Privacy Policy
Effective date: 27 April 2026 Version: 1.0
This policy explains what data Klem HQ collects, why we collect it, and what we do with it. It covers the Klem HQ website (klemhq.com) and the products we ship — currently PageKeeper, our app on the Atlassian Marketplace.
We have written this in plain English. Where a legal term has a precise meaning under the EU General Data Protection Regulation (GDPR) or similar laws, we use it deliberately.
1. Who we are
Klem HQ is an indie software studio. It is operated as a sole proprietorship by an individual proprietor based in Asia, trading under the name "Klem HQ". "Klem HQ", "we", "us", and "our" in this document refer to that sole proprietorship.
The full legal entity details, including the proprietor's name and registered address, are available on written request to privacy@klemhq.com. We provide them where the request is legitimate (for example, to support a verified data subject rights request, a Marketplace dispute, or a regulator inquiry).
For privacy questions, write to privacy@klemhq.com.
For the purposes of GDPR Article 4(7), Klem HQ acts as a data controller for the limited personal data described in section 2, and as a data processor when handling Confluence content on behalf of an Atlassian customer using PageKeeper.
2. Data we collect
We collect only what each surface needs to function. There is no general-purpose telemetry, no advertising SDK, and no third-party analytics in our products.
2.1 The Klem HQ website (klemhq.com)
- Standard request logs from our hosting provider (IP address, user-agent, timestamp, requested URL). These are kept for short-term security and abuse prevention.
- If you email us at any
@klemhq.comaddress, we receive your email address, name (if provided), and message contents.
We do not run third-party analytics, advertising pixels, or retargeting scripts on klemhq.com. See section 9 for the full cookie position.
2.2 PageKeeper (Atlassian Marketplace app)
PageKeeper is a Forge app installed by an Atlassian Cloud administrator into a Confluence site. The app processes the following categories of data on behalf of that customer:
- Confluence page metadata — page IDs, titles, parent space ID, last-modified timestamp, owner account ID, and view counts where Confluence exposes them. We do not read or store the body content of pages.
- Confluence space metadata — space IDs and names of spaces an administrator has chosen to scan.
- User identity — Atlassian Account IDs of administrators configuring the app, and of page owners we contact about stale pages. These are obtained from the Forge
bridgeand Confluence REST APIs under the scopes declared in our Forge manifest (read:user:confluence,read:page:confluence,read:space:confluence,write:page:confluence). - Customer configuration — scan schedule, stale thresholds, notification preferences, archive rules, and the list of spaces in scope.
- Operational audit log — timestamps of app actions (scans run, notifications sent, pages archived) for diagnostic and accountability purposes.
We do not collect: page body content, attachments, comments, payment information, browsing behaviour outside the app, marketing-style profile data, or biometric / sensitive categories of data under GDPR Article 9.
2.3 Billing data
Billing is handled entirely by Atlassian through the Atlassian Marketplace. We do not see your credit-card number, billing address, or invoice details. Atlassian shares with us a monthly statement of license counts and payouts; that statement is processed by Atlassian's payout partner Tipalti and settled to our Payoneer account.
3. Why we collect it (lawful basis under GDPR)
| Data | Purpose | Lawful basis (GDPR Art. 6) |
|---|---|---|
| Website request logs | Security, abuse prevention | Legitimate interest (Art. 6(1)(f)) |
| Email correspondence | Replying to you | Legitimate interest; or contract performance if you are a customer |
| Confluence metadata processed by PageKeeper | Performing the service the customer installed the app for | Contract performance with the Atlassian customer (Art. 6(1)(b)); processed on the customer's behalf |
| Atlassian Account IDs | Identifying who configured the app, who owns a page, who to notify | Contract performance |
| Aggregate Marketplace statements | Tax, accounting, and payout reconciliation | Legal obligation (Art. 6(1)(c)) and legitimate interest |
Where we rely on legitimate interest, we have considered the impact on you and concluded that the processing is limited, expected in context, and does not override your rights.
4. How we use the data
We use the data described above to:
- Run PageKeeper's stale-page scanner and notifier as configured by the installing administrator.
- Respond to support requests.
- Detect and respond to security incidents and abuse.
- Meet our tax, accounting, and Marketplace reporting obligations.
- Improve the product based on aggregated, non-identifying patterns (for example, "scans on instances above 50,000 pages take longer than expected").
We do not:
- Sell your data, ever.
- Use your data to train machine-learning models.
- Run behavioural advertising or build cross-customer profiles.
- Read the body content of your Confluence pages.
