Privacy

What data this website, the shop, the license server and the software use, why, and for how long.

Last updated: 29 October 2026

In short

No advertising and no tracking cookies.
No analytics script. Our pages keep only a few small notes in your browser, such as your choice of a light or dark look, and none of them is sent to us.
Payments are handled by Sold through Link, LLC, a Stripe company. We never see card details.
The license server stores your license key and the email address of your license only as fingerprints. The exception is a withdrawal sent through our form, which is kept encrypted with the email address you typed.
The software needs an internet connection once to activate and again after you install a newer version, on this computer or on another computer or phone. After that it runs without internet. When the computer is online, the software also checks the license. See In the software.
You can object to processing based on our legitimate interest. See Right to object.

Who is responsible

Controller: Hafner Florian Johann (Irrvogel Interactive)
Email: support@irrvogel.com
Postal address and further details: see the Impressum
Data protection officer: none appointed, because the law does not require one for our processing (Art. 37 GDPR).

Visiting the website

The website irrvogel.com is hosted by Cloudflare. When you open a page, your browser sends technical data such as your IP address. Cloudflare processes it to deliver the page and to protect it from attacks.

Legal basis: legitimate interest in a secure and working website and in knowing how much it is used (Art. 6(1)(f) GDPR, Recital 49 GDPR)
Cloudflare's role: Cloudflare, Inc., USA, processes this data for us as our processor under its data processing addendum, which is part of our agreement with Cloudflare. Cloudflare also uses some of this data for its own purposes, such as protecting its network, as its own controller under its privacy policy.
Retention at Cloudflare: Cloudflare does not publish a fixed period for these logs. It says it keeps personal data only as long as its business purposes require.
Transfer outside the EU: Cloudflare processes this data in data centers in the USA and Europe. Transfers to the USA rely on Cloudflare's certification under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR). If the certification lapses, the EU standard contractual clauses in the addendum apply (Art. 46 GDPR).

For each page you open, a small program that runs for us at Cloudflare looks up the country Cloudflare derives from your IP address. If we do not sell to that country, the page shows a one-line note saying so. The country is used only for this note and is not stored, and no cookie is set.

Legal basis: legitimate interest in telling visitors before they try to buy that a purchase from their country is not possible (Art. 6(1)(f) GDPR)

The website runs no analytics script, but as our host Cloudflare keeps aggregated traffic statistics in its dashboard, for example the number of requests and the countries they come from. These statistics contain no profiles of single visitors, and we use them to see how much the website is used.

The website remembers your language choice through the address (pages in German start with /de/). If you pick Light or Dark in the theme menu, your browser keeps that choice in its local storage, so the next page opens in the same look. Picking System deletes it again. On the license pages (license.irrvogel.com) the browser also keeps two notes until you close the tab, namely when a button can be used again after a request to the license server and the last result of the server check. None of this leaves your browser, and our pages set no cookies.

Legal basis: our legitimate interest in showing the pages the way you chose and in holding back repeated requests to the license server (Art. 6(1)(f) GDPR). No consent is needed for this, because you chose the look yourself and the license pages need the two notes for the service you asked for (§ 165 Abs 3 TKG 2021).

Downloads and update checks

Software downloads are offered under downloads.irrvogel.com, which forwards your browser to GitHub (GitHub, Inc., USA). GitHub delivers the file and sees your IP address. The update information the software reads comes from updates.irrvogel.com, which is hosted on GitHub Pages, so GitHub also sees the IP address of that request. GitHub logs and stores the IP address of every visitor of a GitHub Pages site for security purposes.

GitHub processes these requests under the GitHub Privacy Statement. GitHub is certified under the EU-US Data Privacy Framework and otherwise relies on the EU standard contractual clauses.

Legal basis: legitimate interest in delivering downloads and update information reliably and at low cost (Art. 6(1)(f) GDPR)

Buying

You buy from us. Your purchase contract, including the license, is with us. Checkout and payment are handled for us by Sold through Link, LLC, a Stripe company based in the USA, as merchant of record. Link collects the price on our behalf and sends you the receipt and the invoice in its own name. Link processes your payment data as its own controller under its own privacy policy, and Stripe handles requests to delete payment data that it holds. You find the privacy policies at link.com/privacy for Link and stripe.com/privacy for Stripe.

