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Privacy policy

Last updated: 23 October 2026

1. Scope and overview

This privacy policy applies to

  • our website webdonkey.io,
  • our online shop at shop.webdonkey.io with customer account, checkout and the pages for cancelling and withdrawing,
  • our applications WebDonkey, WebDonkey Editor and WebDonkey Pages for macOS (each an “app”, together the “apps”), to the extent that they exchange data with us or with third parties.

It is published with the same wording on webdonkey.io and on shop.webdonkey.io. We use terms such as “personal data”, “processing” and “controller” as defined in Art. 4 of the General Data Protection Regulation (GDPR).

The key points first:

  • The apps run on your Mac. They do not send us your projects, websites, files, databases, credentials for your servers or what you enter into AI services. The apps contain no analytics, advertising or crash reporting.
  • The apps talk to our server only through the interfaces listed exhaustively in section 9: licence, updates, release notes, online documentation and theme gallery. The personal data involved is mainly that of the licence check. Our server never sends anything to the apps on its own initiative.
  • Website and shop run on the same server of our hosting provider. Every request is recorded in one shared log file.
  • Website and shop load services from Google, Meta and TikTok for statistics and ad measurement only if you consent.

2. Controller, data protection officer, supervisory authority

The controller is

BuI Hinsche GmbH
Neumarkt 7
06712 Zeitz
Germany

represented by the managing directors Matthias Hinsche and Yvonne Hinsche.
Phone: +49 3441 9799060, email: info@webdonkey.io. Further details are in the legal notice.

Data protection officer: We have not appointed a data protection officer because we are not obliged to do so (Art. 37 GDPR, § 38 German Federal Data Protection Act, BDSG). We answer questions on data protection at info@webdonkey.io.

Supervisory authority: The authority competent for us is the State Commissioner for Data Protection of Saxony-Anhalt (Landesbeauftragter für den Datenschutz Sachsen-Anhalt). You may also contact any other data protection supervisory authority, in particular in the member state of your habitual residence or place of work (Art. 77 GDPR).

3. Hosting, server and log files

Hosting provider. The website, the shop with its database, the server for licences, updates, downloads, documentation and theme gallery, and our mail server run on a server of profihost GmbH, Hildesheimer Straße 25, 30880 Laatzen, Germany. Website and shop are in the same web space there. profihost GmbH provides server, storage, database and network connection and has access to all data arising on the server. The legal basis is our legitimate interest in operating our services securely and economically (Art. 6(1)(f) GDPR); where data relating to your contract is concerned, also Art. 6(1)(b) GDPR.

Log file. Every time a page or file is requested from webdonkey.io or shop.webdonkey.io, the web server writes a line to one log file shared by both addresses. It contains your full IP address, date and time, the request method, the address requested including the query string, the protocol, the status code, the amount of data transferred, the previously visited page (referrer), the identifier of your browser or program (user agent) and the name of the web server. Cookies and form contents are not included. The same applies to requests from the apps (section 9). We use the log file for operation and security, troubleshooting, preventing misuse and for the statistics in section 4 (Art. 6(1)(f) GDPR).

Retention of the log file. The log file is kept by the hosting provider; the provider controls rotation and deletion of the log files, and we cannot configure them. The entries on the server go back about 30 days. Entries we need to investigate a specific incident are secured until it has been resolved.

Error logs. The shop system writes technical errors to its own log files on the server, one file per day; Mollie's payment module keeps logs of its own, a general one and one per order. In individual cases entries may contain an email address, an order number or a technical identifier. The licence server does not write the licence key into them, only the action and the error message. The payment module deletes its general log after 14 days and its per-order logs seven days after the last entry if the payment was successful, otherwise after 30 days. The shop system keeps the 14 most recent daily files of its error logs and deletes older ones automatically. The legal basis is Art. 6(1)(f) GDPR.

Event log. The shop system logs events in its database such as emails sent, with recipient, subject and content, logins to the customer account, orders, payment notifications from Mollie and status changes of orders. We use this for troubleshooting. The shop system deletes the entries automatically after 14 days, also if your customer account is deleted before then. The legal basis is Art. 6(1)(f) GDPR.

Backups. Before updates and larger changes we create backups of the shop on our hosting provider's server, which usually include the database. We delete these backups after 30 days; the most recent backup before an update of the shop system is kept until the backup before the next update. The legal basis is our legitimate interest in secure operation (Art. 6(1)(f) GDPR, Art. 32 GDPR).

4. Statistics from the log files

Regardless of your cookie choice and without cookies, we evaluate the log file to know how often our pages are visited and the apps are downloaded. For this, the shop reads in the log file once an hour. Because website and shop share one log file, it counts the page views of both addresses together.

  • Visitors and page views: For each day we store a hash value that we form from IP address and user agent using a secret key known only to us. In addition there are daily figures not relating to any person, such as the number of page views and of failed requests.
  • Downloads: For each download of an app we store the same hash value, the date, the app, the version, the type of download and the source of the request.
  • Update requests from the apps: see section 9.3.

We do not store the IP address and user agent themselves in these statistics. Without the secret key the hash value cannot be reversed; we nevertheless treat it as pseudonymous and therefore personal data. We do not combine it with your customer account, your licence or your orders, and we do not pass the statistics on.

Retention: After 90 days we automatically replace the hash value in every entry of visitors and downloads with a random value. The entries and the daily figures then remain stored without reference to a person.

Download quota. You download the program files of the apps with your customer account, at most ten per customer account and calendar day, so that the apps are not downloaded in bulk through one account. For this we count the downloads per day under a hash value that we form from the internal identifier of your customer account and a secret key. Only this hash value, the date and the number are stored; we delete the count after three days at the latest. It is not combined with the other statistics.

The legal basis in each case is our legitimate interest in reliable figures on the use of our services and in protecting them against misuse (Art. 6(1)(f) GDPR). You can object to this processing (section 13).

5. Website webdonkey.io

Without your consent the website only loads content from webdonkey.io and from shop.webdonkey.io; it serves fonts itself. It loads content from third parties only with your consent under section 7. No contracts are concluded via the website.

Prices. So that you see current prices, your browser asks our server at webdonkey.io on pages with prices. The server fetches the prices from the shop and keeps them for ten minutes; only the address of our server and the identifier “webdonkey.io-homepage” go to the shop, no information about you. If that fails, your browser asks the shop directly at https://shop.webdonkey.io/webdonkey/public/offers. It sends no cookies and does not store any cookie the shop sends back; the shop receives your IP address, the user agent and the page the request comes from. Your browser estimates which currency you see from its time zone and language; this information does not leave your device.

Images from the shop. Your browser loads the images of the feature chapters on the pages about WebDonkey, WebDonkey Editor and WebDonkey Pages from shop.webdonkey.io. The shop receives your IP address, the user agent and the address of the page; the request is recorded in the log file (section 3). The shop sets its session cookie. Because website and shop belong to the same domain, your browser sends along the cookies that apply to all addresses under webdonkey.io: the cookie wd_consent with your choice and, if you have consented, the cookies of the services in section 7. On every page your browser also opens a connection to shop.webdonkey.io in advance so that images and prices load faster; the server receives your IP address, but no page is requested.

