and connection. Licence activation and verification transmit the code or activation authorisation, an app-generated identifier, the Mac’s name where available and the app version. The identifier can be associated with the licence and is not the Mac’s serial number. The device name may contain a person’s name. Licence references, plan, status, relevant dates and activations needed for device management and support are retained. Connections also generate normal network and security data for online services. These data do not include Croft or mailbox content. These activities may also concern free, promotional or trial licences. EULA acceptance records. Including in Free, the app keeps the presented texts on the Mac and records explicit EULA acceptance, the date reported by the device, language, document version and a random technical installation identifier. This information, together with document hashes and the app version, is sent to Croftly services at the next usable connection while the app is running. Failed transmissions remain queued on the Mac. Email is not required for this Free record; for Premium it may be linked to the verified licence. The register distinguishes the time reported by the Mac from server receipt and does not certify the user’s personal identity. It does not contain documents, notes or email organised in Croftly. 8 Software updates In versions with updates configured, the app contacts services needed to check availability and download updates, according to available settings. Recipients receive the IP address, request time and technical data needed for checking and distribution. These data are used to provide updates, diagnose errors and protect the service. Log retention is described in section 13. 9 Support communications and confirmations The Contact Us form collects email, topic, subject and message; app and macOS versions are optional. The request is recorded as a ticket and forwarded to the support mailbox; confirmations and subsequent exchanges take place by email. Attachments, screenshots and diagnostic data are processed for the request to which they relate. Send only what is needed, redacting unrelated data, passwords and other credentials. Necessary communications about licences, support, security and contracts are part of the service. Installation and purchase do not automatically subscribe you to a newsletter. Before use, the app presents the EULA and makes the Privacy Notice available. It locally retains the version and fingerprint of the presented texts, language, date and express EULA acceptance to remember the choice and present updates. It does not require general consent to the Privacy Notice; the contractual record is transmitted as described in section 7. 10 Purposes legal bases and choices Documenting EULA acceptance, including the Free installation register, relies on the legitimate interest in proving the terms presented and the establishment of the licence relationship and protecting rights, after assessing necessity, proportionality and effects on individuals. The identifier is random and the record is not used for profiling or statistics about activity inside Crofts. For processing subject to the GDPR, managing purchases, issuing and verifying licences and providing requested support relies on performing a contract or taking pre-contractual steps requested by the individual, where the data are necessary. For contacts acting for an organisation, legitimate interests in managing the professional relationship may apply within legal limits. Tax and accounting obligations and legally binding authority requests rely on compliance with legal obligations. Protecting services, preventing unauthorised access, managing incidents and defending rights may rely on legitimate interests after assessing necessity, proportionality and effects on the individual. Features and integrations perform requested operations. System or provider permissions enable technical access without constituting general consent to further processing. Where necessary, consent is requested separately and may be withdrawn without affecting the lawfulness of earlier processing. Data needed for licensing or payment must be provided to obtain that service. Refusal may prevent activation, purchase or support without making unrelated additional data mandatory. Connecting email, using Kagi, configuring external OCR or sharing content remains optional and affects only features that require those choices. We do not request health data or other special categories of data to purchase or activate Croftly. If present in your local content, they remain subject to your use choices. Avoid sending them to support unless necessary and agreed in advance; processing requires the additional conditions prescribed by law. 11 Recipients and external services Data are accessible to the Controller and authorised persons within their duties. Suppliers acting on his behalf are subject to confidentiality, security and processing agreements compliant with applicable law; independent parties are responsible for their own processing. Recipients include hosting and database providers for licensing and support services; network, distribution and protection providers for the website and downloads; and email providers for delivery and storage of support requests. Each accesses data needed for its service: these relationships do not automatically upload archives or email imported into the app. Paddle processes sales data. Your chosen email account providers, Apple for any remote speech recognition, and Kagi for web search receive data described in the relevant sections. Their privacy notices are listed at the end of this document. Relevant data may be disclosed to administrative or legal advisers and authorised authorities. A business transfer remains subject to original purposes, safeguards and any required consents, including Google data restrictions. 12 International processing The Controller operates in Italy. The main infrastructure used for the website, licensing and support services and support mailbox is in France. Network and protection services, payment services and User-chosen integrations may involve processing outside the European Economic Area, including in the United States. European hosting does not exclude international access or additional processing by the services involved. For GDPR-regulated transfers made by the Controller or on his behalf, safeguards appropriate to the recipient apply: adequacy decisions within their scope, including those covering US recipients participating in the Data Privacy Framework where applicable, or standard contractual clauses and necessary supplementary measures. These mechanisms do not indiscriminately cover every recipient or country. Reading this notice is not general consent to transfers. You can request information about recipients, countries and a copy of applicable safeguards from support@croftly.com. Connected services’ notices describe processing for which they are independently responsible. Additional prior information required by local law, including recipient countries, must be made available for the relevant processing. 13 Data retention EULA acceptance retention. The current record and presented texts remain on the Mac; older local copies are reviewed after 36 months. On the server, Free records are removed 36 months after the last event received. Records linked to Premium are kept during the relationship and for 36 months after it ends; data needed for an actual dispute or legal obligations may be isolated with restricted access for a justified period. Cleanup runs at the service’s next available execution. Local content. Archives, email copies and indexes remain on the Mac for requested features until deleted through app operations. A connection interruption or uninstalling does not necessarily delete these data. Exports, shared Crofts, OCR folders and backups may retain separate copies. Caches and temporary files. Attachment copies still referenced by data in the app remain available for viewing and search. Maintenance deletes unreferenced Mail cache files that have not been written or reused for at least 30 days. App-managed temporary processing files are removed when work ends; recognised abandoned files are deleted at the next maintenance run. If verification fails or a folder is inaccessible, cleanup is deferred. Local OCR logs. In versions implementing these controls, the OCR procedure log uses a 30-day window and a 1 MiB limit, which may remove older entries sooner. It contains times and event codes without document names, paths or extracted text. Cleanup runs at startup, periodically during use and when writing. A powered-off Mac or unavailable folder defers it to the next available run. External scripts require the updated version from the guide; operating system logs follow separate rules. OCR working copies. Copies recognised and verified by the Croftly OCR procedure are moved to macOS Trash, where they remain until you empty it or system settings do so. If verification or moving fails, copies are retained. The OCR log’s 30-day period does not apply to these copies or original documents. Local backups. Automatic copies follow daily and weekly rotation; emergency and pre-migration copies remain for recovery. There is no single maximum period for all local backups. You can delete app-managed copies through Settings > Backup > Delete local backups; exports and copies held by other programs must be managed at their destinations. Licences and transactions. Data needed to manage a licence remain usable for the relationship’s duration. Afterwards, only information needed for administrative obligations, documented fraud prevention or protection of rights is retained, taking account of applicable legal periods and actual open disputes. Tax documents follow their own obligations; not all technical licence data need to be kept as long as an invoice. Licence recovery. Contact and verification data for a request are removed after the link is used or expires; temporary request records are kept for 24 hours. Cleanup takes place at the next available service run. Licence data, received emails and backup copies are separate and follow their respective retention criteria. Support. We retain tickets, correspondence and relevant attachments to handle requests, document interventions and maintain continuity of support, including after an individual ticket closes. Duration takes account of the relationship, subsequent requests and the need to reconstruct earlier problems and solutions. The need for history is reviewed over time, considering conversations as a whole. Systematic deletion of individual attachments is not planned; targeted action on unrelated data or justified erasure requests remains possible, subject to legal obligations and protection of rights. Online service logs. Application logs collected in Croftly’s service monitoring system are retained for 7 days. This period covers that application collection and is not a universal period for every external service’s technical logs. Extracts needed to document a specific incident or dispute may be retained separately, with limited access, for the time necessary to manage it or protect rights. Support correspondence follows the separate rule above. Local confirmations and revocations. The local EULA acceptance record remains to remember the choice and version presented. To prevent an older backup reactivating a removed Mail account, the app separately retains local revocation identifiers without message content or access credentials. These remain as long as needed to prevent reactivation of older copies. Any contractual evidence received by the Controller follows the relationship’s necessity and protection periods. Automatic backups of Croftly service databases are kept for 7 days from creation: deleted database data may therefore remain in earlier backups until they expire. This does not cover local app backups, support mailbox backups or User-chosen services. Data no longer needed are deleted or anonymised; residual backup copies are excluded from ordinary use and removed under the applicable cycle. 14 Account removal and local deletion To remove an account, open Settings > Mail, choose Remove and confirm. Croftly stops access and deletes credentials, imported message copies, attachments in the app cache, extracted text and related index entries. Removal includes notes and relationships associated with deleted messages, including modules in Trash. It does not delete the mailbox or originals held by the provider, or other accounts. Copies removed from the app cannot be recovered through this operation. If removal is interrupted or fails, access remains suspended and the app attempts to finish at the next launch and during maintenance. You can also repeat Remove in Mail settings. An error is not presented as successful deletion. Exports, shared Crofts, separately saved attachments, external OCR folders and backups must be managed at their destinations. App deletion does not recall copies already supplied to others. You can also revoke the connection authorisation or app password in the provider’s settings. For Gmail, remove the password created for Croftly from the App passwords page of your Google Account. Removing an account from Croftly does not automatically revoke the password with Google; revocation with the provider alone does not delete local copies already imported. Use app features to delete other content, taking account of Trash and separate copies. The local backup deletion command removes automatic, emergency and pre-migration copies and cancels a pending restore; it does not delete the current archive or disable future backups. The Controller cannot remotely delete archives stored only on your Mac, but can assist with available operations. After a crash, the app checks pending recovery operations and temporary files it can identify with certainty. An incomplete restore resumes before opening the archive; if it cannot be verified or completed, opening stops. Valid copies and source files are not deleted merely because they are old or not immediately identifiable. These checks do not guarantee recovery of every unfinished change. 