Link uses Stripe's systems: the payment page, the order records and refunds run at Stripe, and our license server exchanges order data with Stripe. Where this policy names Stripe, it means these systems.

Data we receive from Link

We do not collect this data from you directly and receive it from Sold through Link, LLC (Stripe) after your purchase. Under Link's terms Link may share the following order data with us.

Contact data (name, email address, phone number)
Billing address
Payment information
Tax identification number, if you gave one
Order details (product, price, date, country, order reference)

From your order our license server reads only your email address, your billing country, the order number, the amount and currency, the time of payment, and the details our page handed Stripe (see below), and for the country check it also asks Stripe which country issued your card. It uses this data to create your license and send your license key, and it stores only a fingerprint of your email address, the product, the order number, the date, the language of your key email (English or German), the time you ticked the three checkboxes before paying, the version of their wording and the version of the terms of sale, and for a refused purchase the country code. The amount and currency are used for your key email and to see whether a refund can be made automatically. If we have to refund an order by hand, the amount is also in the note we send ourselves about it. Apart from a key email waiting in the outbox, the server saves neither the amount nor the currency. The order and payout records that tax law requires (order number, date, amount, VAT and fees) stay in our Stripe account for 7 years. Our bookkeeping holds only totals, fees, VAT and the payouts to our bank account. In the Stripe dashboard we can also see the order as Stripe keeps it, including the name, email address and billing country you entered at checkout.

When you continue to payment, our license server opens the payment page at Stripe for you. It hands Stripe the product, the language of our page, the email address you typed on our page (so that the payment page is prefilled), the time you confirmed the three boxes, the version of their wording, the version of the terms of sale and the country of your IP address (only the country code). Stripe keeps these details with your order, and they come back to us after the payment for your key email.

To buy, you need to give an email address, because without it we cannot send your license key.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and the legal duty to keep tax records (Art. 6(1)(c) GDPR, § 132 BAO)

Check of the customer's country

Purchases from the USA are not possible, nor from countries where our payment provider cannot handle the tax for us. Purchases from the EU and the EEA are always possible. To enforce this:

When you press "Continue to payment", our license server looks up the country of your IP address in a database file on the same server (IP to Country Lite by DB-IP). Nobody else is asked, your IP address is not stored and only the country code goes with your order to Stripe, as a record that the check was made.
After the payment, the billing country you entered and the country that issued your card (which Stripe tells us) are checked. If they rule the purchase out, it is refunded at once, no license key is created and you get a short email saying why. With the refund we give Stripe a short reason code saying that we do not sell to that country. We keep the order reference, the country code and the date as a record of the check.

This step runs without a person, but you can ask a person to review it by replying to the email or by writing to support@irrvogel.com. You can explain your view and contest the result, and a person then checks the order and the result of the check and answers you by email. If the check was wrong, we tell you and you can buy again.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in not selling to the USA, and only to countries where the tax is handled for us (Art. 6(1)(f) GDPR). If the step counts as an automated decision, it is necessary for the contract (Art. 22(2)(a) GDPR) and the review by a person covers Art. 22(3) GDPR.

Check of earlier refunds

Every refund costs us fees that the payment provider does not return. Our license server checks whether two or more orders with the same email address were refunded or charged back in the last 12 months, counting only the refunds described below. This stops the same purchase being made and refunded again and again.

When you press "Continue to payment", our license server compares the fingerprint of the email address you typed on our page with the fingerprints of the orders it already holds. The email address itself is neither stored for this nor written to any log, and we do not check or record anything about your card for this.
An order counts in two cases. In the first, it was refunded in full, by us or by Link, after we sent the key email and within 14 days after it, and that email quoted the three boxes you ticked before paying. In the second, the bank opened a chargeback on it. A chargeback counts from the day the bank opens it until it is decided in our favor. We do not count a refund that we record as a withdrawal, a refund for a defect or because the software was not delivered, or a refund because of an error by us or by Link. We also do not count a refund more than 14 days after the key email, such as a later refund by Link, a refund of an order bought under version 1 of the terms of sale, a question from your bank that is not a chargeback, or a refund after the country check.
If two or more orders with the same email address count within the last 12 months, your order is not accepted automatically. The page asks you to write to support@irrvogel.com. At the same time the license server sends us one email with the license numbers of the counted refunds, at most once per email address in 24 hours. This notice holds no email address. A person looks at these refunds and lifts the refusal if one of them was for a defect, because the software was not delivered or because of an error.

