Privacy statement

Who is responsible?

The controller for the processing described here is Gwen Huyge, who is self-employed on a part-time basis and created Anatomino:

• Postal address: [to be completed: postal address], Belgium
• Company number: [to be completed: company number]
• Email: [to be completed: email address]

In this statement, “I” refers to me as the controller. You can come to me with any question about your data.

The app: your data stay on your computer

You do not need an account with me to use Anatomino. What you enter in the app and what the app keeps track of stays only on your own computer:

• your profiles: user name, email address and a secure derivative (hash) of your password, never the password itself;
• your practice rounds, results and settings;
• if you have one: your licence code, the proof that it is activated on this computer, and the time of the last online confirmation;
• back-ups, which you make yourself or which the app makes before an update.

These data are stored in a folder of your user account: on Windows %APPDATA%\Anatomino, on a Mac ~/Library/Application Support/Anatomino. I have no access to them and the app does not send them anywhere. You delete them by removing that folder. Uninstalling the app deliberately keeps that folder, so that you do not lose your history by accident.

The email address of your profile is used to link your licence to it. The licence code does not contain your email address, only a short derivative (hash) from which the address cannot be read. That way the app can check that the code belongs to your profile.

To seal the data of the licence check and to derive a device identifier for your licence (see below), the app calculates a key from the computer name, your user name, the type of processor and the operating system. Those data and that key never leave your computer.

When the app connects to the internet

The app works offline. It only connects to the internet for the three things below. The first two go to GitHub, where the installation files and the licence status of Anatomino are publicly available; GitHub is a service of GitHub, Inc. in the United States, a subsidiary of Microsoft. The third goes to my licence server.

• Update check. At start-up (can be turned off under Instellingen › Updates en back-ups, that is Settings › Updates and back-ups) and when you click check yourself, the app asks whether there is a new version. An update is only downloaded if you choose to. The Microsoft Store version does not check itself: Windows handles its updates.
• Licence status. At start-up, then every 6 hours, and when you activate a code or click Nu controleren (Check now), the app downloads a public, digitally signed list of revoked licences. With a licence, this has to succeed at least every 90 days (see the licence agreement).
• Activation and devices. A licence works on 2 devices at the same time. When you activate it, view your devices or release one, the app sends your licence code and a device identifier to my licence server; for the online check after that, only the number of your licence and the device identifier. That identifier is a derivative (hash) that differs for each licence and reveals nothing about your computer. The only other thing sent is whether it is Windows or a Mac, so that you can recognise your devices. For each licence, the licence server keeps those identifiers, “Windows” or “Mac”, and the dates of activation, of the last check and of any release. It does not keep any name, email address or IP address.

The app does not send any other data about you: no email address, no name and no results. As with any connection to a server, GitHub and Cloudflare do receive your IP address and technical data about the request, such as the time and the software version. GitHub processes those data itself, as a separate controller, under its privacy statement; I do not see them. The licence server runs as a Cloudflare Worker at Cloudflare, Inc., which delivers and protects the requests as a processor on my behalf, under its privacy policy.

Purpose

keeping the app secure and up to date, switching off revoked licences and letting a licence work on at most 2 devices at the same time

Legal basis

the performance of the licence agreement (Article 6(1)(b) GDPR) for the licence status, the activation and the devices; the legitimate interest, yours and mine, in a secure app (Article 6(1)(f) GDPR) for the update check

Retention

a device until you release it, and at most [to be completed: retention period] after the purchase; a release 30 days. GitHub’s own policy applies to GitHub

If the app opens a web page, such as the download page or the payment page, it does so in your own browser, and that website’s rules apply.

When you buy a licence

Sales go through Paddle (Paddle.com). Paddle acts as reseller and merchant of record: you buy the licence from Paddle, and Paddle handles the payment, the invoice, VAT and any refund. What you enter at Paddle, such as your name, email address, country and payment details, Paddle processes as a separate controller under its privacy statement. I never see your payment details.