Redirects. The website redirects addresses that belong to the shop, such as the customer account, the checkout or the forms for cancelling and withdrawing, and requests from the apps to webdonkey.io, to shop.webdonkey.io. This creates one line in the log file for the first request and one for the redirected request.

Settings in your browser. What the website stores in your browser is set out in section 6 and in the cookie and consent overview.

Links. Links to the shop or to our Discord server only open that service when you click them. Its own privacy notice applies there.

The legal basis for prices, images, connection set-up and redirects is our legitimate interest in a fast website with correct prices (Art. 6(1)(f) GDPR).

6. Cookies and browser storage

Website and shop store information in your browser (cookies, localStorage, sessionStorage). Which items, with purpose, retention period and legal basis, is set out in the cookie and consent overview. It forms part of this privacy policy.

  • Without consent, website and shop only store what is technically required or what you choose yourself: the shop session with basket and login, information of the shop system so that cached pages match your settings, your country for currency and VAT, your choice in the cookie banner, display, language and price switches, and aids to operation, such as your entries in the checkout until the page is reloaded. The legal basis is § 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG), and Art. 6(1)(b) or (f) GDPR for further processing.
  • We only set cookies of the services for statistics and ad measurement with your consent (section 7; § 25(1) TDDDG, Art. 6(1)(a) GDPR).
  • The cookie wd_consent applies to all addresses under webdonkey.io, that is to website and shop together. The shop reads it on the server to apply your choice. It also serves as proof of your consent (Art. 6(1)(c) in conjunction with Art. 7(1) GDPR).
  • The apps set no cookies and do not store cookies the shop sends them.

You can view, delete and block cookies and browser storage in your browser settings. Without cookies, login and checkout in the shop cannot be used.

7. Consent, statistics and ad measurement (website and shop)

Which services. For statistics and ad measurement we may use Google Tag Manager and Google Analytics 4 (group “Statistics”) as well as the Meta Pixel and the TikTok Pixel (group “Marketing”) on webdonkey.io and in the shop. We load a service only if you have agreed to the respective group in the cookie banner, and only for as long as we use the service. Without your consent neither website loads Google Tag Manager, and no request goes to Google, Meta or TikTok. The legal basis is your consent: § 25(1) TDDDG for storing and reading information on your device, Art. 6(1)(a) GDPR for further processing.

The banner. “Accept all” and “Necessary only” are shown side by side with equal prominence; under “Settings” you choose the groups individually. Your choice applies to webdonkey.io and shop.webdonkey.io together: what you decide on one of the two websites applies to both until you change it. The controller is BuI Hinsche GmbH in both cases. If we change what we ask your consent for, we raise the version number in wd_consent; an earlier choice then no longer applies and the banner asks you again. It also asks again after twelve months.

Withdrawal. You can change or withdraw your consent at any time with effect for the future using “Cookie settings” at the bottom of every page of both websites. We then delete the cookies of the services concerned in your browser. If you withdraw on webdonkey.io, this applies in the shop from the next page view. The lawfulness of processing up to the withdrawal remains unaffected.

Technology. We use Google's consent mode (Consent Mode v2). Until you agree, all consent signals are set to “denied” and Google Tag Manager is not loaded. If you agree to only one group, we only load its services. If you register or log in to the shop, the shop sets the cookie wd_track_event for at most five minutes, and only with your consent. It only contains whether you registered or logged in and by which method (email or Google). The next page reports this to the services you agreed to and deletes the cookie.

What is measured. With your consent the services record:

  • on webdonkey.io: pages viewed and where you came from (the previous page, campaign details in the address), clicks on links and buttons with link text and target (for example download, buy in the shop, account, documentation, legal texts, contact, external links), menus, tabs, detail sections and FAQ questions opened (with the text of the question), switching colour scheme, language and price switches, loading of prices, which sections and feature chapters you view, scroll depth, when copying text only the number of characters copied, printing a page, load times (Web Vitals), pages not found and your choice in the banner;
  • in the shop: pages, products and product lists viewed, adding to the basket, opening the checkout, completed purchases (order number, order value, tax, currency, a voucher code redeemed and the products with item number, name, price and quantity), creating a customer account and logging in, each only with the information by which method;
  • on both: browser and device information and your IP address.

We do not pass your name, email address, postal address, phone number, customer number or payment details to any of these services. We send the order number so that a purchase is only counted once. In the shop we pass page addresses, including that of the previous page, to Google Analytics without the query string; only campaign and click identifiers remain (utm_…, gclid, gbraid, wbraid, dclid, fbclid, ttclid, _gl). On webdonkey.io, Google Analytics transmits the address as it appears in the browser. Meta and TikTok read the page address themselves. On shop pages whose address contains a secret key (for example the password reset link, confirmation links, links from emails to orders and invitations, Sign in with Google and the return from payment), the shop loads none of these services, even with your consent; the next page then only names shop.webdonkey.io as the origin.

Website and shop as one visit. The cookies of the services apply to all addresses under webdonkey.io. If you agreed to statistics, Google Analytics also adds a short identifier (_gl) to the address when you move between website and shop. This lets us evaluate a visit that begins on webdonkey.io and ends with a purchase in the shop as one connected journey.

Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager sets no cookies of its own and only loads the services you agreed to. When it loads, Google receives your IP address. A transfer to Google LLC in the USA is possible; it is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR). Privacy notice: https://policies.google.com/privacy

Google Analytics 4 (statistics). The provider is Google Ireland Limited (address above). It shows us which pages and products are viewed, where visitors come from, which devices and browsers they use and how they move through website and shop up to a purchase. Google derives your approximate location from your IP address; according to Google, Google Analytics 4 does not store the IP address. We do not pass on an identifier of your customer account. Cookies: _ga and _ga_, up to two years; according to Google, _gid (24 hours) and _gat (one minute) may be added. If you also agreed to marketing, the Google tag may set cookies whose names begin with _gcl_ (such as _gcl_au and _gcl_aw, 90 days); they allow Google to link visits and purchases to an earlier click on a Google ad. How long Google keeps the event data depends on the retention period we set in Google Analytics; according to Google it offers two or 14 months for this. A transfer to Google LLC in the USA is possible (EU-US Data Privacy Framework, see above). Privacy notice: https://policies.google.com/privacy

Meta Pixel (Facebook, Instagram; marketing). The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. It lets us measure whether ads on Facebook and Instagram lead to visits and downloads on webdonkey.io and to registrations and purchases in the shop, and build audiences for ads, for example from people who viewed a product but did not buy it. The page viewed, the events (on webdonkey.io viewing product and pricing pages, clicking a download and contact; in the shop product view, basket, checkout, purchase and registration) with product identifiers, amount and currency, an event identifier (for a purchase the order number), browser and device information and your IP address are transmitted. We call the pixel with automatic configuration switched off so that it does not record clicks and page content on its own. If you are logged in to Facebook or Instagram, Meta can link the data to your account. We are jointly responsible with Meta for collecting and transmitting this data (Art. 26 GDPR); the agreement is at https://www.facebook.com/legal/controller_addendum. Under it, Meta fulfils your rights under Art. 15 to 20 GDPR for the data stored by Meta; you can contact us and Meta. Meta alone is responsible for further processing after transmission. Cookies according to Meta: _fbp (three months), _fbc (three months, only if you arrive through an ad) and fr on facebook.com (three months). A transfer to the USA is possible; Meta Platforms, Inc. is certified under the EU-US Data Privacy Framework. Privacy notice: https://www.facebook.com/privacy/policy/