The server refuses an order without a person. When you write to us, a person decides about your order. You can explain your view and contest the result, and we then check the refunds and answer you by email. If the check was wrong, we tell you and you can buy.

We store no new data for this check. We use what the license server already holds: the refund records, including our note that a refund does not count, the email fingerprints, the record of your three boxes, the delivery of your key email and the version of the terms of sale you bought under. We keep this data for the periods stated under "How long data is kept".

Legal basis: our legitimate interest in limiting the fees we lose through repeated refunds and in preventing misuse of refunds (Art. 6(1)(f) GDPR). If the step counts as an automated decision, it is necessary for entering into the contract (Art. 22(2)(a) GDPR), and the review by a person is the safeguard of Art. 22(3) GDPR.

Licenses

Stored license data

The license server runs at license.irrvogel.com on a rented server of netcup GmbH, Karlsruhe, Germany, in its data center in Nuremberg, Germany. To issue and check licenses it stores the following.

Your license key, only as a fingerprint (SHA-256), never the key itself.
Your email address, only as a keyed fingerprint (HMAC-SHA256). When you ask for a login link or a new key, the address you type is compared with this fingerprint. We cannot read your address from it, and we cannot send you your old key again. Before the fingerprint is made, the address is put into a standard Unicode form (NFKC) and lower case.
The product, the order number and the date the license was created.
The language for emails about this license (English or German). It is the language of your key email, so that later emails such as a replacement key or a transfer notice come in the same language.
The time you ticked the three checkboxes before paying, the version of their wording, whether and when the email with your license key was delivered and whether it quoted the three boxes, and the version of the terms of sale that applied to your purchase. We need these to check a withdrawal (see "Withdrawal form") and earlier refunds (see "Check of earlier refunds").
For each activated computer, a machine ID, the operating system (Windows, Linux or macOS, or "offline" for an offline activation), the computer name (online activations only, which is the name the software shows you in its license window and which you can change before you activate, or none if you clear it), the activation date and the date of the last check. When a computer is deactivated or removed, its entry stays with the date and the way it was removed (deactivated in the software, removed on the license page, removed as not yours (“That wasn't me”), or reset by support).
The machine ID is a shortened fingerprint (SHA-256) of an identifier of your operating system, made with a fixed prefix. The identifier itself never leaves your computer, and the same computer has the same machine ID in every Irrvogel Interactive product. If your system gives no such identifier, the fingerprint is made from your user name and computer name instead.
Remote removals and email address changes with their date, to count their limits (twice in any 30 days for remote removals, once in 12 months for email address changes) and, like removed computers, to detect misuse (see below), plus the date of the last key replacement.
If a license is blocked, the block reason (withdrawn, refunded or misuse) and the date of the block. For a refund, a chargeback or a question from the bank, also the order number and the date.

We keep the checkbox record and the delivery of the key email to check a withdrawal, on the bases given under "Withdrawal form" and "Declarations about the immediate delivery". For misuse and blocks, see "Misuse detection".

Legal basis: performance of the contract (Art. 6(1)(b) GDPR)

The login link we email you contains your email address, encrypted so that only our license server can read it. The license management page uses it to show you which address you are signed in with, hidden until you choose to show it, and the address is not stored on the server.

When you remove a computer with “That wasn't me”, we receive an email with the license number, the internal number and name of that computer and the time, so that we can check the license for misuse.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) for showing your address, and our legitimate interest in protecting licenses against misuse (Art. 6(1)(f) GDPR) for the email to us.

