Offline Translator (working title) — Privacy Policy
Version 1.0 · Effective 10 August 2026 · https://sunwardliving.sg/privacy/translator/
People translate the things they cannot read and often would not want to forward: a contract clause, a diagnosis, a private message. This app is built so that none of it leaves the device.
This application has not been released. It is in development and has not been submitted to App Store review. This policy is published in advance so that it can be reviewed alongside the app. It will be re-examined before submission, and if the app changes in any way that affects this document, the version number and effective date above will change with it.
The short version
- Translation runs on your device. The text you translate is processed locally and is not sent to us or to any third-party translation service.
- It works in airplane mode. Once the app and its language data are installed, translation needs no network connection at all.
- There is no account. No sign-up, no email address, no phone number, nothing for us to hold.
- We keep no translation history on our side. Any history the app offers lives on your device and is deleted when you clear it or remove the app.
- No advertising, no profiling, no data sales. Ever.
This summary is here for readability. The sections below are the operative terms.
Who we are
This application is developed and published by:
We are a private limited company incorporated in Singapore on 19 September 2025 and we are the organisation responsible for personal data handled in connection with this application, within the meaning of Singapore's Personal Data Protection Act 2012 ("PDPA").
What this policy covers
This policy covers the offline translation application currently under development by SUNWARD LIVING PTE. LTD.. It does not cover any other application, or any website or service you may copy text from or paste text into.
Translation happens on the device
There is no translation server in this product. When you translate something, the work is done by software and language data on your phone. The text is not uploaded, not queued for later upload, and not retained by us in any form — we operate no service capable of receiving it.
This is a structural property of the design rather than a policy choice layered on top of it. It is also the reason the app can be used with the network switched off, and the reason there is no "delete my translation history from your servers" procedure: there is no such history to delete.
What the app handles, and what we receive
The text you translate
Processed on your device, for the sole purpose of producing the translation you asked for. Not transmitted, not logged by us, not used to train anything.
Local data on your device
The app may store your language preferences, downloaded language data and — if the app offers the feature and you use it — a translation history or a list of saved phrases. All of this is kept in the app's own storage on your device under the protection iOS provides, and is removed when you clear it in the app or delete the app.
Language pack downloads
Language data may need to be downloaded before it can be used offline. Such a download is an ordinary file transfer: it fetches a language pack and carries none of your text with it. It reveals which language pack was requested, and nothing about what you intend to translate.
Analytics
The app does not embed third-party analytics or advertising software development kits. If you have chosen, in iOS Settings, to share analytics with app developers, Apple may provide us with its own aggregated and anonymised crash and usage reports. Those come from Apple, describe the app rather than you, and contain none of the text you have translated. You control that setting in Settings › Privacy & Security › Analytics & Improvements.
Optional permissions
If the app offers a feature that requires a device permission — for example the camera, in order to translate text in a photograph, or the microphone, for spoken input — iOS will ask you first, the app will explain why at that moment, and declining will leave the rest of the app working. Content captured for such a feature is processed on the device on the same terms as typed text. Any feature of this kind that ships will be described here before it does.
How data is used
Data the app handles is used solely to
- produce the translation you have asked for;
- remember your settings, downloaded languages and anything you have deliberately saved;
- diagnose faults in the app, using the aggregated reports described above.
What we never do
The following are not part of this application and will not be introduced without a new version of this policy and a clear notice in the app:
- We do not build advertising or behavioural profiles of you.
- We do not display advertising in the app.
- We do not sell, rent or trade personal data to anyone, for any purpose.
- We do not share personal data with data brokers, marketing networks or analytics networks.
- We do not use personal data to track you across other companies' apps or websites, and we do not ask for permission to do so.
- We do not use the text you translate to train translation models, because that text never reaches us.
Disclosure to others
We do not disclose personal data to third parties. The narrow exceptions, none of which involve routine operation of the app, are: where we are required to do so by Singapore law or by a lawful order of a court or regulator; and where it is necessary to protect our legal rights. Any such disclosure is limited to what we actually hold — which, by design, does not include your translations.
Retention
We hold no translation data, so there is nothing for us to retain or delete on your behalf. Data stored locally by the app remains on your device until you clear it or delete the app. Correspondence you send us by email is kept only as long as needed to deal with the matter and to meet our record-keeping obligations.
Security
Because translation and storage happen on your device rather than on our systems, security rests principally on the protections iOS provides: app sandboxing and device encryption. We recommend keeping a passcode set and iOS up to date.
No method of storage or transmission is perfectly secure. We aim to keep the number of places your data could be exposed as small as possible, which is why the design keeps data on your device rather than accumulating it on a server.
Transfers outside Singapore
Section 26 of the PDPA restricts the transfer of personal data out of Singapore. Because this application does not send your personal data to us or to any third party, there is no such transfer to disclose. If that ever changes, this policy will be updated to identify the recipient, the country and the protection applied, before the change takes effect.
Children
This application is a general-purpose utility. It is not directed at children, and we do not knowingly collect personal data from children. Because the app does not ask for an account, a name, an email address or a date of birth, we hold no information from which a user's age could be determined.
Your rights under the PDPA
Under the PDPA you may ask us:
- For access — whether we hold personal data about you, what it is, and how it has been used or disclosed in the past year.
- For correction — to correct an error or omission in personal data we hold about you.
- To withdraw consent — to stop using or disclosing your personal data for a purpose you previously agreed to. We will tell you the likely consequences before the withdrawal takes effect.
Send any of these requests to dpo@sunwardliving.sg. We will respond as soon as reasonably possible and, in any event, within the timeframes set by the PDPA.
In practice, most requests will get a short answer: the app is built so that we do not receive your data in the first place, and we can only produce what we actually hold. Data stored by the app on your device is under your control — deleting the app removes it.
Data Protection Officer
Section 11(3) of the PDPA requires an organisation to designate at least one individual as its Data Protection Officer and to make that person's business contact information available to the public.
This address reaches the individual designated as our Data Protection Officer. Access requests, correction requests and any other data protection matter can be sent here directly.
If you are not satisfied with our response, you may raise the matter with Singapore's Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.
Changes to this policy
If we change this policy we will update the version number and effective date at the top of this page. Material changes — anything that would newly permit the collection, use or disclosure of personal data — will also be surfaced in the app itself, and, where the PDPA requires it, we will ask for your consent before the change applies to you.
Because the URL of this page is quoted in the app's App Store listing, we keep the URL stable across product name changes. The address of this page will not move.
Version history
- Version 1.0 — 10 August 2026 — first publication, ahead of the app's submission for App Store review.
Contact
Questions about this policy, about what the app does with data, or about anything else on this site: