Privacy Policy

The data controller responsible for your personal data is:

GIMZWARE LTD is a limited company registered in England and is the data controller for the personal data described in this policy. As a small organisation, we are not required to appoint a Data Protection Officer. For any data protection queries, please contact us at the email address above.

Under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), we process your personal data on the following legal bases:

• Performance of a Contract (Article 6(1)(b)): Processing your email address and licensing data is necessary to deliver your purchased software, provide licence keys, and fulfil our contractual obligations to you.
• Legitimate Interest (Article 6(1)(f)): Processing hardware identifiers for licence validation to prevent unauthorised use of our software. On the same basis, when you submit a form on this website the IP address attached to the request is processed for the short period needed to rate-limit that form, which protects the site from automated abuse. It is held in memory for no more than one minute, is not written to a database, is not sent on to anyone else and is not used to identify you. We have balanced both against your rights and consider them proportionate given the minimal data involved and the legitimate need to protect our software and this site.
• Consent (Article 6(1)(a)): Where you have opted in to receive product launch notifications, we process your email address based on your consent. When you opt in we record the date and the exact wording you agreed to, so that what was consented to can be shown rather than asserted. Every notification email carries a one-click unsubscribe link: following it removes your address from the list straight away, with no account, no login, no reply and no confirmation step. You can also unsubscribe by writing to [email protected].
• Legal Obligation (Article 6(1)(c)): Where we are required to retain certain records for tax or regulatory compliance.

We do not sell, trade, or rent your personal information. We share information only with the following third parties, and only as necessary:

• FastSpring (Bright Market, LLC): Our payment processor and Merchant of Record. FastSpring processes your payment and collects billing information on our behalf. They share your email address and order details with us for licence fulfilment. FastSpring is based in the United States and operates under the FastSpring Privacy Policy.
• Microsoft Azure: Our licensing API, our support form backend and our product notification list are hosted on Microsoft Azure infrastructure. Contact form submissions, licence activation requests, product notification signups and unsubscribe requests are processed through Azure Functions, and the email addresses on the notification list, together with the consent record for each one, are stored there.
• Law Enforcement: We may disclose information if required to do so by law, court order, or other legal process.

We do not share your data with any analytics providers, advertising networks, or data brokers.

Some of our service providers are based outside the United Kingdom and European Economic Area (EEA). When your data is transferred internationally, appropriate safeguards are in place:

• FastSpring (USA): Transfers are covered by Standard Contractual Clauses (SCCs) and the EU-US Data Privacy Framework where applicable.
• Microsoft Azure: Microsoft operates under approved Standard Contractual Clauses and the EU-US Data Privacy Framework. Data processing may occur in the UK, EU, or US depending on the service region. This covers licence activation data, support correspondence, and the email addresses and consent records held for the product notification list.

You can request further details about the safeguards in place by contacting us.

Under the UK GDPR and EU GDPR, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data where there is no compelling reason for continued processing
• Right to Restrict Processing: Request that we limit how we use your data
• Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. For product notification emails this takes one click on the unsubscribe link every one of them carries

To exercise any of these rights, contact us at [email protected]. We will respond to your request within one month, as required by law. There is no fee for making a request unless it is manifestly unfounded or excessive.