Privacy notice

Draft, not in force, for CG to complete. This page lists what the notice must cover (GDPR basics, see the accounts plan section 4). Nothing here is a commitment until CG publishes a final text. Items in [brackets] are for CG to fill.

1. Who is responsible

Controller: [CG's name or trading name, address, Portuguese tax number if required]. Contact for privacy matters: contact@rimokon.net.

2. What Rimokon processes and why

Sessions between computers: the picture, keyboard, mouse, clipboard, files, chat and sound are encrypted between the two computers and are never stored or readable by any server. Relays carry encrypted data only.
Accounts (when they open): email address, a password hash (never the password), display name, account created and last sign in, the computers attached to the account (public key, name, system, partner ID), hashed session tokens, subscription state, and the payment provider's customer and subscription identifiers. Purpose: sign in, listing your computers on your devices, billing.
Abuse prevention: sign in addresses kept for 30 days.
Never stored: passwords, session content, clipboard, screens, keystrokes, session passwords, card data.
Telemetry: aggregate counters only, never per session content. [CG: confirm or list exactly what is counted]

3. Legal basis

[Contract performance for accounts and billing; legitimate interest for abuse prevention and security; consent where applicable. CG with advice.]

4. Processors and where data lives

Hosting of the account service and database: alwaysdata (France). Daily backups kept 30 days.
Website and DNS: Cloudflare [confirm which Cloudflare services are used].
Payments: Paddle, as merchant of record; card data is handled by Paddle, never by Rimokon.
Email: sent from alwaysdata's mail servers for verification and password reset only.
Relay servers: [provider and country of each relay server]; they see connection addresses and encrypted bytes only.

5. Retention

Account data while the account exists and [N days] after deletion for backups; sign in addresses 30 days; billing records as tax law requires [years].

6. Your rights

Access, correction, export and deletion within 30 days of a request to contact@rimokon.net; deletion is also available in the app. Complaints: the Portuguese data protection authority (CNPD) or your local authority.

7. Security and breaches

Passwords are hashed with Argon2id, tokens stored hashed, connections encrypted. In case of a breach affecting personal data, [CG's procedure: assessment, notification of the authority within 72 hours where required, notice to affected people].

8. Cookies

This website sets no cookies and loads no third party content. [Update if Paddle's checkout or Cloudflare adds any.]

9. Changes

Date of this version: [date]. Earlier versions: [where].