Contents
- 1. Data Controller
- 2. What Data We Collect and Why
- 3. Legal Basis for Processing
- 4. Data Retention
- 5. Third-Party Sub-Processors
- 6. International Data Transfers
- 7. Your Rights
- 8. Cookies and Tracking Technologies
- 9. Children's Privacy
- 10. Security Measures
- 11. Changes to This Policy
- 12. Supervisory Authority
1. Data Controller
The data controller responsible for the personal data processed through this website and the LensLaber software is:
Name: Clemente O.
Role: Independent developer — LensLaber (sole trader / autónomo)
Country of establishment: Spain
Contact email: LensLaber@gmail.com
LensLaber is operated by a single individual, not a company. There is no appointed Data Protection Officer (DPO), as this is not required for sole traders who do not carry out large-scale systematic processing of personal data (Article 37 GDPR). For any privacy-related query, contact the address above.
2. What Data We Collect and Why
The LensLaber software itself is offline-first and does not collect, transmit, or store any user data in the cloud. Your images, annotations, and local project files never leave your machine. No telemetry or usage analytics are sent from the application.
Future release note
The final commercial release will require a one-time online license activation check. This check will only transmit the minimum data necessary to validate the license (a license key and a machine-generated identifier). No annotation data or file paths will be transmitted. This policy will be updated before that release.
Through this website, we process the following personal data:
| Data | Source | Purpose |
|---|---|---|
| Email address | Newsletter subscription form (Google Forms) | Sending update notifications and new beta announcements |
| Name, email address, message content | Contact form (EmailJS) | Responding to enquiries sent by the user |
| Name, email address, OS/version info, message content | Bug report / feedback form (EmailJS) | Diagnosing and resolving software issues |
We do not collect payment information, physical addresses, IP addresses, browser fingerprints, or any sensitive categories of data (Article 9 GDPR).
3. Legal Basis for Processing
Each processing activity rests on a specific legal basis under Article 6 GDPR:
- Newsletter subscription (email only): Your freely given, specific, and informed consent (Article 6(1)(a) GDPR). You may withdraw this consent at any time.
- Contact and feedback forms: Legitimate interest (Article 6(1)(f) GDPR) — specifically, our legitimate interest in responding to user enquiries and improving the software. The processing is proportionate: only the minimum data needed to reply is collected.
4. Data Retention
- Newsletter email addresses are retained for as long as your subscription is active. You can unsubscribe at any time by emailing LensLaber@gmail.com, after which your address will be removed within 30 days.
- Contact and feedback messages (received via email) are retained for a maximum of 24 months, or until the related matter is resolved, whichever comes first.
After these periods, personal data is permanently deleted or anonymised.
5. Third-Party Sub-Processors
We do not sell or rent your personal data to any third party. However, we use the following sub-processors to operate this website:
Google LLC — Google Forms & Google Workspace
Purpose: Newsletter subscription management.
Data transferred: Email addresses submitted via the subscription form.
Privacy policy: policies.google.com/privacy
EmailJS (Emailjs.com, Inc.)
Purpose: Routing contact and feedback form submissions to the developer's email inbox.
Data transferred: Name, email address, and message content you voluntarily submit.
Privacy policy: emailjs.com/legal/privacy-policy
GitHub, Inc. (Microsoft)
Purpose: Hosting binary releases and documentation.
Data transferred: Standard web server logs (IP address, browser) when downloading a release. We do not control or access these logs.
Privacy policy: GitHub Privacy Statement
6. International Data Transfers
Google LLC and GitHub, Inc. are headquartered in the United States. The data they process on our behalf may therefore be transferred outside the European Economic Area (EEA). These companies rely on Standard Contractual Clauses (SCCs) approved by the European Commission as the legal mechanism for such transfers, in accordance with Article 46(2)(c) GDPR.
EmailJS processes data within the EEA or under equivalent safeguards. We recommend reviewing their privacy policy for the latest information.
7. Your Rights
Under the GDPR and the Spanish Organic Law 3/2018 (LOPDGDD), you have the following rights regarding your personal data:
- Right of access (Art. 15 GDPR): Request a copy of the personal data we hold about you.
- Right to rectification (Art. 16 GDPR): Ask us to correct inaccurate data.
- Right to erasure / "right to be forgotten" (Art. 17 GDPR): Request deletion of your data, where no legal obligation requires us to retain it.
- Right to restriction of processing (Art. 18 GDPR): Ask us to limit how we use your data in certain circumstances.
- Right to data portability (Art. 20 GDPR): Receive your data in a structured, machine-readable format.
- Right to object (Art. 21 GDPR): Object to processing based on legitimate interest.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- Right not to be subject to automated decisions (Art. 22 GDPR): We do not use automated decision-making or profiling.
To exercise any of these rights, send an email to LensLaber@gmail.com with the subject line Privacy Request. We will respond within 30 days, as required by Article 12 GDPR.
8. Cookies and Tracking Technologies
This website does not use analytics, advertising, or tracking cookies. We do not use Google Analytics, Facebook Pixel, or any other behavioural tracking tool.
Third-party scripts embedded in this page (Tailwind CDN, Font Awesome CDN, Google Fonts, EmailJS) may set their own technical cookies or log requests. These are strictly functional in nature. By using this website you acknowledge this limited third-party technical activity.
Note for Spanish / EU users
Under the Spanish Law 34/2002 (LSSI-CE) and the ePrivacy Directive, even technically necessary cookies from third-party CDNs may require an information notice. If you implement any analytics or non-essential cookies in the future, a full cookie consent banner will be legally required.
9. Children's Privacy
LensLaber is a professional software tool not directed at children. We do not knowingly collect personal data from anyone under the age of 14 (the minimum age for consent under Article 8 GDPR as implemented by Spain's LOPDGDD, Article 7). If you believe a minor has submitted data to us, please contact us immediately at LensLaber@gmail.com and we will delete it promptly.
10. Security Measures
We apply technical and organisational measures appropriate to the risk, in accordance with Article 32 GDPR. These include: HTTPS encryption for all website traffic, limiting data collection to the minimum necessary, and using reputable third-party providers with their own security certifications.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority (AEPD) within 72 hours, and affected individuals without undue delay, as required by Articles 33–34 GDPR.
11. Changes to This Policy
We may update this Privacy Policy to reflect changes in the law, our services, or our data practices. When we do, we will update the "Last updated" date at the top of this page. For material changes, we will also notify subscribers by email. Continued use of the website or software after a change constitutes acceptance of the updated policy.
12. Supervisory Authority
As the data controller is established in Spain, the competent supervisory authority is the Agencia Española de Protección de Datos (AEPD). If you believe your data protection rights have not been respected, you have the right to lodge a complaint with the AEPD:
Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6 — 28001 Madrid, Spain
Website: www.aepd.es
Telephone: +34 901 100 099
Users outside Spain may also lodge a complaint with the supervisory authority of their EU/EEA member state of habitual residence.