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Privacy Policy

Effective: 31 August 2026

01Introduction (controller and scope)

Knightage ("we", "us" or "our") handles information in "Rondio" (the "App"), our music player application for iOS / iPadOS, in accordance with this Privacy Policy (this "Policy") and in respect of the Act on the Protection of Personal Information of Japan (the "APPI"), the EU General Data Protection Regulation (the "GDPR"), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA) and any other laws applicable to you.

This Policy covers the handling of information through the App (including any App Extension bundled with it) and through the website we operate at https://rondio.knightages.com/, including its contact form (the "Website"). It does not apply to any other site or app we operate separately.

We are the controller of information obtained in connection with the App (including where this corresponds to the role of data controller under the GDPR). See Section 22 for our contact details.

The App has no account registration, and it never asks you to enter identifying information such as your name, email address or phone number. For information you enter in the contact form, see Section 14.

02Information we do not collect

We do not obtain any of the following through the App — or anything else — and we do not transmit it to us or to any third party.

• Directly identifying information such as your name, address, phone number or email address
• Your audio files themselves, or their filenames, tags, locations or artwork
• Listening history, play counts, favorites, playlists or the contents of the playback queue
• Location, contacts, calendar, photos or microphone audio
• The advertising identifier (IDFA) or any other tracking identifier

The App contains no advertising SDK, no analytics SDK and no crash-reporting SDK. We do not track your activity across other companies' apps and websites, and the App therefore never displays the App Tracking Transparency (ATT) permission dialog. Its App Store "App Privacy" declaration likewise states no data collected and no tracking.

03Information handled on your device (local storage by default)

To function, the App stores the following on your device only. None of it leaves the device, and we have no means of accessing it.

Deleting the App removes this information from your device. Some information may nevertheless remain on the device after deletion in order to prevent misuse; that information cannot identify you.

This information may be lost if your device is lost, damaged, reset or replaced, or if the App is uninstalled. We accept no responsibility for its storage or backup. Please use the standard iOS backup features if you need them (where you use iCloud backup, the privacy policy of Apple Inc. ("Apple") governs how that data is handled). The App does not implement iCloud sync.

04Audio files and the Music library

The App plays the audio files in the folders you select and in your device's Music library by reference, without copying them. The audio files themselves are never copied into the App's own storage, and never transmitted to our servers or anywhere else.

The App reads only what is needed for playback and for building the lists (tags, durations, artwork, file locations and modification dates). As stated in the preceding section, what it reads is stored on your device only.

Access to the Music library is read-only; the App never changes or deletes its contents. Tracks protected by digital rights management (DRM) cannot be handled, for technical reasons.

05Permissions

• File access: the App accesses only the folders you choose yourself in the Files app. It cannot read any location you have not selected.
• Media & Apple Music: used to read the tracks in your device's Music library. This takes effect only if you grant it in the permission dialog shown by iOS.

You can revoke either permission at any time in iOS Settings. If you do, the affected tracks become unplayable, but the rest of the App remains available.

The App uses neither push nor local notifications, so it never asks for notification permission. Nor does it request access to your location, contacts, calendar, photos or microphone.

06Communication with external servers

The App does not transmit your records (play counts, favorites, playlists and the like) or your audio files to any external destination.

The App does communicate with external servers (our Website and the hosting / CDN provider we use) in order to retrieve configuration information such as the latest version of the Terms and of this Policy, in-app announcements, and the minimum version required to run. That communication consists only of a technical request to retrieve the configuration information; none of your records is sent. The same applies when the App displays the Terms or this Policy: it loads the text hosted on the Website.

Separately, communication for making and restoring in-app purchases takes place through Apple's In-App Purchase (StoreKit), and the download of audio files kept in cloud storage takes place through the Files app — in both cases between your device and the respective provider. We take no part in this communication and cannot know its contents.

For the technical information that may be recorded automatically during such communication, see the following section.

07Device and technical information

When the App communicates with our Website to retrieve the configuration information or to display the Terms or this Policy, and when you browse the Website, the access logs of the hosting / CDN provider we use may automatically record your IP address, the date and time of access, and your user agent (device, OS and app version information).

These are recorded automatically by that provider in order to operate the service reliably and to prevent unauthorised access; we do not use them for the purpose of identifying individuals. Nor do we ourselves store anonymous identifiers (such as UUIDs) or consent histories on any server.