TikTok Pixel (marketing). The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. Purpose and data transmitted correspond to the Meta Pixel, for ads on TikTok (events on webdonkey.io: viewing product and pricing pages, clicks on download, contact and other buttons; in the shop product view, basket, checkout, purchase and registration). If you are logged in to TikTok, TikTok can link the data to your account. We are jointly responsible with TikTok for collecting and transmitting (Art. 26 GDPR); we will provide you with the essence of the arrangement on request. TikTok alone is responsible for further processing after transmission. Cookies according to TikTok: _ttp and _tt_enable_cookie (13 months). According to TikTok, it stores data in the USA, Malaysia and Singapore among other places and grants group companies in further countries access, including countries without an adequacy decision; TikTok relies on standard contractual clauses for this (Art. 46(2)(c) GDPR). Privacy notice: https://www.tiktok.com/legal/page/eea/privacy-policy/en

In countries without an adequacy decision the level of data protection may be lower than in the EU, and authorities there may be able to access the data without effective legal remedies being available to you.

8. Shop: customer account, order and contract

8.1 Customer account and registration

You can only buy with a customer account, because licence keys, devices and subscriptions are managed there. For registration we process the account type (personal or company account), salutation, first and last name, email address, a password (stored only as a hash), your postal address with country and where applicable state, for company accounts company, department and VAT identification number and, if you provide one, a different delivery address. You confirm your email address via a link (double opt-in); if you do not confirm it and the account has no order, licence or subscription, we delete the unconfirmed account automatically after 30 days, or earlier at your request. On registration and every login the shop system stores your IP address in shortened form and the time of the last login in your customer account. The account type determines prices and the products you can order. The account is not public. The legal basis is Art. 6(1)(b) GDPR, for the shortened IP address our legitimate interest in protection against misuse (Art. 6(1)(f) GDPR).

8.2 Sign in with Google

Optionally you can register and log in with your Google account. You are redirected to Google for this; the provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The shop does not embed a Google script for this. After you agree at Google, we receive the information of the scope “openid email profile”: your Google identifier, your email address with the information whether it is verified, your first and last name and further profile details such as the address of your profile picture. Of these we use only the Google identifier, email address and name, to create a customer account or to log you in; we do not store further profile details. We reject unverified email addresses. We store the Google identifier in your customer account for as long as it exists. Signing in with Google is voluntary; you can equally register with email address and password. The legal basis is Art. 6(1)(b) GDPR. Google's privacy notice: https://policies.google.com/privacy

8.3 Order

For the order we process the order and billing data: products, term, prices, VAT, discounts, billing address, order number and time. We store your consent to immediate performance of the contract and your confirmation that your right of withdrawal thereby lapses, with wording and time, in the order. The mandatory fields are required for the contract. The legal basis is Art. 6(1)(b) GDPR, for retention Art. 6(1)(c) GDPR.

8.4 Payment via Mollie

Payments are processed by Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, Netherlands. We currently offer credit and debit card and Apple Pay; with Apple Pay, Apple is also involved and the privacy notice of Apple Pay applies. Mollie receives the information needed for the payment (such as name, email address, amount) and processes it under its own responsibility. For entering card details the checkout loads a script from Mollie (js.mollie.com); the card fields come directly from Mollie, and Mollie receives your IP address. We do not receive your full card or account details. From Mollie we receive the payment status, payment, mandate and subscription identifiers and the country in which your card or bank account is held. We store this country in the order; alongside your billing address it serves as evidence of the country in which VAT is due (Art. 24b and 24f of Implementing Regulation (EU) No 282/2011). The legal basis is Art. 6(1)(b) GDPR, for the payment country Art. 6(1)(c) GDPR. Mollie's privacy notice: https://www.mollie.com/legal/privacy

8.5 Checking the VAT identification number

If, as a business customer, you provide a VAT identification number from another EU member state, we check it via the VAT Information Exchange System (VIES) of the European Commission: when it is entered or changed, and at login and before the renewal of a subscription if the last check is some time ago. Your number and our own VAT identification number are transmitted. We store the result in your customer account (number, result, time, the name and address reported by VIES and the request identifier), because we may only invoice without VAT with a confirmed number and must be able to prove this. The legal basis is Art. 6(1)(c) GDPR in conjunction with the VAT evidence requirements, and Art. 6(1)(b) GDPR.

8.6 Accounting, tax adviser and tax authorities

For accounting and tax returns we pass invoice and payment data to our tax adviser, who is bound to professional secrecy: date, order and invoice number, name, company, VAT identification number, customer number, country, payment country, amounts and the payment identifier at Mollie. We report sales to the tax office and, under the One-Stop-Shop procedure, aggregated per country to the German Federal Central Tax Office (Bundeszentralamt für Steuern). The legal basis is Art. 6(1)(c) GDPR.

8.7 Subscriptions, discounts, bonuses, vouchers and creator programme

For running subscriptions we process terms, renewal dates, couplings and assignments of licences, discounts, bonuses and vouchers and the number of charges to which a discount applies. If you accept a bonus or a changed subscription condition in your customer account, we store as proof the time, the text you agreed to, the amounts and the IP address from which you agreed. We keep these records for as long as your customer account exists. The legal basis is Art. 6(1)(b) GDPR, for the proof our legitimate interest in being able to prove contractual declarations (Art. 6(1)(f) GDPR).

Changes to the terms and prices. If we announce a change to our terms or a new price for running subscriptions (Terms § 13 and § 4(1)), we store per customer and change your customer number, when we announced it and reminded you of it, whether, when and how you agreed (link in the email, customer account or, for a change of the terms, order) and, for contracts without agreement, the day they end. For a new price we also store per subscription the previous and the new amount with currency and from when the new amount applies. We do not store an IP address for this. We keep these records for as long as your customer account exists and, after its deletion, until 31 December of the third year after the year of deletion; the day on which a contract without agreement ends is deleted with the customer account. The legal basis is Art. 6(1)(b) GDPR, for the records our legitimate interest in being able to prove contractual declarations (Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR).

If you redeem a creator code or come to the shop via a creator's link, we assign the order with which you take out the subscription to that creator and record at the purchase their commission rate, the net amount and the commission; we do not assign renewals to them. Because a creator code is valid for only one order per customer account, the basket checks whether your customer account has used one before. The assignment proves the billing with the creator; like the order, we keep it until 31 December of the tenth year after the year of the order and then delete it automatically. If your customer account is deleted before then, we remove the link to your customer account from the assignment; order reference, rate, net amount and commission remain until the end of the period. The creator does not receive your name or contact details. From creators we store name, email address, code and terms for billing; for requests to become a creator see section 8.13. The legal basis is Art. 6(1)(b) GDPR in relation to the creator and our legitimate interest in correct billing (Art. 6(1)(f) GDPR).