Outbox and deletion record

Key emails, withdrawal confirmations, links to confirm a withdrawal, answers to a withdrawal, transfer notices, our copy of a withdrawal and refund notices that cannot be delivered right away are kept encrypted for at most 7 days, then deleted. A key email waiting in the outbox also contains the price you paid and, if you paid in another currency, the amount in that currency.

After a request to delete your data, the license server keeps a record of the request for 60 days, which holds the fingerprint of your email address, the order numbers you named and the date. If a backup has to be restored, the deletion is carried out again from this record.

Legal basis: for an email that waits to be sent, the same basis as for the email itself (see "Emails" and "Withdrawal form"). For the record of a deletion request, our legal duty to delete your data (Art. 6(1)(c) GDPR with Art. 17 GDPR).

Counting requests per IP address

To slow down abuse, the license server counts requests per IP address (for IPv6, per /64 and per /48 network block). It keeps the addresses in memory only, never writes them to disk and forgets an address after 10 minutes without requests. The server accepts only a few requests an hour for the checkout, the support form and the withdrawal form. For these three forms it keeps an address for up to 2 hours after its last request instead.

Legal basis: our legitimate interest in protecting the license server from misuse (Art. 6(1)(f) GDPR)

Counting requests in the wrong format

To fend off attacks, the license server also counts requests in the wrong format for each IP address (for IPv6, for each /64 network block). This happens in memory only, and neither the IP address nor anything made from it is written to disk or to a log. Instead of the address the server keeps a fingerprint (a keyed hash) made with a random key that exists only in the server's memory and changes at every restart. We do not use the fingerprint to find out the address, but it still counts as personal data. If many such requests come from one address within 10 minutes, the license server refuses requests from that address for 15 minutes, and for 1 hour if this happens again within 24 hours. A block can also affect other people who share the same address, for example in a company network. The fingerprint is kept for about 10 minutes, or up to 24 hours after a block began, and a restart of the server deletes it.

Legal basis: our legitimate interest in protecting the license server from misuse (Art. 6(1)(f) GDPR)

Limiting emails per address

So that nobody can use the license server to flood an inbox, it limits how many emails it sends to one address in a short time. This covers login links, replacement keys and the messages about a change of email address. For this the server keeps, in memory only, the fingerprint of the email address and the times of the emails it sent. A separate limit applies to the notice we send ourselves when the check of earlier refunds refuses an order: we send at most one per email address in 24 hours. The server forgets the fingerprint after about a day, and a restart of the server deletes it.

Legal basis: our legitimate interest in protecting the owners of email addresses from unwanted emails and our email sending from misuse (Art. 6(1)(f) GDPR)

Bot check

Before the license server sends a login link, a confirmation to a new email address or a message from the support form, your browser solves a small computing task set by the license server (ALTCHA, loaded from our own server). The task contains nothing about you, nothing is sent to anyone else and nothing is stored in your browser. The license server keeps a solved task in memory for at most 10 minutes, so that it cannot be used twice.

Legal basis: our legitimate interest in protecting the login and our email sending from automated misuse (Art. 6(1)(f) GDPR). No consent is needed for this check, because it only protects the login or the message you asked for (§ 165 Abs 3 TKG 2021).

Server logs

The license server and the web server in front of it write log lines.

The license server writes one line each time one of the following happens.

An activation
A license check
A deactivation
A remote removal
A computer removed with “That wasn't me”
A reset
A transfer
A key replacement
A block or unblock
Our mark that a refund does not count when we check earlier refunds
The start of a checkout
A refund after the country check
A withdrawal
A withdrawal that was not confirmed in time
A message from the support form
A request refused by the bot check
A cancelled change of email address
A deletion of data on request
An action on the administration page

Each line says what happened and the result. Where they exist, the line also holds the license number and an internal number for the computer. After the country check it also holds the country code. A line for a support form message holds only the kind (problem, idea or question) and the result. A line for a request refused by the bot check holds only the reason.

The logs also hold the following.

