Privacy Policy

Draft for legal review. Items in [brackets] are to be completed before publication.

Effective date: 3 October 2026. Version 1.0.

1. Controller

The controller of personal data processed in connection with the Clickwill website and the Clickwill software (the "Software"), including its alpha version, is Jakub Warzecha, a natural person who does not run a business in connection with the Software, e-mail: clickwilldev@protonmail.com (the "Controller"). This Privacy Policy is issued in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR") and other applicable data protection laws.

2. Scope

This Privacy Policy applies to personal data processed (a) through the website at clickwilldev.com (the "Website"), including when the Software is downloaded, (b) when the Software checks for updates, (c) when the user requests a lookup of an audio CD, and (d) in communications with the Controller. Downloading the Software does not require registration or the provision of an e-mail address. The Software processes the music library and other content stored on the user's iPod exclusively on the user's computer. Such content is not transmitted to the Controller or to any third party.

3. Categories of personal data, purposes and legal bases

3.1 Use of the Website and downloads. The hosting provider records technical data of requests to the Website, including the IP address, the date and time of the request, the requested resource and the user agent. The Controller keeps only an aggregate count of downloads per version of the Software, which does not identify any person. The data are processed for the purpose of delivering the Website and the Software and of ensuring their security and availability. The legal basis is the Controller's legitimate interest (Article 6(1)(f) GDPR).

3.2 Update checks. When the Software checks for updates, it transmits the version of the Software. The Software does not transmit any identifier of the user, the computer or the iPod. The Controller processes these data, together with the IP address of the requesting device, for the purpose of informing the user of available updates and delivering them. The legal basis is the Controller's legitimate interest in providing updates and correcting errors (Article 6(1)(f) GDPR).

3.3 Audio CD lookups. Only when the user clicks "Look Up Online" for an audio CD inserted into the computer, the Software sends to the MusicBrainz service and the Cover Art Archive, both operated by the MetaBrainz Foundation, the identifier and table of contents of that disc (the number of tracks and their positions on the disc) and the version of the Software, and receives the names and cover image of the matching release. These data describe the disc, not the user, and contain nothing from the user's music library or iPod. The request is sent directly from the user's computer to the MetaBrainz Foundation together with the IP address of the requesting device; the Controller does not receive it. The MetaBrainz Foundation processes these data as an independent controller under its own privacy policy. No lookup is sent without the user's action.

3.4 Feedback and correspondence. The Software does not transmit feedback automatically. Where the user sends a message, the Controller processes the sender's e-mail address and the content of the message, including any diagnostic report the user chooses to attach, for the purpose of responding and improving the Software. The diagnostic report does not contain song titles, device serial numbers or the FireWire GUID, unless the user selects an album, in which case the title of that album is included. The legal basis is the Controller's legitimate interest (Article 6(1)(f) GDPR).

4. Recipients

Personal data may be disclosed to the following categories of recipients, to the extent necessary for the purposes set out above: (a) the hosting and infrastructure provider Cloudflare, Inc., acting as processor; (b) the provider of the Controller's e-mail service, Proton AG (Proton Mail, Switzerland), acting as processor, in respect of correspondence. Audio CD lookups described in section 3.3 are sent by the user's computer directly to the MetaBrainz Foundation, which acts as an independent controller. Personal data are not sold and are not disclosed for advertising purposes.

5. Transfers outside the European Economic Area

Where a recipient processes personal data outside the European Economic Area, the transfer is based on an adequacy decision of the European Commission or on standard contractual clauses adopted by the European Commission (Article 46(2)(c) GDPR). A copy of the applicable safeguards may be obtained from the Controller.

6. Retention

The Controller does not keep server logs; technical request data is processed by the hosting provider in accordance with its own retention rules as processor. Correspondence is retained for two years after the matter has been concluded, and thereafter only for the period required to establish, exercise or defend legal claims.

7. Rights of the data subject

Subject to the conditions laid down in the GDPR, the data subject has the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and the right to object to processing based on legitimate interests (Article 21). Requests should be addressed to clickwilldev@protonmail.com.

The data subject has the right to lodge a complaint with a supervisory authority, in particular the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, Poland, or the supervisory authority of the Member State of habitual residence.

8. Obligation to provide data

The provision of personal data is not required to download or use the Software. The processing of the IP address is technically necessary to deliver the Website, the Software and its updates. The provision of an e-mail address is necessary only if the user wishes to receive a reply to a message.

9. Automated decision-making

Personal data are not subject to automated decision-making, including profiling, within the meaning of Article 22 GDPR.

10. Cookies

The Website does not use cookies or similar technologies for analytics, advertising or tracking.

11. Changes

The Controller may amend this Privacy Policy. The current version is published on the Website together with its effective date.