5. Sharing and subprocessors
We share data only with the small number of providers needed to run the service. Our current subprocessors are:
| Subprocessor | Role | Region |
|---|---|---|
| Atlassian | Marketplace, Forge runtime, billing, customer authentication | Customer-selected (see section 6) |
| Cloudflare | DNS and email routing for @klemhq.com |
Global edge |
| Tipalti | Payout processing for Marketplace earnings | United States |
| Payoneer | Receiving Marketplace payouts | United States / Hong Kong |
We will update this list before adding any new subprocessor that processes personal data.
We will disclose data to a public authority only when compelled by valid legal process binding on us, and we will push back on overreaching requests where we can.
6. Data residency
PageKeeper runs entirely inside the Atlassian Forge runtime. Forge data — including any storage we use under the storage:app scope — is hosted on AWS infrastructure operated by Atlassian, in the AWS region tied to your Atlassian Cloud instance. We do not run our own backend, our own database, or our own AWS account for PageKeeper.
This means: PageKeeper inherits whatever data residency Atlassian Cloud gives you. We do not make an independent residency claim. Atlassian's data residency documentation is the authoritative source for where your data sits at rest.
The Klem HQ website itself is served from a global content delivery network (Cloudflare), which means request logs may transit through edge locations worldwide.
7. Retention
- Website request logs — up to 30 days.
- Email correspondence — kept while the conversation is active and for a reasonable follow-up period; deleted on request.
- PageKeeper customer configuration and audit logs — kept for the lifetime of the app installation, then deleted within 90 days of uninstall, except where law requires longer retention.
- Confluence metadata cached by PageKeeper — refreshed on each scan; not retained beyond what's needed to detect changes between scans.
- Marketplace payout statements — kept for at least 7 years where required by tax law.
8. Your rights
If you are in the European Economic Area, the United Kingdom, or another jurisdiction with comparable data-protection law, you have the right to:
- Access the personal data we hold about you.
- Correct it if it is wrong.
- Ask us to erase it (subject to lawful retention obligations).
- Restrict or object to certain processing.
- Receive a copy of data you provided to us in a machine-readable form (data portability).
- Lodge a complaint with your local data protection authority.
For most PageKeeper data, the Atlassian customer (your employer or the organisation that installed the app) is the data controller and we act on their instructions. Please raise rights requests with them first; if they direct us to act, we will. For data we hold as a controller — such as direct correspondence — write to privacy@klemhq.com and we will respond within 30 days.
We have not appointed a formal Data Protection Officer because, given our scale and the nature of our processing, GDPR Article 37 does not require one. The privacy mailbox above is the single point of contact.
9. Cookies
The Klem HQ website (klemhq.com) uses only strictly necessary cookies — currently, none beyond what our hosting provider sets for security and load balancing. We do not set analytics, advertising, or preference cookies, so we do not display a cookie banner.
PageKeeper, running inside Confluence, uses session cookies set by Atlassian; we do not set cookies of our own inside the Forge iframe.
If we ever add analytics, we will switch to a privacy-respecting tool (server-side, no cross-site tracking) and update this policy in advance.
10. Children
Our products are designed for workplace use. We do not knowingly collect data from anyone under 16. If you believe a child has provided us with personal data, write to privacy@klemhq.com and we will delete it.
11. International transfers
Klem HQ is operated by an individual proprietor based in Asia; our subprocessors are largely based in the United States and on global infrastructure. When personal data of EEA or UK residents reaches us, the transfer is made under the European Commission's Standard Contractual Clauses (or the UK International Data Transfer Addendum where applicable), supplemented by the technical measures described in this policy — primarily the fact that we do not store the body content of customer documents and that all PageKeeper data sits inside the Atlassian Forge perimeter.
12. Security
- All traffic to our website and within Forge is encrypted in transit (TLS 1.2+).
- Forge storage is encrypted at rest by Atlassian.
- We follow the principle of least privilege for the Forge scopes we request.
- We do not run our own servers, which removes a large class of operational risk.
- We will notify affected customers without undue delay — and in any event within 72 hours where GDPR Article 33 requires it — of any personal data breach we become aware of.
13. Changes to this policy
We will update this policy when our processing changes. Material changes will be announced on klemhq.com/legal/privacy-policy and, where appropriate, by email to active customers, with at least 14 days' notice before the change takes effect. Each version is dated; older versions are available on request.
14. Contact
Klem HQ — a sole proprietorship. Privacy mailbox: privacy@klemhq.com General mailbox: hello@klemhq.com Postal address and full legal entity details: available on written request to the privacy mailbox.
If you are not satisfied with our response, you may complain to your local data protection authority. Within the EU, a list is maintained at https://edpb.europa.eu/about-edpb/about-edpb/members_en.