8.8 Refunds, invoice corrections and chargebacks

If we refund a payment in full or in part, for example after a withdrawal, for a charge after the end of a contract or on cancellation of a consumer annual subscription under § 309 no. 9 of the German Civil Code (BGB), the refund is made via Mollie. For this we store the identifiers of payment and subscription, the amounts and the status of the refund, and for every refund you receive an invoice correction (credit note or cancellation invoice) as a PDF by email; it is also shown in your customer account with the order. If your bank or card provider charges a payment back, we do not create an invoice correction and record the chargeback in our accounts. The legal basis is Art. 6(1)(b) and (c) GDPR.

8.9 Cancellation without logging in

If you cancel via “Cancel contracts here”, we process the details in the form (type of cancellation, for an extraordinary cancellation the reason, first and last name, email address, licence key or order number, desired date) and the date and time of receipt in order to assign the cancellation to your contracts, carry it out and confirm receipt to you (Art. 6(1)(b) and (c) GDPR in conjunction with § 312k BGB). If your details match several running contracts, we show them to you immediately afterwards with product name and term only, for you to choose. To limit misuse we count cancellations per IP address and per email address under a hash value that expires after one hour or 24 hours respectively (Art. 6(1)(f) GDPR). We keep the cancellation declaration with your contracts. If your customer account is deleted, we keep it as proof until 31 December of the third year after its receipt and then remove your details from it (Art. 17(3)(e) GDPR).

8.10 Withdrawal via the online form

If you declare a withdrawal using the “Withdraw from contract” form, we process your details (name, email address, order number or the choice “all my orders”, comment and, for add-ons from other orders, your choice per add-on whether it is withdrawn as well or continues) and the date and time of receipt in order to check and carry out the withdrawal and to confirm receipt to you on a durable medium (Art. 6(1)(c) GDPR in conjunction with § 356a BGB and Art. 6(1)(b) GDPR). The confirmation of receipt states for each such add-on whether it is withdrawn as well or continues. If we carry out the withdrawal, we refund the payment via Mollie and create a cancellation invoice (section 8.8). If your customer account is deleted, we remove name, email address and comment from the withdrawal; the case itself remains with the order.

8.11 Emails and mail archive

We send you emails relating to your account and your contracts, such as confirmations of registration, order, payment, cancellation and withdrawal, invoices and invoice corrections, reminders before charges, announcements of changed terms and prices with reminders of them, notices about discounts, failed payments, licences and teams, and replies to your reports. Our terms and conditions, the withdrawal policy and the service description are attached as PDFs to the order confirmation and the confirmation of payment. For sending we use the mail server on our hosting provider's server (section 3). Our emails contain no counting or tracking pixels; we do not measure open or click rates. The legal basis is Art. 6(1)(b) GDPR, for confirmations required by law Art. 6(1)(c) GDPR.

We store every email the shop sends, with recipient, subject, content, attachments and time of sending, in an archive in the shop. This lets us prove that and when we sent it, answer queries and resend emails (Art. 6(1)(f) GDPR). We delete archived emails automatically six years after sending; if your customer account is deleted, we remove the emails sent to you from the archive immediately.

8.12 Offers by email

If you have bought a product from us, we occasionally send you emails with offers about your subscriptions: the offer of a bonus, a reminder that an offered bonus will soon expire, and vouchers. For this we use the email address you gave us when buying and the language of your customer account. We do not ask for consent for this: we advertise in this way only to our customers and only for our own similar products (§ 7(3) of the German Act against Unfair Competition, UWG). The legal basis is our legitimate interest in advertising our products to our customers (Art. 6(1)(f) GDPR).

You can object to this use at any time without incurring costs other than the transmission costs at the basic rates. We point this out at registration and in every such email. You can object via the unsubscribe link in every such email (it works without logging in; you confirm with a button there), via the switch “Offers for my subscriptions by email” in your customer account, or informally, for example by email to info@webdonkey.io. We store your objection with time and channel in your customer account for as long as it exists, so that you no longer receive such offers (Art. 6(1)(c) in conjunction with Art. 21(3) GDPR). You will continue to receive emails about your contracts.

We do not send a newsletter.

8.13 Request to become a creator

If you would like to promote our products as a creator, you can send a request using the form at shop.webdonkey.io/affiliate. We process the details in the form (name, email address, where you want to promote, requested discount for customers, requested commission, preferred code and maximum number of redemptions) and the language of the shop in order to review your request, reply to you and, where applicable, propose changed terms by email. You do not need a customer account for this, and we do not store your IP address. To limit misuse, we count requests per IP address and per email address under a hash value that we form with a secret key and that expires after one hour or 24 hours respectively. If we accept the request, we set you up as a creator with name, email address and the agreed terms (section 8.7). We delete declined and unfinished requests six months after the last change. We keep an accepted request as proof of the agreement for as long as you are a creator and after that until 31 December of the third year. Our emails to you are kept in the mail archive (section 8.11). The legal basis is Art. 6(1)(b) GDPR, for limiting requests and for the proof our legitimate interest in protection against misuse and in being able to prove the agreement (Art. 6(1)(f) GDPR).

8.14 Problem and support reports

If you report a problem to us in the shop, including via the link from an app, we process your details to handle it (Art. 6(1)(b) GDPR): the fields completed (category, title, description, error message, steps to reproduce, expected behaviour) and accompanying technical details such as app version, operating system version, affected page, browser and language. If you are logged in, we assign the report to your customer account so that you can see its history there. To handle it, we send the report with your name and email address to our internal support address. We notify you of replies and status changes by email unless you object. We publish some of the reported problems in an overview of known problems, always with a separate, neutral text and without your entries or details about you. Please do not send credentials or personal data of third parties in the free-text fields. If you write as a member of a company account, the company account sees the report with your name, can reply, and a bonus for the report goes to the company account. If your customer account is deleted, we remove the link; the text of the report remains so that the analysis of a bug stays traceable. You can request complete deletion of your reports at any time.

8.15 Company accounts and team members

A company account can invite team members by email and share licences with them. For the invitation we process the email address entered and send it a message naming the email address and company name of the inviting account (Art. 6(1)(b) GDPR in relation to the company account, Art. 6(1)(f) GDPR in relation to the invited person). Until consent is given, the company account learns nothing about the invited person except the address it entered itself. Only when the invited person agrees in their own customer account using exactly this email address does the company account see their name and email address, can share licences with them, and their reports as a member are assigned to the company account (consent, Art. 6(1)(a) GDPR). You withdraw consent by leaving under “Team” in your customer account; shared licence keys are renewed in the process. Reports already written remain assigned to the company account (Art. 6(1)(f) GDPR). Open invitations expire after 14 days. We delete ended invitations and memberships 90 days after they end. If the customer account of an invited person is deleted, we remove their address from the membership by the following day at the latest.

8.16 Discord community

We run a Discord server for discussion around our apps. The provider is Discord Netherlands BV, Schiphol Boulevard 195, 1118 BG Schiphol, Netherlands; the parent company Discord Inc. is based in the USA. A transfer to the USA is possible; according to its own statement, Discord Inc. participates in the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR). If you link your customer account to your Discord account to receive the “Verified” role, we generate a code that expires after seven days and, once it is redeemed, store your Discord identifier and Discord user name in your customer account. We transmit to Discord only the instruction to assign or remove the role for this Discord identifier; we do not transmit name, email address, customer number or orders. You can remove the link at any time; we then delete the link data, and also with your customer account. If you submit a feature request via the Discord server, we store your Discord identifier, your Discord user name and the text in order to handle the request; it appears publicly under your Discord account in the server's channel. These entries are not linked to your customer account and therefore remain until you request their deletion. The legal basis is your consent (Art. 6(1)(a) GDPR). Discord is responsible for your use of Discord itself: https://discord.com/privacy

8.17 Contacting us

If you write to us by email or via our community channels, we process your details to answer your request (Art. 6(1)(b) GDPR, otherwise (f) GDPR). The mailbox is on our hosting provider's mail server. We delete your request once it has been dealt with and no retention obligation applies.

8.18 Deleting your customer account and record of deletion

You can request deletion of your customer account at any time, for example by email to info@webdonkey.io. First we cancel your running subscriptions at Mollie and send you a final email. Then we delete the entries of our extensions relating to your account, such as licences, devices, bonuses, Discord link and team memberships, and the emails sent to you in the mail archive. We must keep orders and invoices (section 12); we block your name and address in them until the end of the retention period and replace them afterwards. The hash values of the statistics (sections 4 and 9.3) cannot be assigned to any customer account and therefore remain unaffected. Records of changes to the terms and prices are kept as set out in section 8.7. From the creator assignment of your orders we remove the link to your customer account (section 8.7).

As proof we record that and when we deleted: your customer number, a hash value of the internal identifier of your customer account, who carried out the deletion, the type of deletion, a note where applicable and the number of entries deleted per table. We remove customer number, hash value, the person who carried out the deletion and the note after 31 December of the third year after the deletion; after that only date, type of deletion and the number of entries remain. The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 5(2) and Art. 17 GDPR.

9. The apps and our server: all data interfaces

9.1 Principles

  • Addresses. The apps contact our server at shop.webdonkey.io. If it cannot be reached or does not respond as expected, they repeat the request at webdonkey.io; the website forwards it to shop.webdonkey.io. Both addresses are on our hosting provider's server (section 3). There are no other recipients for these interfaces.
  • Only on request of the app. Our server only answers requests from the apps. It sends them nothing on its own initiative; there is no push connection and no link from shop or website that starts an app.
  • Technical data. With every request the server receives your IP address; every request is recorded with address, time and user agent in the log file (section 3). The shop also sets a session cookie for these requests; the apps do not store it.
  • Family on one Mac. If WebDonkey and WebDonkey Editor run at the same time, only one of the two apps talks to the licence server. WebDonkey Pages always asks itself. WebDonkey Editor identifies itself to the licence server and the gallery with the identifier and version of the built-in WebDonkey library; if WebDonkey is not installed, it contacts the licence server itself.
  • Exhaustive list. There are no interfaces between the apps and our server other than the following.

9.2 Activating, checking and signing out a licence

Purpose. To check whether your licence is valid and which functions and packages it unlocks, and to enforce the agreed number of devices used at the same time.

When. Only if you have entered a licence key in the app. About three seconds after start the app signs in, then it checks every ten minutes. It asks more often in these cases: every two minutes while another device holds the seat or a conflict exists; every 30 seconds while no verified answer has been received yet; every minute when the paid period has ended and the server cannot be reached (such attempts do not reach us); in addition once at the end of the term and when you choose “Check now”. On quitting and when you click “Sign out” the app signs out; if WebDonkey and WebDonkey Editor run at the same time, only the one quit last signs out.

Sent with all three requests are exactly these items:

In addition the user agent “WebDonkey/version” (WebDonkey, WebDonkey Editor) or “WebDonkeyPages/version” and your IP address. Hardware identifier and user name leave the Mac only as a hash. We nevertheless treat the device identifier as personal data: it is pseudonymous, not anonymous. The device name often contains a first name (such as “Anna's MacBook Pro”); you can change it in the macOS system settings. Because all three apps send the same device identifier, we can tell which of our apps run on the same Mac and count them as one seat.

Answer. The server answers with a signed message: status of the licence, server time, number of seats, whether this device holds the seat, end of the paid period, the unlocked products with status, end of term, plan and number of websites, the number of packages you bought but have not yet assigned to a licence, plus the hash of the key, the installation identifier, the app and the device identifier sent. If another Mac holds the seat, the answer contains its device name and the time of its last check-in so that you can resolve the conflict. If you share a licence with other people, they therefore see your device name. In the event of a licence conflict we send you one email per conflict with the device name of the requesting Mac; it is kept in the mail archive (section 8.11).

Stored in the shop:

We do not store which app is asking. In your customer account you see device names and last use and can sign devices out; a team member with whom a licence is shared sees the device name.

Without a connection. If the app cannot reach the server, the licence's functions remain usable until the end of the period confirmed at the last check; this includes three days beyond the end of the paid period (Terms § 6(3)). The Free scope can also be used without a connection.

WebDonkey Pages can take over a licence key entered in WebDonkey on your Mac; this happens only locally, after which Pages asks the server itself. WebDonkey Editor, if WebDonkey is not installed, stores licence key, signed answers and installation identifier in a database of its own on your Mac.

Legal basis. Art. 6(1)(b) GDPR (contract) and our legitimate interest in preventing unauthorised use (Art. 6(1)(f) GDPR). Reading the hardware identifier, user name and computer name on your Mac is strictly necessary for the licence function you requested (§ 25(2) no. 2 TDDDG). You stop the transmission by removing the licence key from the app; the app then runs in the Free scope.

9.3 Update check and update download

Purpose. To offer you new versions, including security updates.

When. Also without a licence: WebDonkey at start, WebDonkey Editor and WebDonkey Pages four seconds after start, then every ten minutes while the app is running, and when you look for updates yourself. In WebDonkey Editor you can switch off the automatic check in the settings; in WebDonkey and WebDonkey Pages you cannot.

Sent. The address of the request contains the product, the operating system, the processor architecture and the installed version. In addition the user agent of the update module (“tauri-plugin-updater/version”), for WebDonkey also the language of the app (German or English), and your IP address. No licence key, installation or device identifier is sent.

Answer. No new version, or version number, release notes, date, download address and signature. If you load the update with “Install”, the app fetches the file from our server and checks its signature on your Mac. If a change to our terms has been announced, the answer also contains its version, date, the day it takes effect and the addresses of the new text; it contains no information about you. The hourly import may count downloads of update files like other downloads (section 4).

Stored in the shop. For each day one entry per hash, product and app version, with the date, a hash of IP address and user agent that we form with a secret key, the platform, the number of requests and the first and last request of the day. After 90 days we merge the entries into daily figures per product, version and platform without the hash and delete them; the daily figures remain. Because the hash is formed the same way every day, requests from the same IP address can be linked across several days within these 90 days. Because all apps send the same user agent, the hash in practice depends only on the IP address; several Macs behind one IP address count as one.

Legal basis. Our legitimate interest in secure, up-to-date software and in figures on its distribution (Art. 6(1)(f) GDPR).

9.4 Release notes

When. When you open the release notes in an app or page through them; also without a licence.
Sent. Product, the requested page of the list and the language (German or English), your IP address and the user agent: for WebDonkey that of the app's built-in browser with the app's origin header, for WebDonkey Editor and WebDonkey Pages none.
Answer. The release notes of the requested page.
Stored in the shop. Nothing apart from the log file; the requests do not count as page views.
Legal basis. Art. 6(1)(f) GDPR.