After a successful payment, Paddle reports the order to my licence server. The server creates your licence code, tied to the email address of the order, and sends you the code by email. For this I use two processors, which only use the data on my behalf:

• the licence server runs at [to be completed: licence server provider];
• the email with your code is sent via [to be completed: email provider].

I keep the order number, the email address of the order, the number of your licence, and your name if Paddle passes it on. This is done on the licence server and in my licence register, which I keep on my own computer together with the plan, the date of issue, the status and possibly a note, such as the reason for a revocation. The licence server does not keep the licence code itself. If a licence is revoked, only its number appears on the public list of revoked licences, not your name or email address.

Purpose

creating and delivering your licence, sending it again if you lose it, revoking a licence after a refund or in case of abuse, and answering questions about your purchase

Legal basis

the performance of the contract (Article 6(1)(b) GDPR); for the public list of revoked licences also my legitimate interest in preventing abuse (Article 6(1)(f) GDPR)

Retention

[to be completed: retention period] after the purchase; after that, the data are deleted

Recipients

Paddle, the licence server provider and the email provider; nobody else

I do not use these data for advertising or newsletters, and I do not sell or rent them to anyone.

When you email me

If you email me, I use your email address and your message only to reply and to follow up your question.

Legal basis

the performance of the contract if your question is about your purchase (Article 6(1)(b) GDPR); otherwise my legitimate interest in answering questions (Article 6(1)(f) GDPR)

Retention

as long as needed to deal with your question; if it concerns a purchase, at most [to be completed: retention period] after that purchase

This website

This website is hosted by Cloudflare (Cloudflare Pages). On every visit, Cloudflare processes technical data, such as your IP address, the page requested, the time and your browser, to deliver the pages and to protect the website against abuse and attacks. Cloudflare does this as a processor on my behalf; some security data are also processed by Cloudflare for its own purposes, under its privacy policy.

Purpose

delivering and securing the website

Legal basis

my legitimate interest in an accessible and secure website (Article 6(1)(f) GDPR)

Retention

according to Cloudflare’s policy; I do not keep any data about visitors myself

No cookies, no tracking. This website sets no cookies, stores nothing in your browser, loads no files from other websites (the fonts are on this server too) and uses no analytics, advertising or social media services. That is why it does not ask for cookie consent. If you open the home address without a language, the page picks a language based on your browser’s language setting; that is not stored either.

Transfers outside the European Union

GitHub and Cloudflare are American companies; Paddle and the licence server and email providers may also process data outside the European Economic Area. If I myself transfer data to a processor outside the European Economic Area, this only happens to a country for which the European Commission has adopted an adequacy decision (for the United States: to a company that participates in the EU-US Data Privacy Framework), or with the standard contractual clauses of the European Commission. You can ask me for a copy of these safeguards.

What you share directly with Paddle or GitHub yourself falls under their responsibility; their privacy statements explain how they transfer data.

Your rights

You have the right to:

• access your data and get a copy;
• have incorrect data corrected;
• have your data erased;
• have the processing restricted;
• receive your data in a common digital format (portability);
• object to processing based on legitimate interest.

What is on your own computer, you manage yourself: you can clear your history in the app, and remove everything by deleting the Anatomino data folder. For the data I hold, email [to be completed: email address]. I reply within one month. To make sure nobody else requests your data, I may ask you to send the request from the email address of your purchase. For the data held by Paddle or GitHub, please contact them.

If you have your data erased from my records, your licence keeps working: the app checks it without those data. I will, however, no longer be able to resend your code if you lose it.

There is no profiling and no automated decision-making. The app does choose which questions to ask you based on your own results, but that only happens on your computer.

Making a complaint

If you are not happy with how I handle your data, please tell me first; we can usually find a solution together. You also always have the right to lodge a complaint with the Belgian Data Protection Authority:

Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données)
Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels, Belgium
www.dataprotectionauthority.be · [email protected]

If you live or work in another country of the European Union, you can also turn to the supervisory authority there.

Changes

If anything changes in what the app, the sales or this website do, I update this statement and put the new date at the top.