Personal data processing policy

The operator of personal data is Valeria Maksimovna Romodina, taxpayer number (INN) 591608924841, a payer of the professional income tax; email ask@zerno.photo, website zerno.photo. The policy is published pursuant to part 2 of article 18.1 of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and applies to the data of buyers of licences for the Zerno program, users of the program, members of the waiting list and persons who contacted support. The licence conditions are in the licence agreement.

What data and why

Only what is needed to issue, renew and service a licence:

Name and email

to issue the licence, send the activation code and the receipt, and reply to support requests. They are given at payment, in an email or — optionally — in the trial window, where consent is also given to a reminder about the end of the trial and to news emails

This Mac's code

an irreversible digest (SHA-256) of the device's hardware identifier. The identifier itself or any information about the device cannot be recovered from it; it is needed to count the seats in use and to renew the licence file

Contact dates

when the program last renewed the licence file, checked for updates and asked for permission to launch in the trial — to free the seats of Macs that have gone out of use, and to count the days of the trial

Usage counters

three cumulative numbers — how many times the program was launched, how many frames it exported and how many minutes it was the active window — plus the program version, the platform (macOS or Windows) and the operating system version (without the patch number). They are sent together with the renewal of the licence file. Numbers only: no file names, chosen films, settings or content. They are needed to understand whether the program is used and on which systems to support it; the export counts of all users are summed into the public counter on the website

Payment details

the amount, the date and the payment service's transaction number — for the receipt and the books. Card details are not passed to the operator

Waiting list

the name and email left in the form on the Website, to announce the release of a version of the program for another platform. Kept until that announcement or until you opt out via the link in the email

What is not collected

The content of photographs, their metadata, the processing settings and the export results are never sent to the server. All processing is done on the user's computer. The program contains no advertising or analytics modules, collects no information about the hardware beyond the computer's code, the platform and the operating system version, and does not track the user's actions.

The Website uses no visitor counters and makes no requests to third-party services — including fonts, maps and external scripts. The only cookie it sets is lang, which remembers the language you chose with the RU / EN switch; it holds no identifier and is used for nothing else. The only form on the Website — the waiting list — sends the name and email to the operator's server and nowhere else. Payment is made on the payment service's page, which has a policy of its own.

Grounds and consent

The data is processed to conclude and perform the licence agreement to which the data subject is a party (clause 5 of part 1 of article 6 of Federal Law No. 152-FZ), and the payment details also to fulfil the operator's obligations under tax law. No separate consent is required for this. By contacting support, the data subject consents to the processing of the data given in the email in order to reply to it; by sending the waiting-list form — to the keeping of the name and email for one message about the release.

There are two kinds of email. Emails about the licence — the activation code, renewal, the receipt, replies to requests — are sent under the agreement. Emails about new versions, features and the operator's products are sent with the consent given at payment (clause 2.2 of the licence agreement) or in the waiting-list form, no more than once a month; you can opt out of them via the link in any such email or by writing to ask@zerno.photo — emails about the licence continue to arrive.

Storage and protection

The data is recorded and stored on a server located in the Russian Federation. The exchange between the program, the website and the server is protected with TLS; access to the server is limited to the operator and the person maintaining the program on the operator's behalf. Backups of the database are kept on the same server or on the operator's media in Russia.

Retention periods: name, email, Mac codes, contact dates and counters — for the term of the licence and three years after it ends (the limitation period); payment details — five years from the date of payment (sub-clause 8 of clause 1 of article 23 of the Tax Code of the Russian Federation). When the periods expire, the data is deleted.

Who it is passed to

The data is not sold or passed to third parties, with two exceptions: the payment service receives the email address, the amount and the purpose of the payment in order to take it and send the receipt; the tax authority receives the receipt data under Federal Law No. 422-FZ. The server's hosting provider keeps it running and has no access to the data. There is no cross-border transfer.

Rights and requests

6.1. The data subject may find out which of their data is processed, demand its correction or deletion, and withdraw consent — by writing to ask@zerno.photo from the address the licence was issued to. A reply follows within 10 working days (article 20 of Federal Law No. 152-FZ).

6.2. Payment details that the operator is obliged to keep by law are not deleted on request until the retention period expires.

6.3. Deleting the name, email and Mac codes ends the licence: without them the right to use the program cannot be confirmed. The operator warns of this in the reply to the request and deletes the data after confirmation.

Changes

A new edition of the policy is published on this page with its date. Changes that widen the scope of the data collected or the purposes of processing take effect for existing licences no earlier than 30 days after publication.

The policy is drawn up in Russian. Translations are published for convenience; in case of a discrepancy between the Russian text and a translation, the Russian text applies.