9.5 Online documentation

When. When you open the documentation in an app, navigate or search in it; also without a licence. The app loads the table of contents only when opened and reuses what it loaded for ten minutes.
Sent. The address of the file, which reveals product, chapter and language, for screenshots also whether you use the app in light or dark mode; plus your IP address, the user agent and language of the app's built-in browser and the app's origin header. No login or session data is used.
Answer. Table of contents, texts, search index and images. Without a connection WebDonkey shows its built-in documentation.
Stored in the shop. Nothing apart from the log file; the requests do not count as page views.
Legal basis. Our legitimate interest in up-to-date documentation (Art. 6(1)(f) GDPR).

9.6 Theme gallery

In WebDonkey, WebDonkey Editor and WebDonkey Pages you can take over colour presets (“themes”) from a gallery and submit your own. You only use the gallery when you open it; WebDonkey Pages only loads it when you click.

Viewing and searching (without licence key). Sent are page size, type of preset (app or editor), sort order, continuation marker, plus your IP address and the user agent “WebDonkey/version” (from all three apps). The apps do not send your search term; they search the loaded presets on your Mac. The only thing stored is a counter under a SHA-256 hash of your IP address to limit requests (at most 120 per ten minutes), which expires after ten minutes.

Viewing, submitting and withdrawing your own presets (with licence key). Your licence key is sent, when submitting also the preset: name, icon, light or dark, background and two accent colours or the editor preset (at most 4 KB). You can submit in WebDonkey and WebDonkey Editor with WebDonkey Premium, in WebDonkey Pages with a Pages plan. We store the preset with status, counter and timestamps, together with the SHA-256 hash of your licence key. The same hash is stored with your licence, so we can assign a preset to your customer account. We use this only to enforce submission limits (at most 20 write requests per hour and licence), to show you your own presets, to handle your requests and to remove unlawful content. We review every preset before release. The gallery never shows who submitted a preset. You can withdraw a preset as long as it has not been released; released presets remain in the gallery, and we delete them on request. If your customer account is deleted, we delete presets not yet released and remove the hash from released ones.

Counting take-overs (without licence key). If you take over a preset (in WebDonkey Editor with Premium), the app sends only its identifier. So that the same take-over is not counted twice, we keep a SHA-256 hash of the preset identifier and your IP address (for IPv6 the /64 network) in a cache for seven days, plus a counter under a hash of this network for one hour. We form both hashes without a secret key; for IPv4 the IP address could be found from them by trial. They are not combined with your customer account or your licence. The database only stores the total number with the preset.

Answer. Lists of presets with identifier, name, icon, colours or editor preset and number of take-overs, for your own presets their status; never the author.

Legal basis. Art. 6(1)(b) GDPR for your own presets, otherwise our legitimate interest in a working, misuse-proof gallery with meaningful sorting (Art. 6(1)(f) GDPR).

9.7 Links from the apps

Some buttons in the apps open a page of the shop or the website in the browser, such as Premium, the customer account, the download page, the page for reporting a problem, the legal texts or the invitation to our Discord server. The app itself sends nothing; sections 3 to 8 apply to the visit in the browser.

9.8 What the apps never send to us

  • Contents of your projects, sites and websites, files, databases, credentials for servers, what you enter into Claude or other AI services, email address or identifier of your customer account.
  • Your hardware identifier and your user name, except as a hash in the device identifier (section 9.2), and never the MAC address.
  • For the update check, release notes, documentation, gallery viewing and take-over counter: neither licence key nor installation or device identifier.
  • Usage statistics, crash reports or other telemetry. The user interface of the apps may only exchange data with shop.webdonkey.io, webdonkey.io and destinations on your Mac. In addition, WebDonkey's user interface loads images from websites you check (such as the preview image in the page inspector), and the live previews of the toolbox load their building blocks from the CDNs named in section 10.2. In both apps the notes view (notes and Second Brain, with Premium) also loads the images a note embeds by a web address, unless you switch this off for the vault (section 10.6).

9.9 All interfaces at a glance

All requests are also recorded for about 30 days in the hosting provider's log file (section 3).

9.10 Summaries in the apps

WebDonkey and WebDonkey Editor show a summary of this policy under “Legal”. This privacy policy prevails; an installed app may contain an older version. The apps also point out the consequences immediately before individual steps, for example before WebDonkey fetches a database containing personal data onto your Mac. These notices supplement this policy; they do not change it.

10. Connections of the apps to third parties

10.1 Principle

For many functions the apps connect from your Mac directly to third-party services or to destinations you specify yourself. We are not involved and receive no data. The provider concerned receives your IP address and the information stated; its privacy notice applies. The main connections:

10.2 WebDonkey

  • Installing and updating software: the official sources of the manufacturers, such as Homebrew, npm, GitHub, Packagist, manufacturers' downloads and mirror servers for the system images of virtual machines.
  • Logos of the tools: the manufacturers' websites or their profile on GitHub.
  • Only when you use the function: the icon search Iconify (api.iconify.design, with your search term), the component libraries shadcn/ui, Magic UI, Kibo UI and uiverse (via GitHub), the CDNs esm.sh and jsDelivr for the live preview of React components (with the names of the packages needed) and, for domain monitoring, the directory service rdap.org (with the monitored domain name).
  • Local AI: WebDonkey loads models from registry.ollama.ai or huggingface.co. Chats with local models stay on your Mac. If you choose a cloud model from Ollama, your input goes to Ollama Inc., USA. Coding agents in the terminal (such as Qwen Code, Aider, Codex, OpenCode) are programs of their manufacturers that WebDonkey installs and starts at your request; if you connect them to a cloud provider, your input and the code the tool reads go to that provider. WebDonkey starts them with usage statistics switched off where the manufacturer offers a switch for this.
  • Claude management: If Claude Code is installed, WebDonkey loads Anthropic's price list (platform.claude.com) to display usage, checked at start and while WebDonkey runs: at most once a day, after an error or while a model in use has no price there yet at most once an hour, never without a network connection. Only the app identifier “WebDonkey” is sent, no information about you. WebDonkey reads the costs of your sessions from the amounts Claude Code itself writes into its histories on your Mac; they do not leave your Mac. Claude Code itself is a program by Anthropic; what you ask Claude to do and which code and which notes it reads goes to Anthropic, and Anthropic's terms apply. If you assign a Second Brain (a folder of notes) to a Claude project in WebDonkey, sessions of that project in WebDonkey Editor receive this folder (section 10.4). If you start Claude in a WebDonkey brain or a personal Second Brain, Claude can retrieve its notes through a read-only access that WebDonkey starts on your Mac for this (brain MCP); it connects to no one, and what Claude retrieves through it goes to Anthropic like other notes it reads. For Claudian brains, setting up a personal Second Brain and editing notes with Claude, section 10.6 applies in addition.
  • SEO package: Audits request the pages of the website you check. For the accessibility check WebDonkey starts a Chromium browser installed on your Mac (such as Google Chrome) without a window and loads the pages with everything they embed, such as fonts, scripts or statistics services of other providers; these receive your IP address. WebDonkey loads the required test modules from the npm registry the first time.
  • Online check: Whether your Mac itself is connected to the internet, WebDonkey checks with a request without content (HEAD) to one.one.one.one (Cloudflare, Inc., USA) and, if no answer comes from there, to dns.google (Google LLC, USA). This happens before every check round of the monitoring, when a check in the monitoring fails, in an audit of the SEO package when pages do not answer (if the connection is missing, then about every 15 seconds until it is back), and after a failed scheduled flow test of the maintenance package. This way WebDonkey does not take a missing connection of your Mac for an outage of your website. Both providers receive your IP address and the time, but no information about you or your websites.
  • Destinations you specify: your own servers (SSH, SFTP, databases, mailboxes), websites in monitoring, requests in the API client, workflows, checking MCP servers and pages in the built-in browser.
  • Sending mail: If you write a mail under Remote › Mail, WebDonkey sends it through the account's outgoing server (SMTP), directly or through its SSH connection, to the recipients you enter; as a test it only goes to the local Mailpit. WebDonkey stores the outbox (sender, recipients, subject, text, names and sizes of attachments, result and the server's answer) only on your Mac; you can delete entries one by one, they go when the account goes, and the app's backup includes them. WebDonkey files no copy in the mailbox's “Sent” folder. You, not we, are responsible for these mails.