15 Security and incidents Credential, connection and access safeguards proportionate to the data and risks are adopted. Local content security also depends on protecting the Mac and backups. No measure guarantees absolute security. Keep the app and system updated, limit Mac access and protect credentials and backups. These precautions do not remove the Controller’s obligations. For breaches under the Controller’s responsibility, containment measures and any legally required notifications and communications are made. To report an incident: support@croftly.com. 16 Rights requests and complaints Subject to applicable legal conditions, you may request confirmation of processing and access, a copy of information, correction, erasure, restriction and portability. You may object to legitimate-interest processing on grounds relating to your situation and to direct marketing without giving reasons. Where processing relies on consent, you may withdraw it at any time. To exercise a right or complain, write to support@croftly.com with a reference that helps locate your data. No account is required. You may act through a representative where provided; identity and authority checks are limited to necessary information. GDPR requests receive a response without undue delay and ordinarily within one month. Any justified extension within permitted limits is communicated within the initial period. Exercising rights is normally free; exceptions for manifestly unfounded or excessive requests must comply with law. A refusal is explained with available remedies. Rights may be limited only as provided by law, for example for legal obligations or protection of others’ rights. Lawful exercise does not result in unfavourable treatment. You may send a complaint about data processing to the same address, describing the facts and desired outcome. The Controller examines it, performs relevant checks and provides a reasoned response without undue delay, with updates when needed. Where UK complaint rules apply, receipt is acknowledged within thirty days. Complaint periods do not replace the separate periods for exercising rights. You may complain to the Italian data protection authority, https://www.garanteprivacy.it, or the competent authority, including in your country of residence, work or alleged infringement where provided. Contacting Croftly first may help resolve the issue but is not a prerequisite for contacting an authority. Croftly does not use content for advertising profiles or solely automated decisions with legal or similarly significant effects. Technical checks on validity and device numbers apply licence conditions; if an error occurs, you can request human review from support. 17 Information for individuals in other countries The following provisions supplement the above rights where local laws apply. United Kingdom. Where applicable, the UK GDPR and Data Protection Act 2018 provide relevant data protection rights. You may contact the Information Commissioner’s Office: https://ico.org.uk. Switzerland. Where applicable, the Federal Act on Data Protection provides relevant rights and requires information about recipient countries and transfer safeguards. The authority is the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch. California and other US states. The Controller does not sell personal data or share it for cross-context behavioural advertising. Categories processed include identifiers and contacts, commercial licence data, technical network activity, authentication data and information voluntarily sent to support, as described above. Content held exclusively on the Mac is not thereby collected on the Controller’s servers. Where the CCPA, as amended by the CPRA, or other state laws apply, relevant rights include access, correction, deletion, portability and, where provided, opting out of sale or targeted advertising, limiting particular uses of sensitive data and appealing a refusal. Requests and appeals may be sent to support@croftly.com, including through an authorised representative. We do not use sensitive data to infer personal characteristics for commercial purposes. Canada. Where PIPEDA or provincial laws apply, access, correction and challenge rights remain, with meaningful consent where required. Access requests under PIPEDA ordinarily receive a response within 30 days, subject to permitted extensions. You may contact the Office of the Privacy Commissioner of Canada, https://www.priv.gc.ca, or the competent provincial authority. Australia and New Zealand. Where applicable, the Privacy Act 1988 and Australian Privacy Principles, or the Privacy Act 2020 and New Zealand principles, are followed, including access, correction and complaint rights. You may contact the Controller and, as appropriate, the Office of the Australian Information Commissioner, https://www.oaic.gov.au, or New Zealand’s Office of the Privacy Commissioner, https://www.privacy.org.nz. Where New Zealand indirect collection rules apply, required information is also provided for data received from others, such as a seller, in the manner and subject to exceptions provided by law. Additional mandatory rights under applicable local law remain. 18 Children Croftly is not specifically designed or promoted for children. We do not knowingly request children’s data to purchase or activate licences or use content for advertising directed at minors. Use by minors must comply with applicable age and authorisation requirements. If you believe a child has sent data to Croftly services without meeting those requirements, contact support@croftly.com for investigation and necessary measures. 19 Updates and access to this notice This notice is updated when features, processing or obligations change. The version identifies the text presented. Significant changes are brought to the User’s attention through suitable channels; updating the document alone does not authorise new processing requiring consent. You can read and save the notice in Italian, English, French, Spanish and German on the website and in the app, choosing the language before accepting the EULA, or request a copy from support@croftly.com. Acknowledging it is not general consent to further processing. 20 Privacy notices of main services For processing by services you choose, consult their respective notices. For other email providers, refer to your chosen service’s notice. Paddle: https://www.paddle.com/legal/privacy Google: https://policies.google.com/privacy Microsoft: https://privacy.microsoft.com/privacystatement Apple and iCloud: https://www.apple.com/legal/privacy/ Yahoo: https://legal.yahoo.com/us/en/yahoo/privacy/index.html Kagi: https://kagi.com/privacy