When a payment arrives or is refunded, the license server writes one line. It holds the number and type of the Stripe event, the order number and what the server did (licenses created, refunded or blocked).
The separate signing service on the same server writes one such line for each signature it makes, with what was signed, the license number and the result.
Once a day the license server writes one line with how many records the automatic deletion removed (numbers only).
For each request, the web server in front of the license server logs the time, the type of request, the host name, the address called (including anything after a question mark) and the result. It also logs the size and duration of the answer and technical details of the encrypted connection. It logs none of the headers your browser sends along.

Lines written during a web request carry a random ID of that request, and lines about an order or a withdrawal also name that order or withdrawal (the order and checkout numbers at the payment provider, the withdrawal number), so that the steps of one order can be found together. No log line holds an IP address, license key, email address or machine ID, unless someone types one into the address of a request. They are kept for at most 30 days and are not copied into backups.

Legal basis: our legitimate interest in running the license server securely, finding faults and tracing the steps of an order (Art. 6(1)(f) GDPR)

Switch-on file

When we publish the switch-on file described in the license terms of each product (section 1) and in the supporter key terms, it contains a one-way fingerprint of each valid license key. A fingerprint cannot be turned back into the key, and it contains no name, email address or license number. Until then these fingerprints are kept on the license server and, ready for publication, in a private repository of ours at GitHub (GitHub, Inc., USA, under the EU-US Data Privacy Framework and otherwise the EU standard contractual clauses).

Legal basis: performance of the contract (Art. 6(1)(b) GDPR), because the switch-on file is part of the promise in the license terms and the supporter key terms.

Misuse detection

Activation data is also used to detect misuse of a license key. Misuse means one of the grounds in section 12 of the terms of sale, for example a key that is published or used on more computers than allowed. For this we look at how many computers were activated with a key in the last 12 months, and at license keys we find published online.

Before we block a key for misuse, we warn you by email (section 12 of the terms of sale). As evidence we keep where and when the key was found, the activation counts, our warning and your answer. We keep the full evidence of misuse only while a dispute about it is likely, for example while you contest a block. After that we keep only the block record, which holds the license number, the block reason, the date and the computers of the license, so that they still receive the block. We keep it for 3 years after the block, and if we do not block the key, we delete the evidence when the case is closed.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) for counting the computers activated with your key and enforcing the limit of two computers, because both are part of your contract. Detecting misuse and keeping evidence and block records rely on our legitimate interest in protecting our licenses and preventing fraud (Art. 6(1)(f) GDPR, Recital 47 GDPR). You can object to that part, see Right to object.

We think this is fair to you because a license key is easy to copy, and without these checks one key could activate the software on any number of computers. We use as little data as we can for this, namely fingerprints instead of your key and your email address, a shortened fingerprint as machine ID instead of details of your hardware, only the activations of the last 12 months, and a warning by email before any block. That a license server checks where a key is used is part of buying a license key, and the limit of two computers is in the terms you accept before paying.

Transfer of a license

If a license is transferred to you at the request of its previous owner, we receive your email address from that person. We store it only as a fingerprint, as described above, and tell you about the transfer in a short email right away.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR), because the license terms allow the transfer and the license is then yours.

Emails

Key emails, replacement keys, login links for the license management page, confirmations of an email address change, the notice about a change of email address with a link to cancel it, links to confirm a withdrawal, confirmations of a withdrawal and notices about a refund after the country check are sent through Scaleway Transactional Email (Scaleway SAS, France). The same service sends us our copy of a withdrawal, a notice when a computer is removed with “That wasn't me” or an email change is cancelled, messages from the support form, a short notice with the license number and order number when a key email went out without some order details, and a short notice with the license numbers of the counted refunds when the check of earlier refunds refuses an order.

Scaleway processes these emails for us as our processor under its data processing agreement, which is part of every Scaleway contract. Scaleway says that Transactional Email data is hosted and processed only in the EU and that no personal data leaves the EU. Scaleway deletes the message itself after sending it. For each email Scaleway keeps the recipient address, the sender, the subject and the delivery status, which we see in the Scaleway console, but it does not say how long it keeps these delivery records.

The key email contains your license key, license number, order number, the date of your purchase and the price you paid. If you paid in another currency, it also shows the amount in that currency. The attached PDF repeats the order number and the date. It also contains the record of your three checkboxes, the withdrawal information and the terms that apply to your purchase.

Login links are valid for 15 minutes. The notice about a change of email address contains a link that cancels the change. That link is valid for 7 days.

When you write to support@irrvogel.com, we use your message to answer you. Mail to our addresses is received by Cloudflare Email Routing and forwarded to our mailbox at Google (Gmail). This is a personal Gmail account and not Google Workspace, and Google Ireland Limited keeps the mail in this mailbox under its own privacy policy. Google's data processing terms are for business services such as Google Workspace and Google Cloud, and we have no such contract with Google for this mailbox. Google may also process the mail in the USA, and Google LLC is certified under the EU-US Data Privacy Framework.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and legitimate interest in answering requests (Art. 6(1)(f) GDPR)

Support form

When you send the form on irrvogel.com/support/write, your browser sends what you entered to our license server (license.irrvogel.com), namely what your message is about, your email address, your message and, if the software opened the page, the product and its version number. Before that, the same server gives your browser the bot check described under "Licenses". The server sends your message to us by email through Scaleway Transactional Email and keeps no copy. The email is then received like any email to support@irrvogel.com (see "Emails"). If your message contains a license key, the server removes it before the email is sent to us. Nothing is sent before you press the button, and if the form cannot be sent, the page offers to open an email to support@irrvogel.com with your message instead.

Legal basis: performance of the contract or steps before it (Art. 6(1)(b) GDPR) and our legitimate interest in answering requests and improving our software (Art. 6(1)(f) GDPR)

Withdrawal form

When you use the form on /withdraw, our license server stores your name, the email address you bought with, the license number or order number if you give it, your note if you write one, the date and time, the language of the page and which of your licenses the number matches. The record is encrypted and deleted automatically after 3 years. You get a confirmation with the content of your declaration by email at once, and we get a copy by email to handle your withdrawal.

The license server checks each withdrawal automatically against the license it names. It checks the date of the purchase, whether you ticked the checkboxes on the immediate delivery before paying, and whether the email with your license key was delivered. If the withdrawal is clearly valid, we send a link to the email address the license belongs to. When you open it and confirm, the payment is refunded and the license blocked without further steps, and you get an email saying so. If you do not confirm within 5 days, a person checks your withdrawal and answers you. Your withdrawal is valid from the moment you send it either way, and the link only lets the refund happen at once. If it looks as if your right of withdrawal had already ended, the server does not decide. A person checks your case and sends the answer (Art. 22 GDPR). All other cases are handled by a person. The record also keeps how the withdrawal was assessed and what was done.

If the form cannot reach our license server, or your browser does not run the page's script, the page opens an email to support@irrvogel.com with your entries instead. That withdrawal reaches us as an email (see "Emails").

Legal basis: legal duty to provide the withdrawal function and to confirm receipt (Art. 6(1)(c) GDPR, § 13a FAGG). Checking the withdrawal and refunding: legal duty to refund a valid withdrawal within 14 days (Art. 6(1)(c) GDPR, § 14 FAGG). Keeping the record for 3 years: our legitimate interest in being able to prove when and what you declared (Art. 6(1)(f) GDPR). We keep it for 3 years because claims expire after 3 years (§ 1489 ABGB).

Declarations about the immediate delivery

Before you pay, you tick three boxes, one for the terms and two about the immediate delivery. The record of all three (date and time, version of the wording, language of the page) is stored with your order at Stripe and confirmed in your key email.