10.3 Maintenance package in WebDonkey

With the maintenance package you look after websites on servers you specify. Here too we receive no data; all connections go from your Mac directly to the destination, and the checks only run while WebDonkey is running. If a scheduled flow test fails, WebDonkey also uses the online check from section 10.2.

  • Updates: WebDonkey asks public directories for new versions. Names and versions of the installed extensions and packages are sent, for WordPress also the versions of WordPress and PHP and the language of the website, but not its address. Destinations: api.wordpress.org and downloads.wordpress.org (WordPress.org), repo.packagist.org (Packagist), registry.npmjs.org (npm), releases.shopware.com (Shopware) and mirror.mage-os.org (Mage-OS). Requests to Packagist carry the app's identifier with version number and our contact address.
  • Known vulnerabilities: Names and versions of the installed packages go to api.osv.dev and to the npm registry. From Packagist WebDonkey loads the list of known vulnerabilities without information about your websites. WebDonkey loads the Wordfence vulnerability feed only if you have entered your own key, at most every 30 minutes; only this key is sent, and the matching against your websites takes place on your Mac.
  • File checksums: For WordPress, WebDonkey loads the official checksums from WordPress.org (sending version and language of WordPress or name and version of a plugin). A helper program on your server checks the files themselves; their content does not leave the server.
  • Applying Shopware updates: Your shop's server loads extensions from the Shopware Store using the shop's own store access; the access stays on the server. WebDonkey loads other extensions on your Mac via Packagist and the download address stored there (often GitHub), checks their checksum and transfers them to the server by SFTP.
  • Your servers and websites: WebDonkey connects via SSH and SFTP to the servers you specify and requests the maintained websites, their staging and their sitemap via HTTP, for example after every push. When you add a website, WebDonkey briefly places a test file on the server and requests it via the address to check that folder and address belong together. Visual comparisons and flow tests open the pages in your Chromium browser; the pages also load the services they embed themselves, with your IP address. WebDonkey hides cookie banners for the capture without giving consent. If you switch the maintenance mode of a Shopware sales channel via WebDonkey, WebDonkey enters your Mac's IP address from the SSH connection in the shop's allow list. WebDonkey uploads the status page by SFTP to a folder you choose; it contains no external content and no tracking.
  • On your Mac: check results, reports, screenshots, checksum lists, the state before every push, local copies of your websites and, if you wish, copies of the backups. Before every fetch into a local copy, WebDonkey backs up its database; the last three per website are kept. WebDonkey deletes older entries itself, for example individual results of the update check after 40 days and visual comparisons beyond the last twelve. WebDonkey stores credentials (for example for the staging database, access protection, test accounts of the flow tests and your Wordfence key) encrypted (AES-256-GCM); the key for this is kept separately from the database in the app's configuration folder.
  • On the servers you maintain: Before every write, WebDonkey creates a backup there of the database and the files affected, when restoring a backup only if you do not deselect it; at least the last ten per environment of a website (live, staging) are kept. They remain there until you delete them, even after archiving or the end of your licence. WebDonkey copies personal data into staging and local test copies only in replaced (pseudonymised) form: names, email addresses, postal addresses, phone numbers and IP addresses of customers are replaced as early as the export on the server; sessions, baskets, payment tokens and logs are emptied. This is pseudonymisation, not anonymisation: the numbers of the records, the order contents and the administrators' accounts remain.
  • Fetching locally: Without the maintenance package, WebDonkey copies the database to your Mac unchanged, with all personal data of the website; the app points this out beforehand and asks for your confirmation.
  • Your role: You, not we, are responsible for the data on the websites you maintain. If you look after websites for clients, you usually process their data as their processor (Art. 28 GDPR); your agreement should also cover copies on your Mac, staging and backups. We are neither controller nor processor in this respect, because we have no access to this data.

10.4 WebDonkey Editor

WebDonkey Editor connects to third parties only at your instigation: with Premium to your own servers (SSH, SFTP, databases, mailboxes), for Git commands to your Git server, via the program gh to GitHub, when setting up Claude Code to Homebrew and npm. What you ask Claude Code to do in the terminal and which code it reads goes to Anthropic. If you assign a Second Brain (a folder of notes) to a Claude project or a Claude session, Claude Code can also read its notes, and the names and paths of your notes folders are part of the instruction to Claude; this goes to Anthropic as well. Such sessions get the read-only access from section 10.2 (brain MCP), which the Editor starts on your Mac. For the notes, Claudian brains, setting up a personal Second Brain and editing notes with Claude, section 10.6 applies. If you download a model in the local AI, the Editor downloads it via Ollama from registry.ollama.ai or huggingface.co. If you choose a cloud model from Ollama in the local AI, your input goes to Ollama. If Claude Code is installed, the Editor too loads Anthropic's price list to display Claude usage as described in section 10.2, also when WebDonkey is not running. If WebDonkey is not installed, the Editor stores licence, server connections (passwords encrypted) and settings in a database of its own on your Mac. The Editor stores your own local database connections on your Mac, their passwords in the macOS keychain.

10.5 WebDonkey Pages

The contents, drafts, photos and settings of your websites stay on your Mac. Pages connects directly:

  • to the AI you choose as AI access. With your own API key, your chat input, the details about your website and the files the AI reads to build go to Anthropic; your contract with Anthropic and its privacy notice apply. Pages stores the key encrypted on your Mac and sends it only to Anthropic. If you choose your Claude Code, Pages uses its login on your Mac;
  • when publishing by SFTP, to the server you specify. If you let Pages prepare a server of your own, that server loads the web server Caddy from its official package source and obtains certificates from Let's Encrypt; your Mac queries the DNS records of your domain and checks whether the server responds;
  • for the automatic checks, Pages starts a browser installed on your Mac (Google Chrome, Chromium or Microsoft Edge) without a window and lets it open your website locally. Which data the browser itself sends to its manufacturer depends on its settings and terms.

If WebDonkey is installed, Pages and WebDonkey only work together locally on your Mac. Websites you export in the Free scope contain a plain text link “Built with WebDonkey Pages” to webdonkey.io in the footer, without script, image or tracking pixel; only when visitors to your website click it do they visit our website.

