Privacy Notice

Who we are

Fixed Frame Ltd., a company registered in Ireland (company number 820747, registered office 77 Lower Camden Street, Dublin D02 XE80, Ireland), is the data controller for the processing described here, except where this notice says another company is.

Privacy contact: [email protected]. We have not appointed a Data Protection Officer; please send any data-protection question or request to that address.

The short version

Our apps run on your computer. They do not upload your media, projects, files, or anything you record in the built-in time-tracking and billing tools to us; we have no server that receives them. If you choose to send us something, for example when you ask for support, the support section below applies.

We do not collect product-usage analytics. There is no install or launch counting and no telemetry in the apps.

Konformer, the free app, never connects to us. The paid app connects to us only for licensing: when you sign in, when your licence is renewed, once a day while you are online, every 30 minutes while a computer holds a floating Team seat and when an app holding one quits, when you sign a computer out, and when you choose to subscribe or buy a pass in the app. Those connections carry the account and licence details listed below. Apart from them, the apps connect only to applications you send work to, such as DaVinci Resolve, on your own computer or network; those connections do not reach us.

Purchases are made from Paddle, which is the merchant of record: Paddle takes your payment details, not us.

What the apps send us

Konformer, Konformista and Kontroller contain no analytics. They do not count installations or launches, do not report versions or operating systems, and do not upload your projects or media to us.

The paid app connects to our licence service only for these licensing tasks:

• Signing in. You type your email address; we email you a 6-digit code. When you enter it, the app sends your email address, the code, a hashed identifier of your computer, and your computer’s name as your operating system reports it (its network name, for example “Adas-MacBook-Pro.local”). We use the name only so that you can tell your computers apart on your account page.
• Renewal and the daily check. When a computer’s licence runs out, and once a day while it is online, the app sends the computer’s hashed identifier and its sign-in token, and receives the current licence. This is how a renewal, a cancellation, a refund or a failed payment reaches your computer.
• Signing out, subscribing and buying a pass. Signing a computer out, or choosing to subscribe or buy a pass in the app, sends the same two items.
• Team seats. On an account with Team seats, each of these also sends an identifier the running app makes up when it starts (a new one each time it starts, tied to nothing else) and, once you send, export or open Kontroller, which of those it is about to use. While a computer holds a floating Team seat, the app checks in every 30 minutes to keep it, and gives it back when it quits, sending the same items. Keeping a seat on a computer, or giving one back, from the app’s Account menu sends them too.
• Licence keys. If you activate with a licence key instead (beta and some older licences), the app sends the key and the hashed identifier once.

The hashed identifier is a one-way hash of your computer’s hardware identifier, made on your computer; the bare hardware identifier is never sent. The licence the app receives is stored on your computer and names your email address and that hashed identifier. It is checked on your computer without contacting us.

Like any connection over the internet, each of these reveals your computer’s IP address to our service. The service uses it only to reply and to limit repeated requests, and does not store it.

Each app also records, on your computer only, which version of its licence agreement you accepted and when. That record is not sent to us.

Enterprise licences can be activated with an offline licence file, which sends us nothing.

Earlier versions offered an opt-in install and launch signal. No record of it was ever received, and it has been removed from the software.

Your account, purchases and free trial

When our licence service issues a licence, it sends your email address, the computer’s hashed identifier, the products and the end date to our licence-signing server, which signs the licence and returns it. The signing server does not store these details. Its log records the licence number and whether signing worked (for a licence key, the first characters of the key and of the hashed identifier), and those log lines are kept for 7 days in Fly.io’s log search.

Automated decisions. The licence service decides automatically, from your subscription, seats, passes and trial, whether a computer gets a licence. This is necessary to perform our contract with you.

It never refuses a 7-day pass by itself (Terms of Sale section 4). It holds one for a person to decide when, in the last 12 months, a pass bought by your account (or by an account that shares seats with it), or a pass that ran on the computer it would run on (under any account), was refunded or charged back and not won back, leaving out refunds we agreed were for a fault. A held pass does not start. A person at Fixed Frame then looks at that history, including whether each refunded pass was bought with the withdrawal consent, and decides whether the pass starts (it then runs for 7 days from that decision) or is refunded in full. What it means for you: a new pass may wait for that decision, and you can still subscribe.

If you think any decision got something wrong, email [email protected]: a person who can change it will review it, and you can give your view and contest it.

Buying through Paddle

Our order process is conducted by our online reseller Paddle.com. Paddle.com is the Merchant of Record for all our orders made through our website and app. When you subscribe or buy a pass, you give your payment and billing details to Paddle, not to us: Paddle.com Inc. if you buy in the United States, Paddle.com (Canada) Ltd. in Canada, and Paddle.com Market Limited everywhere else, as named at checkout. Paddle uses them to take payment, calculate tax, issue invoices, prevent fraud and handle refunds, as an independent controller under its own privacy notice, which is linked at checkout. We never see your card details.

Paddle tells us the subscription and pass details listed in the table above. When we refuse a pass (Terms of Sale section 4), we ask Paddle to refund it, naming only its Paddle transaction. When you choose to subscribe or buy a pass in the app, our pricing page fills in your account’s email address at checkout so that the purchase reaches your account.

Our website

• Analytics. Most pages of konformista.com load Cloudflare Web Analytics. It counts page views without cookies or other storage on your device; we see only totals, such as visits per page and referring sites. Cloudflare processes your IP address and browser details to produce those totals. Our lawful basis is our legitimate interest in knowing which pages are read.
• Daily totals. Our server keeps daily totals of download clicks (per file), clicks on the Slack invite link, waitlist sign-ups and beta requests. Each is a number per day and nothing else: no IP address, identifier or anything that could tell visitors apart.
• Pricing page. To show prices in your currency, our server looks up your country from your IP address and passes it to the page. We do not store it. The page also loads Paddle’s checkout script from Paddle, which may set its own cookies or use similar storage for checkout and fraud prevention under Paddle’s privacy notice.

• Account page. If you sign in at konformista.com/account, we email a 6-digit code (only to an address that Paddle has told us belongs to a customer) and, once you enter it, set one cookie, described under Cookies below. On that page you can see your subscriptions, passes and computers, see which computers hold Team seats and since when, free a Team seat, sign a computer out, and open Paddle’s billing portal. When every Team seat is in use, the app on another computer of your account shows the same: the names of the computers holding seats and when each took its seat, never an email address.

If you contact support

If you email us, we process the details you send to answer you. Our lawful basis is contract where your message is about your subscription, pass or licence, and otherwise our legitimate interest in answering you. We keep support correspondence for 2 years after your last message. If you ask us to forward a refund request to Paddle, we send Paddle the details needed to identify your order.

If you join the beta programme

If you take part in a Konformista or Konformer beta, we process the email address you sign up with and any feedback, bug reports, diagnostic reports or files you choose to send us, so that we can run the programme, contact you about it, and fix and improve the software. Our lawful basis is our legitimate interest in developing and supporting our products and, where you have a beta agreement with us, the performance of that agreement. Taking part is voluntary and you can leave at any time by emailing [email protected]. We keep your beta request and sign-up details for 2 years after your request, your acceptance of the Beta Test Agreement or the issue of your beta key, whichever is latest; a beta key’s own record is kept as the licence-key row in the table above says, and correspondence as the support section says. Feedback you send may be retained and incorporated into our products as described in the Beta Test Agreement.

If you request a beta invite

If you ask to join the Flame or Baselight beta on our website, we process the name and email address you enter, which system you asked about, the time you asked, the version of the Beta Test Agreement you accepted and when, and the licence key we issue you and when. (Requests made before October 2026 may also hold whether you use macOS or Windows.) We use these details to run the invite process: to reply to you, to correspond with you about your request and setup, and, when a seat opens, to send your invite and issue your beta license, which carries your name. Each request is also delivered to our mailbox so a person sees it. Our lawful basis is that this processing happens at your request, in order to take steps prior to entering into the beta agreement (Article 6(1)(b) GDPR). The requests are stored with Cloudflare, as described below, and are shared with no one else. Each request is deleted 2 years after it was made, the agreement was accepted or the key was issued, whichever is latest. You can withdraw your request sooner by emailing [email protected] and we will delete it; if you join the beta, the beta programme section above applies from then on. Asking for an invite does not put you on the launch waitlist below, and neither list is used for the other’s purpose.

If you join a waitlist

Our website has two waitlists: one to be told when Flame and Baselight leave beta, and one to be told when Kontroller ships as its own app. If you sign up, we process the email address you enter, which list you joined, and when. We use it for that one purpose: to email you when that happens. Our lawful basis is your consent, which you can withdraw at any time by emailing [email protected], and we will delete the address. The lists are stored with Cloudflare, as described below, are shared with no one else, and each address is deleted once its list has served its purpose. The waitlists are separate from the beta requests above; signing up for one never adds you to another.

We are not a processor of your media, or of your time-tracking and billing data

Your media, projects, and edit data stay on your machine and are never transmitted to us or to any processor acting for us. We are not a data processor of your production content, and no data processing agreement is required for it.

The same is true of the time-tracking, billing, and invoicing tools in Kontroller: the sessions you record, the rates you set, and any invoice details you enter, including your own clients’ or contacts’ names, are held only on your device and in the files you export to your own accounting software. They are never sent to us. We are neither controller nor processor of them; where they include personal data of your clients, you remain the controller of that data and decide what to record.

Who processes the data, and who receives it

We do not sell your data. Apart from Paddle, which acts as an independent controller for your purchase as described above, the companies below process it only for us, as our processors, under data processing terms:

• Cloudflare (Cloudflare, Inc.): hosts our website, our account and licence service, and the database that holds accounts, computers, trials, subscription and pass details, beta requests and the waitlist (Cloudflare D1, in Western Europe), and forwards mail sent to [email protected] to our inbox (Cloudflare Email Routing).
• Fly.io (Fly.io, Inc.): hosts our licence-signing server, in its Paris region.
• Resend (Plus Five Five, Inc.): sends the sign-in code emails, so it receives your email address and the code, and sends us the notices of beta requests and of 7-day passes waiting for a check, so it receives the details of each request, and the email address and Paddle transaction of each held pass.

Google hosts our support inbox: mail sent to [email protected] is forwarded to it by Cloudflare Email Routing, so Google holds the messages you send us.

Paddle receives your purchase details as the merchant of record and an independent controller, as described above.

We may also share data with our professional advisers (such as accountants and lawyers, who are bound by confidentiality), and with public authorities, courts or regulators where the law requires it.

International transfers

Cloudflare, Fly.io and Resend are US companies, and may process data outside the EU/EEA even where it is stored in Europe. Where that happens, transfers are covered by the European Commission’s Standard Contractual Clauses in each provider’s data processing terms, or by the EU-US Data Privacy Framework where the provider is certified under it, together with supplementary measures where appropriate. You can ask for a copy of these safeguards at [email protected]. Google, which hosts our support inbox, may also process messages outside the EU/EEA. The Paddle company you buy from (in the United Kingdom, the United States or Canada) handles its own transfers as an independent controller.

Security

We keep what we hold to the minimum the service needs. Your computer’s hardware identifier is hashed on your computer before it is sent. Sign-in codes, sign-in tokens and Subscribe links are stored only as keyed hashes. Connections to our services are encrypted, licences are cryptographically signed, and access to our systems is limited to the people who run them.

How long we keep data

The table above gives the period for each kind of account and licence data. Support, beta and waitlist data are kept as described in their sections. The deletions are made automatically by our services, except for the support inbox and the waitlists, which we clear ourselves. We hold no usage data at all: none is collected, and none ever was.

Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and get a copy;
• have it rectified if it is wrong;
• have it erased;
• restrict how we process it;
• data portability, where processing is based on contract or consent;
• object to processing based on our legitimate interests;
• withdraw consent at any time where we rely on it, without affecting processing before you withdraw; and
• not be subject to a decision based solely on automated processing that significantly affects you, and to ask a person to review the licence service’s decisions.

Your right to object. Some of what we hold is used on the basis of our legitimate interests: the trial record, and, for the 7-day pass rule, your passes’ refund and chargeback history and the records of the computers they ran on. You can object to this at any time by emailing [email protected]. We will then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or need the data to establish, exercise or defend legal claims.

To exercise any right, email [email protected]. We will answer within one month. If a request is complex, or you send several, we may extend that by up to two further months, and we will tell you within the first month if we do.

You also have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie), or with the supervisory authority where you live or work.

Cookies

Our website sets one cookie of its own: when you sign in on the account page, a cookie that keeps you signed in for 24 hours. It holds a signed reference to your Paddle customer record, cannot be read by scripts on the page, and is strictly necessary for the page to work, so it needs no consent. Our own pages store nothing else on your device. Cloudflare Web Analytics uses no cookies. The pricing page loads Paddle’s checkout script, which may use its own cookies, as described under Our website above.

Changes

We will post any changes to this notice at https://konformista.com/privacy and update the date above. Material changes will be noted in the apps’ release notes.