Legal basis: our legitimate interest in being able to prove the declarations (Art. 6(1)(f) GDPR)

In the software

What the software sends is described in the notice that is also shown inside the software. The software sends data only to activate, deactivate, silently check a license, check for updates or, when you ask for it, look for the switch-on file, and there is no usage tracking. On activation it sends a one-way fingerprint of the key you entered (not the key itself), a machine ID, the operating system and the computer name. When the computer is online, the software checks the license about once a day, and once an hour while a check does not get through. When you press "Look for the switch-on file online", it downloads the switch-on file from raw.githubusercontent.com (GitHub, Inc., USA) and, if that fails, from irrvogel.com (Cloudflare). It sends no license data, no machine ID and no computer name with these requests, and each host the software asks sees your IP address. On your computer it keeps the license confirmation, the computer name you chose when you activated (with no key and no email address, so that the license window shows the same name as the license management page, and it is deleted with the license confirmation), the time of the last update check and the last update information. It also keeps a one-way fingerprint of the key you entered, so that the software can be activated with your key once the switch-on file is published, and the switch-on file itself once one has been found and checked. After the license server removed that computer or blocked the license, it also keeps the server's signed notice, so it can show the reason after a restart. For support, it also writes a short record of its licensing steps into the file license.log, with the time, the step, how it ended, how long it took and the license number, but never the key. The record uses at most three files of 1 MB each and stays on your computer until you delete it. An icon button on the About page ("Copy diagnostics") puts a short text on your clipboard that you can paste into a message to us. It contains the name and version of the software, the operating system and architecture, the license state with the license number, the last error code, the last problem the software showed and the last 20 lines of this record.

Legal basis: performance of the contract (Art. 6(1)(b) GDPR) for activating, deactivating and checking the license and for the switch-on file. For the update check, see "Downloads and update checks".

If an error in the software's own code stops it, the software writes a short crash report on your computer only. It contains the version, the operating system, the name of the part of the program that stopped (thread), the error message, where in the code it happened and the list of program functions that were running (backtrace). It is built to leave out license keys, email addresses and the text you typed, but an error message can name a file or folder on your computer. The last 5 reports are kept, and the software offers the newest one once on the next start. The folder with the reports also holds a file seen.txt. It contains the name of the newest report that was offered, so that no report is offered twice. Nothing is sent unless you copy it and send it yourself, for example in the support form. Please read a report before you send it. The entry "Send feedback or an idea…" opens irrvogel.com/support/write in your browser with the product id and version number in the address, and nothing else.

Who receives data

Sold through Link, LLC and Stripe, USA (payment, receipts and invoices, as their own controllers under the Link privacy policy and the Stripe privacy policy). We pass your order data to Sold through Link, LLC and Stripe, LLC in the USA, and Link and Stripe use it as their own controllers. The transfer to the USA relies on the certification of Stripe, LLC under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR), and if the certification lapses, the EU standard contractual clauses in Stripe's data transfers addendum apply (Art. 46 GDPR).
Cloudflare, Inc., USA (website hosting, DNS, receiving mail to our addresses and backup storage, as processor under Cloudflare's data processing addendum, with transfers under the EU-US Data Privacy Framework and otherwise the EU standard contractual clauses)
Scaleway SAS, Paris, France (email sending, as processor under Scaleway's data processing agreement, with the data staying in the EU)
netcup GmbH, Karlsruhe, Germany (rented server for the license server in its data center in Nuremberg, Germany, as processor under a data processing agreement under Art. 28 GDPR). For this server netcup uses only companies of its group in Germany and Austria, so the data stays in the EU.
Cloudflare R2 (backup storage for the license database, as processor under the same addendum). The backup files are stored in data centers in the EU, because the bucket uses Cloudflare's EU jurisdiction.
GitHub, Inc., USA (downloads and update information and also the private repository with the fingerprints for the switch-on file, see "Licenses", under the EU-US Data Privacy Framework and otherwise the EU standard contractual clauses)
Google Ireland Limited (support mailbox, personal Gmail account, see "Emails")

Where a transfer to the USA relies on the EU standard contractual clauses, you can ask us for a copy at support@irrvogel.com. The European Commission publishes the clauses in its Implementing Decision (EU) 2021/914.

We do not sell data and do not pass it on for advertising.

How long data is kept

The license server deletes the records below by itself once a day, as soon as their period is over.