08In-app purchase information

Purchases of paid features are processed by Apple. We never receive credit card numbers or other payment details, your Apple ID, or any information that could identify a purchaser. Through App Store Connect we can see only aggregated, non-identifying figures (units sold, sales by country or region and the like).

Whether a purchase has been made is held on your device only, based on the information Apple returns to it (Section 3).

09Purposes of use and legal bases for processing

The purposes for which information handled in connection with the App is used, and (where the GDPR or a similar law applies) the legal bases for processing, are as follows.

10Provision to third parties

Because the App's code does not obtain your library information, we never provide it to any third party. We do not sell your personal information to third parties.

We do not provide personal data to third parties except as required by law, where necessary to protect a person's life, body or property, or with your consent. The personal data we hold on any server is limited to information received through the contact form and similar.

The external providers we use to deliver the service are as follows.

• Apple: distribution of the App through the App Store and processing of in-app purchases
• Our hosting / CDN provider: delivery of the Website and of the configuration information (Section 7)
• Zoho Japan Co., Ltd. (Zoho Forms): the contact form on the Website (Section 14)

11International transfers of information

We do not ourselves send your library information outside Japan. However, the communication by which the App retrieves configuration information, and your browsing of the Website, pass through the hosting / CDN provider we use. That provider may operate servers around the world, and the technical information described above (such as IP addresses) may therefore be processed outside Japan. In that case, the provider handles the information under appropriate safeguards such as Standard Contractual Clauses (SCCs).

Information submitted through the contact form on the Website may also be processed and stored on Zoho Forms servers, as described in Section 14. Zoho Corporation has put in place safeguards for international data transfers based on Standard Contractual Clauses (SCCs).

Information relating to in-app purchases is processed by Apple, in part in the United States and other countries or regions. Please see Apple's privacy policy for details.

12Retention periods

Library information, settings and the information needed to manage the App's behaviour are stored on your device until you delete them within the App or uninstall the App. Because they are not stored on our servers, we neither set nor manage any retention period for them (for information that may remain on the device after the App is deleted, see Section 3).

The access logs of the hosting / CDN provider are erased automatically after the period that provider sets (generally from a few days to a few months). Information provided to us through the contact form is deleted within a reasonable period after your enquiry has been resolved (as a guide, no more than one year after our reply), unless we are required by law to retain it.

13Use of cookies and similar technologies

The App is a native app and does not use browser cookies. Because it contains no advertising SDK, no advertising identifier or similar identifier is used either.

The Website does not currently use Google Analytics or any other third-party analytics tool. Your choice of appearance (light / dark) is stored only in your browser's local storage and is never transmitted to us. The contact form page (Zoho Forms) may set cookies that Zoho requires for its own functionality; please refer to Zoho's cookie policy for details. If we introduce a web analytics tool in future, we will update this Policy and say so.

14Use of the contact form (Zoho Forms)

The contact form on the Website uses "Zoho Forms", provided by Zoho Japan Co., Ltd. (the Japanese subsidiary of Zoho Corporation Pvt. Ltd.). When you submit the form, the name, email address and message you entered are transmitted to and stored on Zoho's servers.

Submitting the form is entirely optional, but if you do submit it, the information needed to handle your enquiry (your name, email address and message) is required. Information obtained through the form is used solely to reply to you, to provide support and to investigate defects, and for no other purpose. Zoho Corporation offers a GDPR-compliant Data Processing Addendum (DPA) and has put in place safeguards for international data transfers based on Standard Contractual Clauses (SCCs).

Privacy policy of Zoho Japan Co., Ltd.: https://www.zoho.co.jp/privacy/

15Your rights under Japan's APPI

We neither obtain nor store, through the App, retained personal data that could identify you. If you make a request under the APPI for disclosure, correction, addition or deletion, suspension of use or erasure, or cessation of provision to third parties, we will check promptly and respond within the scope of the data we hold; please note in advance that library information exists only on your device and cannot be checked by us. For names, email addresses and similar information provided through the contact form, we will respond to requests for disclosure, correction, deletion or suspension of use within the scope of what we hold.

You can delete library information yourself at any time, by deleting it within the App or by uninstalling the App.

16Rights of individuals in the EEA, the UK and Switzerland (GDPR and similar)

If you live in the European Economic Area (EEA), the United Kingdom or Switzerland, you have the following rights in respect of personal data concerning you, under the applicable data protection law.

