PRIVACY POLICY — CustodiaTray
Secure Clipboard Manager for Windows
Last updated: March 20, 2026

SUMMARY: CustodiaTray does NOT collect, transmit, or share any personal data. All clipboard data is stored exclusively on your device. No servers, no cloud, no accounts, no telemetry, no analytics, no ads.

1. WHO WE ARE
Publisher: Roberto García Collado (RGCSOFTNET)
Contact: rgcsoftware@hotmail.com
App: CustodiaTray (Microsoft Store ID: 9P9VZZFHZHX6)

2. DATA WE COLLECT
None. CustodiaTray does not collect any data from you:
- No personal information (name, email, phone, address)
- No device identifiers or hardware fingerprints
- No IP addresses or geolocation data
- No usage analytics or telemetry
- No crash reports sent to external servers
- No cookies, tracking pixels, or advertising identifiers
- No account creation or authentication with external services

3. CLIPBOARD DATA — 100% LOCAL
CustodiaTray intercepts clipboard events (WM_CLIPBOARDUPDATE) to provide history functionality. This data:
- Stays on your device. It is never transmitted over any network.
- Is stored in a local SQLite database at %APPDATA%\CustodiaTray\custodiatray.db (or a custom path you configure).
- Is optionally encrypted with AES-256-GCM using a master password that only you know (Pro).
- Can be permanently deleted by you at any time via Preferences > Clear History.

The application has NO network capabilities. It does not open sockets, make HTTP requests, or communicate with any server. There is no code path that transmits data off your device.

4. DATA STORAGE AND SECURITY
- Storage: Local only — %APPDATA%\CustodiaTray\ or custom path
- Database: SQLite 3 with WAL journaling
- Encryption (Pro): AES-256-GCM, PBKDF2-derived key, per-clip IV
- Master password: Never stored — derived in memory only
- Anti-screenshot (Pro): WDA_EXCLUDEFROMCAPTURE prevents screen capture
- Sensitive detection (Pro): Regex-based, runs entirely on-device
- Auto-delete (Pro): Clips can self-destruct after 5 min, 30 min, 1h or 24h

5. THIRD-PARTY SERVICES
CustodiaTray uses zero third-party services, SDKs, or libraries that collect data. No embedded analytics (Google Analytics, Firebase, App Center, etc.), no advertising frameworks, no social media integrations. The only third party involved in distribution is the Microsoft Store, governed by Microsoft's Privacy Statement (https://privacy.microsoft.com/privacystatement). CustodiaTray does not interact with Microsoft services after installation.

6. EXPORT AND IMPORT (Pro)
The Pro edition allows exporting clipboard history as a JSON file saved to a location you choose on your local file system. It is never uploaded anywhere. You are solely responsible for exported files.

7. CHILDREN'S PRIVACY (COPPA)
CustodiaTray does not collect data from anyone, including children under 13. No registration, no age information requested, no data on external servers. Fully compliant with COPPA and equivalent regulations.

8. GDPR COMPLIANCE (EU/EEA)
CustodiaTray qualifies as a zero data controller — it does not process personal data on behalf of any server or third party. All processing occurs locally on the user's device.
- Legal basis: Not applicable — no personal data collected externally.
- Data portability: Export full history as JSON at any time (Pro).
- Right to erasure: Clear History permanently deletes all clips. Uninstalling removes all data.
- Data transfers: No data leaves your device. No international transfers.

9. CCPA COMPLIANCE (California)
CustodiaTray does not sell, share, or disclose personal information because it does not collect any.

10. LGPD COMPLIANCE (Brazil)
CustodiaTray does not process personal data on external systems. All data remains under the exclusive control of the user on their own device.

11. PERMISSIONS USED
- Clipboard listener: Core functionality — save clipboard history. No data sent externally.
- Global keyboard hook: Detect Ctrl+Shift+V, Ctrl+Shift+Q hotkeys. No data sent externally.
- Mouse hook (optional): Hot Edge — detect cursor at screen edge. No data sent externally.
- SetWindowDisplayAffinity: Anti-screenshot protection (Pro). No data sent externally.
- File system access: Read/write local SQLite database. No data sent externally.
- Registry (HKCU): Store custom data directory path, autostart. No data sent externally.

12. UPDATES TO THIS POLICY
If this policy changes, the updated version will be published with a new date. Since CustodiaTray collects no data, material changes are unlikely. If a future version introduces any network feature, this policy will be updated before release and users will be notified via Store release notes.

13. CONTACT
Roberto García Collado
Email: rgcsoftware@hotmail.com
Publisher: RGCSOFTNET

14. OPEN-SOURCE DEPENDENCIES
CustodiaTray is built with Rust. None of its dependencies perform network operations or collect data: eframe/egui (UI), rusqlite (SQLite, bundled), windows (Win32 bindings), aes-gcm (encryption), pbkdf2 (key derivation), image (image processing).

© 2026 Roberto García Collado — RGCSOFTNET. All rights reserved.