10.6 Notes and Second Brain (WebDonkey and WebDonkey Editor)

With Premium both apps show and edit folders of notes on your Mac the way Obsidian does. The following applies:

  • Images from the web in notes. If a note embeds an image by a web address (such as ![](https://…) or an image in HTML, also in a text card of a canvas), the notes view loads it when it is shown (in the reading view as in Live Preview), without asking, directly from the server at this address, as Obsidian does, as long as “Load content from the web” is switched on for the vault (default). The recipient is the operator of that server. It receives your IP address, the address of the image, the time and the technical information the view sends with every request (such as the identifier and language of the view). The view sends neither the origin of the request (referrer) nor cookies. From this the operator can tell that and when the image was retrieved from your internet connection; an image can thus act like a tracking pixel. The server may be located outside the EU. We receive no data in the process; the operator of the server is responsible for the processing on it, and its privacy notice applies. The view does not embed audio, video or web pages from the web; web page cards of a canvas only show their address, and a click opens it in your browser. Images, PDFs, audio and video stored as files in the folder are read by the view only on your Mac. The Markdown preview outside the notes (such as a README in the Editor) loads nothing from the web.
  • You decide what is in your notes. A web address is only in a note if you, Claude or another program put it there, for example when taking over content from the web, or if you take over other people's notes or open a shared folder. If a server is not to learn of a retrieval, switch off “Load content from the web” for the vault: the view then shows a placeholder in its place and only loads the image when you click it. You can also store the image as a file in the folder and embed it from there, or remove the address. The app stores this setting in its database on your Mac, not in the vault. If several people share a folder, every device that shows the note loads these images according to its own setting.
  • Legal basis. Showing notes as they are written, including the images they embed from the web, is part of the agreed service (service description, sections 4.3 and 5.3). Insofar as we are responsible under data protection law for this design of the apps, we base it on Art. 6(1)(b) GDPR and, for example where your company rather than you is the contracting party, on Art. 6(1)(f) GDPR. Our legitimate interest is to show notes without asking before each piece of content, as Obsidian does, so that the same note looks the same in both programs.
  • Setting up a personal Second Brain. If you choose the kind “Personal Second Brain”, the app puts a guide into the folder as CLAUDE.md; it connects to no one in doing so. The setup is run by Claude Code, a program by Anthropic (sections 10.2 and 10.4), in WebDonkey in the terminal, in the Editor in Mission Control. Claude asks you, for example, for your name, profession and fields of expertise, your projects, areas and topics. Your answers, including information about other people, go to Anthropic; Claude creates folders and notes from them on your Mac. You decide what information you give.
  • Obsidian Skills. The guide instructs Claude to ask you whether it may install the Obsidian Skills from github.com/kepano/obsidian-skills (open source, MIT licence) into the brain's folder .claude/skills/, and to download them only after your express yes. Claude Code then downloads them itself from GitHub (GitHub, Inc., USA); GitHub receives your IP address and the request. How Claude Code performs the download depends on Claude Code and your settings there. The apps do not download the skills. Claude only points to the Obsidian plugin Iconize; if you install it, that happens in Obsidian.
  • Claude in a personal Second Brain after its setup. If you start Claude in a personal Second Brain after its setup, the apps give Claude a short working guide in addition to its instruction. It names the link format and the folders for attachments, daily notes and templates, which the apps read for this on your Mac from the folder's Obsidian settings (.obsidian/); it goes to Anthropic with the instruction. Sessions in a personal Second Brain or a WebDonkey brain also get the read-only access from section 10.2 (brain MCP).
  • Claudian brains. Every brain has a kind that you choose and can change: Claudian brain, WebDonkey brain or personal Second Brain. The app stores the kind in its database on your Mac, not in the folder. Obsidian vaults for which you have not chosen a kind are usually treated as Claudian brains. There both apps start Claude Code the way the Obsidian plugin Claudian does: with Claudian's system prompt (open source, MIT licence) and the folder's Claudian settings, such as model, permission mode, environment variables, custom instructions and skills, and without such settings with Claudian's defaults. The system prompt names the folder's path on your Mac and, if you have entered it in Claudian, your name; it goes to Anthropic with your messages. Claude Code starts the MCP servers entered for Claude Code in the folder (.mcp.json, from older Claudian versions .claude/mcp.json) without asking, as in Claudian, and Claude Code's question whether you trust the folder does not come up for this session. Whom these servers connect to is up to them; we receive no data in the process. A session that starts in a Claudian brain does not get the read-only access from section 10.2 (brain MCP).
  • Chats in Claudian. If the Claudian plugin is set up in the folder, the app creates a small file under .claudian/sessions/ in the folder for every chat you begin there in the app: a title (the beginning of your first message, at most 50 characters), times, the session's identifier and the linked note. This way Claudian shows the chat in its list; conversely the app shows chats from Claudian with their titles. Claude Code stores the history itself on your Mac. The file lies in the folder and is synced or shared with it if you do so; you can delete it in Claudian or as a file.
  • Working and editing with Claude. “With Claude” gives Claude the path of the open note and the selected text with every message, and so does Mission Control in a Claudian brain (the open note with the first message). “Edit with Claude” (only on your click or with ⌘⇧E) sends the selected text or the paragraph at the cursor, your instruction and the note's path through your Claude Code to Anthropic. Claude may only read: files of the folder and, as in Claudian, search the web and fetch web pages. The app applies the change only on your click; Claude Code does not store this edit as a session.
  • Brain from existing notes. If you let Claude set up a Claudian or WebDonkey brain from the notes of a folder, Claude reads the notes and proposes a guide or a structure; what Claude reads goes to Anthropic. On request the app first creates a zip backup of the folder next to it; it stays on your Mac.

11. Recipients and transfers to third countries

We only pass on personal data where a legal basis permits it. Recipients are:

Creators receive no data of our customers. Data can only reach third countries outside the EU and the EEA through the services in section 7 and through Discord (section 8.16), with the safeguards stated there. Connections that the apps establish directly to providers outside the EU at your instigation (section 10) are not transfers by us.

12. Retention at a glance

We delete data as soon as it is no longer needed for its purpose and no retention obligation applies. The following table shows the actual state; “no automatic deletion” means the data remains until we delete it.

13. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR). You can withdraw consent at any time with effect for the future (Art. 7(3) GDPR), for statistics and ad measurement via “Cookie settings” at the bottom of every page. You can lodge a complaint with a supervisory authority (section 2). An email to info@webdonkey.io is sufficient for all requests.

Right to object (Art. 21 GDPR)

Where we process data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you can object to this at any time on grounds relating to your particular situation. We will then no longer process the data unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. You can object at any time, without giving reasons, to the use of your data for direct marketing, for example for offers by email (section 8.12); we will then no longer use it for this.

14. Provision of data and automated decisions

For customer account and order we need the information marked as mandatory; without it we cannot conclude a contract. The information of the licence check is needed so that the apps unlock the functions of your licence; without a licence key the apps run in the Free scope. Beyond this you are not obliged to provide us with data.

We do not take decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR). The automatic allocation of a licence's seat only implements the agreed rules of use (Terms § 6); we are happy to clarify questions about it with you personally.

15. Changes

We update this privacy policy as soon as changes to website, shop or apps require it. The version published at any given time applies.