Privacy – platform and application

The controller of account, licence, support and security data, and of order and payment data stored in the portal, is the publisher named in the “Publisher details” document. Contact: contact@mapengine.pro. This document concerns the app.mapengine.pro portal, the service API, the Windows application, updates, online analyses and account handling. The public website has a separate privacy notice.

Personal data in files. A file from a car or a workshop may contain personal data (for example a VIN or a workshop designation). I process personal data contained in a file you send only in order to carry out your analysis, and to that extent I act on your behalf as a processor. Binding processing terms under Article 28 GDPR must be concluded before you upload personal data for which you are the controller. Write to contact@mapengine.pro before uploading; do not upload such data until the terms are concluded. I do not assume that data from an ECU file is not personal.

I process: e-mail address, password hash, account status, profile data, dates of registration and logins, sessions, IP addresses and browser information needed for login and security. E-mail confirmation and password recovery tokens are assigned to the account. I do not store the password as plain text. System messages (account confirmation, access recovery, important information about the service) are not marketing.

Purchases are made by PayPro Global as reseller and seller (Merchant of Record) at its own checkout, on its own terms and under its own privacy policy. You give the data needed for the purchase and the purchase document (for example name or business name, address, country, tax number, card details) directly to the operator at checkout. The portal does not collect a separate billing profile and does not ask for that data.

I pass your account e-mail address to the checkout. From the operator I receive and store the data needed to grant access, handle refunds and settlement: amounts, currencies, net amounts, statuses and identifiers of orders, transactions, refunds and events. I do not store card details or the checkout address. The order history distinguishes the first purchase and a continuation.

The server stores the hash of the licence key and its visible beginning, the link to the account, status, allowances, computer registrations, verification times, IP addresses, the computer identifier and a public key used to confirm that this is that computer. A computer’s label may derive from its name, so it may contain a first name or business name if the computer is named that way.

The application calculates a hardware identifier locally, from the available identifiers of the system, motherboard, BIOS, processor and Windows installation. Only the calculated hash reaches the server, not a list of all the raw numbers. This is not browsing your documents or the list of installed programs. The private device key stays on your computer, and Windows mechanisms protect the local registration and licence data. These identifiers are not automatically anonymous, because they are linked to the account.

Merely opening a file and editing it does not send the contents for analysis. When you request map analysis or DTC decoding in the online version, the program sends: the selected file, its length, its SHA-256 hash, the analysis parameters and the necessary authentication data. Cloudflare mediates authorisation and the private storage; the analysing computer, which belongs to the provider, processes the data and returns the result. A file may contain a VIN or identifiers of a person, a workshop or a vehicle. Send only data you have the right to, and avoid unnecessary personal data.

The result includes map suggestions and recognised DTC codes, available descriptions, an assessment of state, information about the recognition and metadata. I do not show it to other customers. I use the data sent for the commissioned analysis, not for training models, selling files or building a library from them. A separate handing over of materials for my development requires an agreed scope and basis – this document does not provide that.

Reading the counters (when the program starts, periodically and on request) sends the necessary licence and computer data and queries; it does not send the ORI file. It may refresh verification times, the IP address and security data. The analysis register contains: account, licence and computer identifiers, the hash and size of the file, the requested and recognised family, the similarity setting, engine and library versions, status, times, number of results and error codes. It serves to carry out the analysis, show the counters, settle allowances and diagnose problems.

The portal records administrative actions, server errors and relevant metadata. Errors may include the text of a message, an execution trace, the route and the method of the request; I limit such data to a minimum and protect it. Access of employees and administrators is limited to their permissions and a justified need.

Support stores the subject, messages, the link to the account, statuses and attachments (name, type and size). Support attachments are not deleted automatically like files for analysis. The wishlist stores suggestions, notes, votes, weeks and links to the account; the voting result shown to customers does not reveal e-mail addresses. Moderation decisions are made by an administrator.

At registration and at purchase I record which versions of the terms and the privacy information you accepted, in which language and when (at registration also the IP address). Optional marketing requires a separate basis and compliance with the rules on electronic communication; it is not a condition of the licence, a complaint or exercising your rights. Newsletter. I send the MapEngine newsletter (product news, guides and offers by e-mail) only to people who have given separate, optional consent. Every message contains an unsubscribe link, and you can withdraw your consent at any time; withdrawal does not affect the lawfulness of earlier processing. For the newsletter I record the consent (time, source, document version) and the delivery status of messages.