• The right of access (to obtain a copy of the personal data being processed)
• The right to rectification of inaccurate personal data
• The right to erasure (the so-called "right to be forgotten")
• The right to restriction of processing
• The right to data portability
• The right to object to processing (including processing for direct marketing purposes)
• The right to withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)
• The right to lodge a complaint with the supervisory authority in your country of residence

Because we do not hold your library information, you can exercise the rights above in respect of that information directly on your own device (by deleting the records, uninstalling the App and so on). For any other request or question, please contact us using the channel in Section 22.

We do not carry out automated decision-making, including profiling, that produces legal effects concerning you.

17Rights of residents of California and other U.S. states

If you live in California and the California Consumer Privacy Act (CCPA/CPRA) applies, you have the right to know the categories of personal information collected and the purposes of use, the right to request deletion, the right to request correction, the right to opt out of the "sale" or "sharing" of personal information (disclosure for cross-context behavioural advertising), and the right not to be discriminated against for exercising these rights.

We do not sell your personal information for monetary consideration, and we do not "share" it for cross-context behavioural advertising. Because the App contains no advertising SDK, no advertising identifier is obtained. For the twelve-month look-back period set out in the CCPA, there is no category of personal information that we collected through the App (other than identifiers (category (A)) provided through the contact form on the Website).

Residents to whom other state privacy laws apply (such as the Virginia VCDPA or the Colorado CPA) may have similar rights under those laws. To exercise them, please contact us using the channel in Section 22. We will not change the service in a discriminatory way because you have exercised your rights.

18Security measures

Library information is stored on your device under the standard security mechanisms of iOS (device encryption, the app sandbox and so on). Some information is stored in a protected area provided by the OS. In developing and maintaining the App, our basic policy is to obtain and retain no more information than necessary (data minimisation) and to follow the standard recommendations of the OS. However, we cannot accept responsibility for risks arising from factors beyond our control, such as loss or theft of the device itself or vulnerabilities in the OS. We recommend that you make use of your device's own security features, such as setting a passcode.

Zoho Japan Co., Ltd. takes appropriate technical and organisational security measures for information submitted through the contact form. That said, no method of transmission over the internet can be guaranteed to be 100% secure.

19Children's privacy

The App is not directed to children under 13 (in the EU, the EEA and the UK, children below the digital age of consent under the GDPR — 16 in principle, or between 13 and 16 depending on national implementing law — and, elsewhere, children below any higher age set by the law of your country or region), and we do not knowingly collect personal information from such children. If we learn that personal information of a child below that age has been collected, we will promptly take appropriate measures, including deletion. If you are a parent or guardian and believe your child may be using the App, please contact us using the channel in Section 22. Because library information is stored only on the child's device, we will, on hearing from you, delete the information we hold (such as enquiry information) and explain how to delete the data on the device (by uninstalling the App and so on).

20Features added in future

We may add to or change the features of the App in future. If such a change alters the type or scope of the information handled, we may revise this Policy and give notice on the Website. In particular, if there is a material change in how information is handled — such as synchronising library information with a server outside your device — we will revise this Policy at that time, explain the new handling separately, and obtain your consent where the law requires it.

21Changes to this Policy

We may change this Policy in light of changes in the law, additions or changes to the App's features, or other circumstances. Where we make a material change, we may give notice within the App or through announcements on the Website. The revised Policy takes effect when it is published on the Website. For changes that widen the scope of the information obtained, or that otherwise require your consent by law, we will obtain that consent by the means we specify.

22Contact

For questions about this Policy, requests for disclosure, requests to exercise your rights, or any other enquiry about the handling of personal information, please use our contact form. We may ask you for additional information in order to verify your identity. We can respond in Japanese and English only. Requests to exercise rights under applicable law will be answered within the period that law provides. Other general enquiries will be handled according to their content, but we cannot guarantee a reply to every enquiry.

If you are not satisfied with how we have handled a matter concerning personal information, you may also raise it with the Personal Information Protection Commission of Japan or, if you live in the EEA or the UK, with the data protection supervisory authority in your country.

• Personal Information Protection Commission (Japan): https://www.ppc.go.jp/en/
• List of EEA data protection authorities: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
• UK Information Commissioner's Office (ICO): https://ico.org.uk/

Effective: 31 August 2026