Who is responsible
Liechtenstein is part of the European Economic Area. The General Data Protection Regulation (GDPR) applies directly here.
The short version
- This site sets no cookies and does not measure what you do here.
- Fonts and code are served from this domain. Opening the page makes no connection to Google or any third party content network.
- Your email address is processed only if you actively join the list for Pandelo Plus or the list for the Pando plush, and only after you click the link in the confirmation email.
- For Plus, Paddle is the payment service and processes your payment under its own responsibility. I only receive from Paddle what I need to send you your key.
- Pandelo sends no data. Everything stays on your device.
This website
This site is hosted by Cloudflare. When you open it, your browser transmits technically necessary data that Cloudflare records in its server logs: your IP address (the number under which your device can be reached on the internet), time, the address requested, amount of data transferred, referring page, and the identifiers of your browser and operating system. These logs serve the secure and stable operation of the site and the defence against attacks.
The legal basis is Art. 6(1)(f) GDPR. The legitimate interest lies in being able to deliver the site at all and to protect it from abuse. Cloudflare acts as a processor. A transfer to the United States may occur. The basis is Cloudflare's certification under the Data Privacy Framework between the EU and the United States. Should that lapse, the European Commission's standard contractual clauses together with supplementary measures apply instead.
What does not happen here
No cookies, no audience measurement, no behavioural analysis, no profiling, no ad networks, no embedded third party content. Everything this page loads, that is fonts, images and code, comes from this domain. The only exception is the payment service Paddle, and only once you start a payment for Plus (see below).
List: hear when Pandelo Plus is available
How the signup works
On the home page you can join a list so that we let you know when Pandelo Plus is available. It works in two steps like the test signup: your address is first held provisionally and you get an email with a link. Only clicking it adds you. If you do not click, the provisional record is deleted automatically after three days.
What data this creates
- the email address you entered,
- the time of signup and of confirmation,
- the country code my host derives from your IP address, at signup and at confirmation,
- the language version of the site,
- the version of this text you agreed to and a note that you confirmed in two steps.
Your IP address is not stored here either. The abuse brake works as described for the test below.
What it is for
The address is used only to write to you once, when Pandelo Plus is available. Never otherwise. No newsletter, no sharing.
Legal basis
Your consent under Art. 6(1)(a) GDPR, given by clicking the confirmation link. You may withdraw it at any time. An informal message to support@zane.group is enough.
For how long
I delete the address as soon as the message about the Plus launch has been sent, or sooner if you ask.
Who else is involved
The same two processors as for the test: Cloudflare (site and storage) and Sendinblue SAS ("Brevo") (sending the emails). Details below.
List: Pando as a plush
How signing up works
On the home page you can join a list if you would like Pando as a plush toy. It works in two steps like the Plus list: your address is first held provisionally and you get an email with a link. Only clicking it adds you. If you do not click, the provisional record is deleted automatically after three days. Signing up is free and does not commit you to anything.
What data is created
The same as for the Plus list (see above). On the home page we only show the number of confirmed signups, never addresses or names.
What for
The address is used only to write to you when preorders for the plush open. Never otherwise. No newsletter, no sharing.
Legal basis
Your consent under Art. 6(1)(a) GDPR, given by clicking the confirmation link. You can withdraw it at any time. An informal message to support@zane.group is enough.
How long
I delete the address once the preorder message has been sent, at the latest twelve months after your confirmation, or earlier if you ask.
Who else is involved
The same two processors: Cloudflare (site and storage) and Sendinblue SAS ("Brevo") (sending the emails).
Plus and the payment service Paddle
Who processes what
Payments for Plus are handled by Paddle (Paddle.com Market Limited, London, United Kingdom). Paddle is your contracting party for the payment and processes your payment details, for example email address, country and payment method, as an independent controller. What data Paddle processes and for how long is set out in Paddle's privacy notice. This site loads Paddle's code only once you start a payment. Before that, there is no connection to Paddle.
What I receive from Paddle
After the payment, Paddle tells my service at Cloudflare which kind of Plus was paid for, Paddle's number for the transaction, Paddle's number for the customer and a random number from your browser, so that the page can show you the key right away. With the customer number, the service asks Paddle once for your email address so that it can send you the key.
The key and the email
The key contains nothing about you: no name, no email address, no identifier of your device. It only carries the kind of Plus, the day it was issued, for twelve months the last valid day, a random number and the number of the signing key.
The email with the key is sent by Sendinblue SAS ("Brevo") as a processor, on servers inside the EU. I do not store your email address in the process. It goes from the service straight to Brevo for sending and is not kept anywhere on my side afterwards.
What sits in the storage at Cloudflare
- for each payment: Paddle's number for the transaction, the random number of the key, the kind of Plus, the days from the key and the time. I keep this record for at most 13 months, so that I can match a refund to the right key,
- for the page after the payment: the key under the random number from your browser, for 24 hours, after which it is deleted,
- the list of blocked keys: only random numbers of keys whose payment was refunded or charged back.
This storage holds no email address, no name and no IP address.
Legal basis
Art. 6(1)(b) GDPR: I need this information to deliver the Plus you paid for and to carry out a refund correctly.
The page with your key
The link in the email opens the app or the page /k. The key sits after the # sign. That part of a link never goes to a server. It stays in your browser and in the app.
Signing up for the closed test
The test has ended. New signups are no longer possible. For signups already stored, the following still applies:
How the signup works
Signing up happens in two steps. When you submit the form, your address is only held provisionally and you receive an email with a confirmation link. Only when you click that link does an entry on the tester list come into being. If you do not click, the provisional record is deleted automatically after three days and you hear nothing further. This rules out anyone signing you up without your involvement.
What data this creates
- the email address you entered,
- the time of the signup and the time of the confirmation,
- the country code my host derives from your IP address (for example “DE”), at the time of signup and at the time of confirmation,
- the language version of the site you signed up through,
- whether you also want a message when the app is released,
- the version of this text you agreed to, plus a note that the confirmation went through two steps.
The timestamps, the country codes and the last two items exist solely so that your consent can be evidenced, as Art. 7(1) GDPR requires.
Your IP address is not stored
So that the form cannot be flooded automatically, a check value is derived from your IP address together with a random, secret addition and kept for one hour. After that it expires by itself. The addition is generated randomly once on first operation, is not known to me, and exists only for this installation. Your IP address therefore cannot be recovered from the check value. The IP address itself is stored nowhere.
What it is for
The address serves solely to invite you to the closed test on the Google Play Store and to give you feedback during the test. If you ticked the box, I will additionally notify you once when the app is publicly released.
Legal basis
Your consent under Art. 6(1)(a) GDPR. You give it by clicking the confirmation link. The release notification is a separate consent given through the checkbox. Providing the address is voluntary. Without it you simply cannot take part in the test. You may withdraw your consent at any time with effect for the future. An informal message is enough.
For how long
I delete the signup data no later than four weeks after the closed test ends. If you consented to the release notification, I keep the address until the app is published and delete it immediately afterwards. Sooner, as soon as you ask.
Who else is involved
The data is not sold, not used for advertising, not combined with other sources and not evaluated for profiling. Two processors are involved:
- Cloudflare runs the site and the storage the signups live in. A transfer to the United States is possible. The basis is Cloudflare's certification under the Data Privacy Framework. Should that lapse, the European Commission's standard contractual clauses together with supplementary measures apply instead.
- Sendinblue SAS (“Brevo”) in Paris, France, sends the emails and processes your address for that purpose. Delivery runs on servers inside the EU. No transfer to a third country takes place for it.
Contact form and email
If you write to me through the contact form, I process your email address, your name if you give one, and the text of your message, solely to reply to you.
None of it is stored on this site. The message is forwarded straight to my mailbox and sits there afterwards like any other email. Delivery runs through Sendinblue SAS (“Brevo”) and therefore on servers inside the EU.
The legal basis is Art. 6(1)(f) GDPR, the legitimate interest in being able to answer enquiries at all. If your message concerns a contract or its initiation, Art. 6(1)(b) GDPR applies in addition.
For how long. I delete the correspondence once it is settled and no statutory retention duty stands in the way, at the latest after two years.
So that the form cannot be abused automatically, the same brake applies as above: at most three messages per hour and connection, checked through the same non reversible check value. Your IP address is not stored here either.
The Pandelo app
Pandelo sends no data. Everything stays on your device. There is no account, no login and no synchronisation. Your entries, categories, time blocks, settings and progress live only in the app's storage on your phone. The app contains neither analytics tools nor advertising nor third party components that could recognise you.
What the app keeps
The entries of the last 35 days with entries stay saved individually, with time and note. The app condenses older days into totals per day and category. The times and notes of those days are dropped in the process.
Your Plus key
When you redeem a key, the app checks it on your phone, without a network. The key stays in the app's storage. The list of blocked keys arrives with app updates; the app does not ask anywhere for it.
Usage data
In the settings there is the switch "Share usage data". In this version of the app it only stores your answer. Nothing is sent. Should a later update send anything, it will say so here first, and it will only happen with your yes.
Backup and deletion
If you back up your entries as a file, that file sits wherever you save it. If iCloud Backup is on, your entries are included in it. With "Delete everything" in the app's settings you delete all entries on the phone. If you uninstall the app, its data goes with it. No deletion request to me is needed for that. I never had a copy.
Links from the app
The app opens only two addresses, and only when you tap them: this privacy notice and Pandelo's page on the Google Play Store or Apple's App Store. Both open in your phone's browser.
Your rights
You may at any time request access to the data stored about you, as well as its rectification, erasure or the restriction of processing. You also have the right to data portability and a right to object to processing based on legitimate interests. Consent once given may be withdrawn at any time with effect for the future. Processing carried out until then remains unaffected.
An informal message to support@zane.group is enough for all of this. No automated decision making, including profiling, takes place.
Independently of that, you have the right to lodge a complaint with a supervisory authority for data protection, in Liechtenstein with the Datenschutzstelle, otherwise with the authority where you are located.
Changes
If anything about the processing changes, I change this text and put a new version date on it. If the change affects data you have already entrusted to me, I will tell you beforehand.