• If you are a party to a contract with me, I carry out the account, licence, analysis and order handling on the basis of Article 6(1)(b) GDPR.
• A business representative’s data may be processed on the basis of my legitimate interest in handling the relationship with the business (point (f)).
• Documentation I must keep (for example accounting) and the carrying out of requests arising from the law I base on a legal obligation (point (c)).
• Securing the service, preventing abuse, necessary diagnostics and defending claims I may base on a legitimate interest (point (f)), after checking that this is necessary and does not infringe your rights.
• Consent (point (a)), where it is needed for a specific purpose, must be freely given and capable of being withdrawn. This document is not a general consent for all purposes.
• Without an e-mail address and the data needed for a licence I cannot create an account or authorise the program. I collect other data only to the extent needed for the purpose.
• Data I receive from the payment operator or from your business’s account administrator is data obtained from third parties – I inform you of it by this document.

Cloudflare provides hosting, the API, the database, protection and file storage. Resend handles system messages (account confirmation, access recovery) and, for people who have consented, the newsletter. The contact@mapengine.pro mailbox is handled by OVH. The payment operator processes payment data in its own role, under its own policy. Data may go to authorised persons, necessary advisers or authorities where there is a basis for it. I do not sell customers’ data.

Cloudflare and Resend may also process data outside the EEA, including in the USA; OVH, which handles mail, is a company based in France. The basis for transfers is the mechanisms in Chapter V of the GDPR, most often standard contractual clauses or an adequacy decision; you may ask for information about the safeguards by writing to contact@mapengine.pro.

Files for analysis and results. You have 10 minutes from creation of the job to send the file. A job after the file is sent lasts up to 60 minutes. A finished result is available for collection for 15 minutes from completion (or less if the job expires earlier). After successful processing, after cancellation and after the job expires, I delete the input file or the result. Physical deletion takes place periodically and in batches, so a failure or backlog may delay it.

Analysis register. I delete the file hash of finished jobs after 15 days and the whole entry after 45 days, in batches. This is separate from how long you yourself keep the result. I keep database backups for up to 35 days; the backup script deletes older local copies. A database backup does not include files in the analysis storage or files on local computers.

Sessions. They are described in the document “Cookies and local data”. The expiry of a token does not prove that every historical record has been deleted.

Support, messages, audit log, diagnostics, billing and legal records. I apply these periods: support messages and attachments – up to 24 months from closing the matter; audit log – up to 365 days; error logs and diagnostics – up to 90 days; billing and accounting documents – as long as the law requires (usually 5 years from the end of the tax year), with the payment operator also handling payments under its own rules. I carry out deletion periodically, at least once a quarter; keeping data for longer is possible only where the law or defence of claims requires it.

Deleting an account invalidates sessions and access, deletes the current profile, the computer registrations and the licence, and replaces the e-mail address with an identifier of the deleted account. Orders, payments, support reports and backups that the law requires, or that are needed to defend a claim, stay for the periods stated above. Deleting an account is not a request for a refund or consent to losing claims that are due to you.

You have the right to access your data, to rectification, erasure, restriction of processing, objection and portability (where the conditions are met) and to withdraw consent for a given purpose. Write to contact@mapengine.pro. As a rule I reply within a month, with the possibility of a statutory exception or extension. You may lodge a complaint with the President of UODO or another competent authority. Verification of identity must be proportionate to the request.

I use, among other things: HTTPS, hashes of passwords and tokens, signature verification, confirmation of the computer, administrative permissions and private file storage. Licence status, computer status and allowances are enforced automatically; abuse signals go to a human for assessment. A map-matching result is not a legal decision about you. If you believe that a refusal of access or of an allowance is wrong, report it to support – a human will assess the matter.

PayPro Global, including Canadian PayPro Global Inc. and the selling entity identified at checkout, processes order and payment data for sales, taxes, purchase documents, refunds and fraud prevention under its own privacy notice provided at purchase. PayPro supplies me with data necessary to fulfil the licence, handle the order and provide support: order identifiers and status, contact details, product, access period, amounts and refund events. I provide PayPro with necessary order fulfilment and request information. I do not provide calibration files to PayPro for payment processing.

I act as controller for my own account, licence and security purposes. For data entrusted to me by PayPro, I act as processor under my processing terms with PayPro. Authorised accounting providers and advisers may receive necessary documentation for settlement and legal obligations.

Purchase handling may involve transfers outside the EEA, including Canada. The Canadian adequacy decision covers commercial organisations subject to PIPEDA; it does not automatically cover every recipient. Other transfers require appropriate Chapter V GDPR mechanisms, including standard contractual clauses where required. Write to contact@mapengine.pro for recipient and safeguard information.