EF-PUMP Professional V1

EF-PUMP Professional V1

Privacy and Local Data Handling Notice

Status: DRAFT — FINAL CONTROLLER IDENTITY REQUIRED

Data controller: [FINAL SELLER / LICENSOR LEGAL NAME]

Privacy contact: [FINAL PRIVACY CONTACT EMAIL]

1. Local engineering data

EF-PUMP Professional V1 is designed as a local Windows application.

Normal analytical execution processes pump operating data locally on the customer's computer.

The verified V1 analytical workflow does not require:

• uploading pump operating datasets to an EF-PUMP cloud service;
• continuous Internet connectivity;
• an online analytical account;
• or telemetry as a condition of analytical execution.

The customer remains responsible for the data entered into or imported into the application.

2. License activation information

To issue an EF-PUMP Professional entitlement, the customer may provide the seller with an EF-PUMP Installation ID.

The Installation ID is used to issue authorization evidence for the applicable installation.

The customer may also provide information reasonably necessary to identify the corresponding purchase or licensed user.

3. Purchase information

Where a purchase is processed through Paddle, Paddle processes the checkout transaction under its own applicable terms and privacy notices.

The EF-PUMP seller may receive information from Paddle that is reasonably necessary for:

• order identification;
• product fulfillment;
• license issuance;
• customer support;
• accounting;
• fraud or abuse prevention;
• and legal recordkeeping.

Payment-card details are not required to be collected directly by the EF-PUMP desktop application.

4. Support communications

The dedicated EF-PUMP Professional support and privacy contact is [email protected], operated under the commercial identity Tembris Forge.

Google Gmail is used to receive and send customer support, commercial contact, and privacy-rights correspondence.

Support correspondence may contain the sender's name, email address, message content, purchase or installation references, and attachments voluntarily provided by the sender.

Such information is used to answer requests, investigate installation or activation problems, investigate reported defects, and maintain appropriate support records.

Customers should not submit confidential pump operating datasets, credentials, payment-card details, or other sensitive information unless specifically necessary and appropriately agreed for a support purpose.

Google's applicable processing terms, service arrangements, processing locations, and international-transfer safeguards require final verification before this notice is approved for publication.

5. Engineering datasets

EF-PUMP does not require the customer to send engineering datasets to the seller merely to perform normal licensed analysis.

If a customer voluntarily provides engineering data during support, that data shall be handled only for the stated support purpose unless another lawful basis and purpose are clearly established.

6. Purposes and lawful bases

The licensor processes the minimum personal information actually needed for the following activities, subject to verification of the real operational workflow before commercial publication:

• Order identification, license fulfillment and installation authorization: performance of the applicable license or pre-contractual steps requested by the customer, where Article 6(1)(b) GDPR applies.
• Customer support and defect handling: performance of contractual support obligations where applicable; other support requests require an independently established lawful basis.
• Accounting and legally required records: compliance with applicable legal obligations under Article 6(1)(c) GDPR.
• Security, misuse prevention and dispute evidence: legitimate interests under Article 6(1)(f) GDPR only after an actual necessity and balancing assessment; this is not a blanket authorization for unrelated monitoring.

Consent is requested separately where a processing activity legally requires it. No marketing consent or marketing activity is implied by purchase.

7. Recipients and international transfers

Google Gmail: Google provides the ordinary Gmail email service used for EF-PUMP Professional support, commercial correspondence and privacy requests. Google publishes privacy terms and international-transfer information for its services. Google Workspace-specific contractual arrangements are not assumed to apply to this ordinary Gmail account. The precise account-specific terms and processing arrangements remain subject to final confirmation.

Paddle: For Paddle-processed purchases, Paddle acts as authorized reseller and Merchant of Record. Paddle's published reseller data-sharing arrangements describe Paddle and the supplier as independent controllers for the relevant shared data. The EF-PUMP licensor separately administers software licensing, authorization, fulfillment and applicable customer support. Transaction information may be received where necessary for those purposes; the actual categories exchanged will be confirmed during commercial onboarding.

Render contractual processing and international transfers: Render's published Data Processing Addendum, modified December 19, 2024, describes Render as a processor for customer personal data covered by that agreement, subject to its stated scope and exceptions. Section 6.1 identifies the United States as the location of Render's primary processing operations and states that transfers to the United States are necessary for providing the services. Section 6.2 describes applicable transfer mechanisms, including the EU-US Data Privacy Framework or Standard Contractual Clauses, as applicable. Section 4 addresses subprocessors. Render separately acts as an independent controller for certain account and usage information under Section 9. Selection of the Frankfurt service region does not establish exclusively European processing. The applicable contractual scope, actual data flows, and safeguards remain subject to final operational verification.

Render: Render hosts the public EF-PUMP demonstration backend. The deployed service region was confirmed in the Render dashboard as Frankfurt (EU) on 2026-10-27. Demonstration requests are separate from the normal local analytical workflow of the licensed Windows application. Inspection of the demonstration request handlers identified no application-level persistence in those handlers.

Render infrastructure may process technical connection information and operational logs. Render publishes subprocessor and data-protection information. Frankfurt deployment does not establish that all infrastructure processing, support access or subprocessors remain within the European Economic Area.

The Render workspace was confirmed as Hobby on 2026-10-27. Render documents a seven-day workspace log-retention window for that plan. Dashboard inspection showed deployment and Gunicorn operational events; no individual HTTP request records were identified in the inspected screenshots. This does not establish that Render retains no other infrastructure connection data.

Google, Paddle and Render publish information about international-transfer arrangements and safeguards. Applicable mechanisms, account-specific contractual terms and access to information about relevant safeguards must be confirmed before final publication. No claim is made that all provider processing occurs exclusively within the European Economic Area.

8. Retention

Personal information shall be retained only for the purposes for which it is processed and for applicable legal obligations.

The following retention criteria are supported by an internal manual review procedure and a private review register established during Task 19 preparation. Their operation remains subject to ongoing compliance, and provider-specific retention arrangements must be verified before commercial publication:

• Support correspondence: retain while the support case remains active. Ordinary support correspondence will be reviewed 12 months after case closure. Messages and attachments no longer necessary for support, legal compliance, contractual obligations, security, or dispute resolution will be deleted. Information requiring continued retention will be kept only for the justified period and reviewed accordingly.
• Purchase and accounting records: retain for the applicable statutory accounting, tax, and other legally required periods, determined by record category and applicable Spanish law.
• Installation and entitlement records: retain while needed to administer the purchased license, verify fulfillment, provide legitimate reactivation support, or establish relevant transaction history, subject to appropriate minimization and applicable legal requirements.
• Security and dispute records: retain only for a justified documented period linked to the relevant security incident, potential claim, or applicable limitation period.
• Public demonstration requests and technical logs: the inspected demonstration request handlers do not show application-level persistence. Any infrastructure logging and retention by Render or other hosting components must be verified separately.

A final retention schedule must identify sufficiently precise periods or criteria, operational deletion/review practices, and exceptions for legally required preservation. No indefinite retention or automatic immediate deletion is promised.

9. Individual rights and complaints

Subject to applicable conditions, individuals may request access, rectification, erasure, restriction, portability and objection. Where consent is the lawful basis, it may be withdrawn without affecting prior lawful processing. Requests may be sent to [FINAL PRIVACY CONTACT EMAIL]. Individuals may lodge a complaint with the Spanish Data Protection Agency (AEPD) or another competent supervisory authority.

10. Controller identity and final operational verification

Data controller: [FINAL SELLER / LICENSOR LEGAL NAME]

Privacy contact: [FINAL PRIVACY CONTACT EMAIL]

Before commercial publication, verify and publish the controller's required contact information, the real categories of personal data, legal bases, recipients, retention criteria, transfer safeguards where relevant, and an effective rights-request route. This draft must not be represented as a completed Article 13 GDPR notice until those facts are established.

11. Verified technical data-handling architecture

The EF-PUMP Professional V1 application generates a local installation identifier in UUID version 4 format. The identifier supports installation-bound license authorization and entitlement verification.

The application stores installation identity and entitlement artifacts locally. Normal engineering analysis does not require uploading customer pump datasets to an EF-PUMP-operated cloud service.

Commercial fulfillment software includes a SQLite purchase ledger that can associate a verified transaction identifier with an installation identifier, entitlement artifact, and fulfillment state. These records are separate from customer engineering datasets.

The commercial architecture includes authenticated Paddle purchase intake. Paddle acts as the authorized reseller and Merchant of Record for Paddle-processed transactions; the EF-PUMP licensor separately administers software authorization and fulfillment.

The public Render demonstration uses a separate Flask/Gunicorn application entry point. The inspected request handlers process demonstration scenario identifiers and permitted edits. This does not establish the absence of infrastructure access logs or other hosting-provider processing.

The dedicated commercial and privacy correspondence address is [email protected], using Google Gmail.

The actual deployment, operational access controls, provider arrangements, processing locations, retention schedule, and international-transfer safeguards remain subject to final verification before publication.

Commercial-release status: DRAFT — FINAL SELLER / CONTROLLER IDENTITY REQUIRED