Records needed for taxes (order and payout records of the payment provider, bank statements): 7 years from the end of the calendar year (§ 132 BAO), longer while a tax procedure is pending.
License data (order reference, license number, key fingerprint, email fingerprint, mail language): as long as the license exists.
Fingerprints for the switch-on file: on the license server as long as the license is valid, and the private repository at GitHub holds the latest daily list. A published switch-on file stays public.
Activated computers: as long as they are activated.
Removed computers (deactivated, removed on the license page, also as not yours, or removed by support): 12 months after the removal.
Remote removals and email address changes: 12 months after the event.
Blocked licenses, with their computers, the block reason and the date: 3 years after the block.
Notes on refunds, chargebacks and questions from the bank (order number and date): 3 years after the date of the note.
Full evidence of misuse (where and when the key was found, activation counts, our warning and your answer): only while a dispute about it is likely, for example while a block is contested, and then only the block record, 3 years after the block. Without a block, until the case is closed.
Withdrawals: 3 years after receipt.
Declarations about the immediate delivery: with the order at Stripe, as long as the order records are kept (7 years for tax).
Countries of refused purchases (order reference, country code, date): 3 years after the refusal.
Deletion notes after a request to delete your data (order reference and date only): 90 days, so that the license is not created again by mistake. If the license was blocked, its license number with the block and its reason stays until the 3 years of the block are over.
Record of a request to delete your data (fingerprint of the email address, order numbers, date): 60 days.
Support emails (also messages from the support form): up to 3 years after the case is closed. After we delete a mail, Google may need some time to remove it from its backups.
Delivery records at Scaleway (recipient, sender, subject, status): see "Emails".
Emails that could not be delivered right away (key emails, withdrawal confirmations, links to confirm a withdrawal, answers to a withdrawal, transfer notices, refund notices): at most 7 days.
Request counts of the license server (IP addresses, and for requests in the wrong format fingerprints of IP addresses): in memory only, about 10 minutes, and up to 24 hours after a block. For the checkout, the support form and the withdrawal form it is up to 2 hours. A restart deletes them.
Fingerprints of email addresses with the send times of emails, used to limit emails per address: in memory only, about 1 day. A restart deletes them.
Server logs: at most 30 days.
Backups: each backup file is deleted 29 days after it was made, so deleted data can remain in backups for up to 30 days. Until then this data is not used, and if a backup is restored, the deletions are applied again (§ 4 Abs 2 DSG).

Your rights

You can ask for access to your data, correction, deletion, restriction of processing and data portability. Write to support@irrvogel.com and we answer within one month. In complex cases we can extend this by two more months and tell you why (Art. 12(3) GDPR).

If you ask us to delete your data, the license server deletes your licenses with the fingerprints of your key and your email address, every computer with its name and machine ID, the events, and emails to you that are still waiting to be sent. Computers on which the software is already activated keep working, because the license confirmation is stored on the computer itself. The key can then no longer be activated, the license management page no longer shows the license, and versions released after a computer's last license check are not activated on that computer. Before we delete a license, we tell you this by email and ask you to confirm. We keep the order reference and the date as a deletion note for 90 days, so that the license is not created again by mistake. Withdrawals, refund and block notes and records of refused purchases are kept until their 3 years are over, as proof in case of a dispute (Art. 17(3)(e) GDPR). If the license was blocked, its license number stays with the block and its reason for that time, so that its computers still receive the block. Records needed for taxes stay with the payment provider for 7 years (§ 132 BAO). Server logs end after 30 days and backups after at most 30 days, and if a backup is restored, the deletion is carried out again.

You can complain to the Austrian data protection authority.

Österreichische Datenschutzbehörde, Barichgasse 40-42, 1030 Wien, Austria
Email: dsb@dsb.gv.at
Website: https://www.dsb.gv.at

Right to object

You can object at any time. Where we process your data based on our legitimate interest (Art. 6(1)(f) GDPR), you can object to this processing for reasons arising from your particular situation (Art. 21(1) GDPR). This covers every processing marked "legitimate interest" above, for example the website logs and the server logs, the country note, downloads and update checks, the check of the customer's country, the check of earlier refunds, the bot check, the counting of requests per IP address, the limit on emails per address, support emails, misuse detection, the records of blocks and the 3-year record of a withdrawal. Write to support@irrvogel.com and we then stop the processing unless we can show compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims.