EF-PUMP Professional V1

EF-PUMP Professional V1

Privacy and Local Data Handling Notice

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 efpumpsupport@gmail.com, 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 may process correspondence and related technical data under its applicable privacy terms. Information about Google's processing locations and international-transfer arrangements is available in Google's published privacy documentation.

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 personal information for the purposes and on the legal bases described below.

• 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: The licensor uses an ordinary Gmail account for customer support, commercial correspondence and privacy requests. Google provides the email service under its applicable terms and privacy documentation. No Google Workspace-specific contractual arrangements are claimed for this account.

Paddle: For purchases processed through Paddle, Paddle acts as authorized reseller and Merchant of Record. Purchase-related information may be exchanged with the licensor where needed for order identification, licensing, fulfillment, customer support, accounting and applicable legal obligations. Paddle provides its own buyer-facing privacy information.

Render and international transfers: Render provides infrastructure for the separate public demonstration backend. Render publishes data-protection documentation describing processing arrangements and international-transfer mechanisms. Selection of an EU hosting region does not establish that all related processing occurs exclusively within the EEA.

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.

Hosting infrastructure may retain operational logs and technical connection information according to the applicable provider configuration and practices. The public demonstration is separate from the normal local analytical workflow of the Windows application.

These providers publish information concerning international processing and transfer safeguards. Individuals may request further information about relevant processing and safeguards through the published privacy contact.

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 apply to the licensor's records, subject to applicable legal requirements and justified exceptions.

• 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. Infrastructure logs may be processed and retained under the hosting provider's applicable configuration and retention practices.

Retention periods and review procedures depend on the record category, processing purpose and applicable legal obligations. A twelve-month support review is not a promise of automatic deletion after twelve months.

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 and privacy contact

Data controller: [FINAL SELLER / LICENSOR LEGAL NAME]

Privacy contact: [FINAL PRIVACY CONTACT EMAIL]

Privacy enquiries and requests to exercise applicable data-protection rights may be directed to the privacy contact identified in this notice.

11. 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 efpumpsupport@gmail.com, using Google Gmail.

The licensed desktop application's normal analytical workflow is local. Purchase fulfillment, support correspondence and the separate public demonstration involve the processing activities described in this notice.