Privacy Policy

Last Updated: August 29, 2026 · Version 2.0

This Privacy Policy is issued by Data Network Technology Lab, Hong Kong SAR ("DNT Group", "we", "us") and applies to your use of KJK Encryptor (the "Software"). It is prepared in accordance with the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486, "PDPO") and its six Data Protection Principles, as well as the EU General Data Protection Regulation (GDPR), and takes into account the data-protection laws of multiple regions worldwide. Data minimisation is at the core of this policy to protect your personal data and privacy.

1. Introduction and Scope

1.1 The Software is a tool that performs encryption, decryption and data-protection operations locally on your device. This Policy applies to the processing of personal data in connection with your use of the Software, and may serve as the privacy policy statement contemplated by the PDPO.

1.2 Unless otherwise stated, the meaning of "personal data" follows the PDPO and the GDPR, i.e. information that directly or indirectly identifies you.

2. Definitions

"Personal data" means information that identifies you; "processing" includes collecting, recording, using, storing, disclosing, transferring and erasing; the "data user / data controller" is DNT Group.

3. Data Controller and Contact

3.1 DNT Group is the data controller (GDPR Art. 4(7)) and the data user (PDPO) in respect of the processing described herein.

3.2 For users in the EU/EEA, we have taken all reasonable steps to ensure our processing complies with the data-subject rights set out in Chapter III of the GDPR.

4. Information We Collect

4.1 The Software is designed to run locally; it does not actively collect, transmit or store any personal data. All encryption, decryption and file-processing operations are performed locally on your device.

4.2 Your preference settings (language, theme, update-check toggle, etc.) are stored in a configuration file on your device. This configuration does not contain personally identifiable information and resides solely on your device.

4.3 We may only learn your contact details where you proactively provide them (e.g. by sending a support request) and use them solely to respond to your request.

5. Legal Basis for Processing

5.1 Under GDPR Art. 6, any processing (if any) is based on one or more of the following: your explicit consent; the performance of a contract; compliance with a legal obligation; protection of your vital interests or those of another person; or our legitimate interests, without prejudicing your rights.

5.2 Under DPP1 of the PDPO, any collection must be lawful, fair, directly related to the functions or activities of the data user and adequate but not excessive. Our design embeds this principle of proportionality.

6. Use of Data and Transparency

6.1 We do not use any data for "new purposes" inconsistent with the following: providing the Software's functionality and update information. Should a new purpose arise, we will first obtain your express consent in accordance with DPP3.

6.2 The update checker connects to dnteam.top solely to verify whether a new version exists; no personal data is transmitted during this process, and the connection can be disabled in settings.

7. Data Minimisation and Local Processing

7.1 All files, text and passwords you process through the Software remain on your device and are never sent to external servers or DNT Group.

7.2 If you enable the embedded local API server, it runs solely on your local machine and establishes no external connections.

8. Cookies and Tracking

8.1 The Software deploys no third-party analytics, advertising, behavioural or cross-site tracking, and sets no persistent identifiers for tracking purposes.

9. Third-Party Services and Cross-Border Transfers

9.1 The Software may load third-party resources such as open-source libraries via a CDN where necessary to provide functionality; we do not provide any personal data to such third parties.

9.2 Because the Software does not collect personal data, no cross-border transfer occurs in the ordinary course. Should future transfers outside relevant jurisdictions be necessary, we will apply appropriate safeguards (such as Standard Contractual Clauses or an adequacy decision) in accordance with Chapter V of the GDPR and DPP3 of the PDPO.

10. Data Retention

10.1 We do not retain any of your personal data in identifiable form. The local configuration file exists only as long as you keep it and can be deleted at any time.

10.2 Where statutory requirements compel retention of certain records, we retain them only for as long as required to comply, and ensure accuracy and non-excessiveness in accordance with DPP2.

11. Data Security

11.1 As data resides on your device, its security depends on your device and browser/system security settings. We apply reasonable technical and organisational measures under DPP4 to prevent unauthorised access or accidental loss, destruction or damage.

11.2 We recommend that you safeguard your passwords, enable device encryption and multi-factor authentication, and back up important files regularly.

12. Children's Privacy

12.1 The Software is not designed for children and does not intentionally collect personal data from children. As no data is collected, no separate processing channel for children is maintained; guardians are invited to contact us should any concern arise.

13. Your Rights

Pursuant to sections 18 and 22 of the PDPO and Articles 15 to 22 of the GDPR, you have the following rights:

Right of access: to confirm whether we hold your personal data and obtain a copy (PDPO s.18 / GDPR Art. 15);
Right to rectification: to correct inaccurate personal data (PDPO s.22 / GDPR Art. 16);
Right to erasure (right to be forgotten): to request deletion of your personal data (GDPR Art. 17);
Right to restriction of processing: to restrict processing of your data (GDPR Art. 18);
Right to data portability: to receive data you provided in a structured, commonly used, machine-readable format (GDPR Art. 20);
Right to object: to object to processing based on legitimate interests or direct marketing (GDPR Art. 21);
Right not to be subject to automated decision-making: to be free from decisions based solely on automated processing, including profiling (GDPR Art. 22);
Right to withdraw consent: to withdraw any previously given consent by written notice at any time.

Because the Software does not collect personal data, you will generally not need to exercise these rights; if you wish to do so, please contact us using the details below. We will respond within the statutory period (generally 40 days) under the PDPO. If you are dissatisfied, you may lodge a complaint with the Hong Kong Privacy Commissioner for Personal Data or your local supervisory authority (GDPR Art. 77).

14. Multi-Regional Compliance

14.1 Beyond the PDPO and the GDPR, this Policy adopts data minimisation, purpose limitation and local processing as a common baseline, intended to be compatible with data-protection requirements in China, Singapore, Japan, Korea, the United States and Latin America. Because the Software collects no personal data, most mandatory obligations are not triggered.

15. Policy Updates

15.1 We reserve the right to amend this Policy in accordance with applicable law. The revised version will be posted on the official website and in-app with a new effective date; continued use of the Software constitutes acceptance of the updated Policy.

16. Contact and Complaints

If you have any questions about this Policy, data processing or your rights, please contact us via the official website https://dnteam.top, quoting "Privacy / Data Rights" as the subject.