Privacy Policy – 2026-10-28
Information about personal data processing in the Validarium web and mobile applications.
Version 2026-10-28 · effective from 10/28/2026
Privacy Policy
This document explains how Pavel Zaněk, as the data controller, processes personal data of users of the Validarium web and mobile applications.
Data I process
- Identification and contact details, especially name and email address.
- Data stored in Cloud mode, such as item names, expiration dates, categories, notes, reminders, workspace memberships, and attachments.
- Contact form and newsletter data when the user chooses to use those services.
- Necessary technical and security data, such as request time, the account used, and information required to diagnose errors and protect the service.
Device and Cloud modes
Data created in the mobile app's Device mode remains only on the phone and is not processed by Validarium servers unless the user chooses to transfer it to Cloud mode. Cloud mode data is transmitted to Validarium servers so it can be synchronized, displayed in the web app, and shared with authorized workspace members.
Purposes and legal grounds
I process data to create and manage accounts, provide cloud synchronization and attachment storage, deliver user-configured notifications, provide support, secure the service, and comply with legal obligations. Processing required for an account and Cloud mode is based on providing the requested service. Security and diagnostics are based on the legitimate interest in reliable operation. Newsletters are sent only with consent, which can be withdrawn at any time.
Cloudflare R2 and cloud attachments
Cloud attachments are stored in a private Cloudflare R2 bucket operated by Cloudflare, Inc., acting as a processor for this purpose. The bucket is configured for the European Union jurisdiction. Attachments are not public, and client applications do not receive storage credentials or a direct public object URL. Uploads, previews, downloads, and deletions are handled through the authorized Validarium server interface.
Cloudflare's contractual terms and data processing addendum apply to its processing. If service operation involves a transfer outside the European Economic Area, an appropriate legal transfer mechanism must be used.
Sharing data
I disclose data only to technical service providers to the extent necessary to operate Validarium or where required by law. Paddle processes identification, billing, and payment data as merchant of record for subscription management. Shared account and workspace content is available to authorized members according to role and assignment. I do not sell personal data.
Retention and deletion
Account and Cloud mode data is retained while the account or relevant workspace exists. Downgrading or cancelling a plan does not itself delete data; excess data may become read-only. An attachment is removed when deleted or when the related item, workspace, or account is removed. Billing and audit records may be retained as required by legal obligations and the protection of rights.
Security
Access to cloud data is restricted through user authorization and workspace permissions. The R2 bucket is not public, and access keys are stored only in server configuration. Nevertheless, no internet service can guarantee absolute security.
User rights
Users may request access, rectification, deletion, restriction of processing, or portability of their personal data and may object to processing based on legitimate interests. Consent may be withdrawn at any time. Users also have the right to lodge a complaint with the competent data protection authority.
Contact
Requests and questions about personal data protection can be sent to info@pavelzanek.com.
AI clients, MCP, and OAuth
Validarium does not send cloud data to ChatGPT or Claude without a connection authorized by the user. After OAuth approval, the connected client can request data within the user permissions and selected workspace, such as expiration titles and dates, categories, notes, reminders, and attachment information; using the download tool can also provide attachment contents. The client can also request item creation, editing, or deletion. Data returned to the client is processed by its provider, such as OpenAI or Anthropic, under that provider's terms and account settings; processing may involve transfers outside the EEA.
To manage and secure the connection, I retain the OAuth client identity, assigned account and workspace, granted permissions, connection credentials, and time of last use. Tool call counts are recorded for monthly plan limits. Connections can be revoked in Settings → AI connections, invalidating their access and refresh tokens. Revocation does not itself remove copies of data already obtained by the client. Deletion and retention of those copies must be addressed with the AI provider.
Contact form
Form data is used to answer your enquiry and handle follow-up communication. The message is stored in the administration and sent by email through Mailgun. For spam protection, I record the IP address, browser, time, and source page; the form uses a frequency limit and a control field. Data is retained for the time needed to resolve the enquiry and, where necessary, protect rights. Submitting the form does not subscribe you to the newsletter.
Version archive
- 2026-10-30 — Current version Added operator identification, account closure procedure, and mobile notification information.
- 2026-10-28 — Displayed version Added optional MCP/OAuth connections to AI clients, access scope, and revocation.
- 2026-07-18 Added Paddle, billing data, shared accounts, and retention after downgrade.
- 2026-07-16 Added Cloud mode, workspaces, and private Cloudflare R2 attachment storage.
- 2026-06-20 First recorded version of the document.