Privacy Notice

1. Controller and contact

The controller responsible for the Paintdeck service under the General Data Protection Regulation is:

Email: mail@paintdeck.net

2. Scope of this notice

This notice covers the Paintdeck marketing website, the Paintdeck application, and the Paintdeck API. It explains what personal data is processed, why it is processed, who receives it, and how long it is retained.

The initial marketing website does not use analytics, advertising, newsletter forms, third-party embeds, or non-essential cookies. It therefore does not display a cookie-consent banner. A technical color-mode preference may be stored on your device so that the site can remember whether you selected light or dark mode.

3. Website, API, and security requests

When your browser or application contacts Paintdeck, the service and its delivery infrastructure process the IP address, request time, requested address, HTTP method and status, user agent, referrer where supplied, and other request or error metadata. This is necessary to deliver the requested content or API response, maintain service security, diagnose failures, and prevent abuse.

The legal basis is Article 6(1)(b) GDPR where the request is needed to provide a feature you requested, and Article 6(1)(f) GDPR for the legitimate interests of operating, securing, and troubleshooting Paintdeck. CDN and platform logs are kept only for the configured operational and security period and are then deleted or anonymized. Paintdeck does not use these logs to build advertising profiles.

4. Accounts and authentication

Email accounts and one-time codes

To create or use an account, Paintdeck processes your email address, a generated or selected username, optional full name, email-verification state and time, role, permissions, internal account identifier, and creation and update timestamps. Providing an email address is required to use account-based features; providing a full name is optional. The legal basis is Article 6(1)(b) GDPR.

For passwordless email authentication, Paintdeck processes the email address, a hashed one-time code, request identifier, attempt count, issue time, expiry time, and consumption time. The code expires after 10 minutes and expired records are removed by periodic cleanup. Scaleway Transactional Email receives the recipient address and authentication-email content to deliver the message.

Passkeys

If you use a passkey, Paintdeck processes the credential identifier, public-key material, signature counter, supported transports, optional device label, last-use time, and creation and update timestamps. Paintdeck does not receive your biometric data or device unlock secret. Passkey challenges expire after five minutes and are removed by periodic cleanup. Your device and operating-system provider may separately process data needed to create, store, synchronize, and use a passkey under their own terms.

Sessions and token storage

Access tokens identify an authenticated account and expire after 15 minutes. Refresh tokens expire after 30 days, are rotated during use, and are stored by the API only as cryptographic hashes together with their family, status, expiry, usage timestamps, and optional device label. Expired server records are removed periodically. On the web, the current refresh token is stored in local storage; in the iOS application it is stored using secure device storage. Logging out removes the device-side token and revokes the applicable server-side token family.

5. Paint collection and feedback features

Paint inventory and wishlist

Paintdeck stores the paint variants associated with your account, owned quantities, wishlist selections, and related timestamps so that it can provide your collection. This data is supplied when you choose to use these features and is processed under Article 6(1)(b) GDPR.

Feedback

If you submit feedback, Paintdeck processes your account identifier and username, the feedback title, description, category, status, administrative replies, and creation and update timestamps. Submission is optional. Processing is based on Article 6(1)(b) GDPR to provide the requested feedback feature and Article 6(1)(f) GDPR for the legitimate interest of understanding reports, supporting users, and improving Paintdeck.

6. Camera permission and barcode scanning

On supported iOS devices, you can grant camera permission to scan a paint barcode. Apple’s VisionKit processes camera frames on the device. Paintdeck does not upload or store camera images. The application receives the recognized barcode value and format and sends the barcode value to the Paintdeck API to look up a paint or update your collection. Use of the scanner is optional and is based on Article 6(1)(b) GDPR when you request the feature. Camera permission is controlled through the operating system and can be withdrawn in device settings.

7. Recipients and service providers

Personal data is disclosed only where needed to operate Paintdeck, comply with law, or establish legal claims.

• BunnyWay d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia (bunny.net), provides CDN, compute, and database infrastructure. Paintdeck constrains its API compute and primary database resources to Germany. CDN delivery may involve the edge location selected for a request. Bunny.net may process request and security metadata and publishes its current subprocessors and data-processing information.
• Scaleway SAS, 8 rue de la Ville-l’Évêque, 75008 Paris, France, provides Transactional Email in the Paris region (fr-par). It processes authentication-email recipients, message content, and delivery events. Scaleway states that the Transactional Email technical stack is managed and processed within the European Union.
• Apple and operating-system services may process device and account information independently when you obtain the application, manage permissions, use secure device storage, or create and synchronize a passkey. Their processing is governed by the settings and privacy terms of the service you use.
• Public authorities, courts, advisers, or other recipients may receive data where legally required.

8. International transfers

Paintdeck configures its primary API and database processing in Germany and transactional email processing in the European Union. CDN routing and a provider’s support or subprocessor operations can involve processing outside the European Economic Area. Where a transfer to a country without an EU adequacy decision occurs, Paintdeck relies on the transfer safeguards made applicable through the relevant processor agreement, such as the European Commission’s Standard Contractual Clauses, together with supplementary measures where required.

9. Retention and deletion

• Authentication one-time codes expire after 10 minutes and passkey challenges after five minutes.
• Access tokens expire after 15 minutes and refresh tokens after 30 days; expired server records are cleaned up.
• Incomplete, unverified signup records without a credential are removed after the five-minute registration challenge period.
• Account details, credentials, paint collection data, and feedback remain while the account is active because they are needed to provide those features. They are deleted when the account is deleted, except where specific data must be retained for a legal obligation or the establishment, exercise, or defence of legal claims.
• Operational, CDN, email-delivery, and security records are retained according to their configured purpose and are deleted or anonymized when no longer necessary. Failed-delivery addresses may remain on an email blocklist while needed to prevent repeated delivery failures or abuse.
• Rights-request records may be retained as necessary to demonstrate compliance and handle related legal claims.

Paintdeck currently has no self-service account-deletion endpoint. To request deletion of your account and its associated data, email mail@paintdeck.net from your account address. We may need to verify your identity before acting on the request.

10. Your rights

Subject to the conditions in applicable law, you may request:

• access to and a copy of your personal data;
• rectification of inaccurate or incomplete data;
• erasure of your data;
• restriction of processing;
• data portability for processing based on contract or consent and carried out automatically;
• objection to processing based on legitimate interests; and
• withdrawal of consent at any time where processing is based on consent.

To exercise a right, contact mail@paintdeck.net. You also have the right to lodge a complaint with a data-protection supervisory authority. The authority responsible for the controller is the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin, Germany, datenschutz-berlin.de.

11. Automated decision-making

Paintdeck does not use personal data for automated decision-making or profiling that produces legal or similarly significant effects. Technical anti-abuse and email-delivery checks may automatically reject or block a request or message, but they do not make such decisions about you.

12. Changes to this notice

This notice will be reviewed when Paintdeck adds or materially changes features, providers, analytics, advertising, embeds, forms, permissions, or retention behavior. The date at the top identifies the current version.