Privacy notice

1. Controller

Max Zelinka
c/o Impressumservice Dein-Impressum
Stettiner Str. 41
35410 Hungen
Germany
Email: fristly.app@icloud.com

2. Hosting and technical delivery

This website is hosted on Cloudflare Pages. Delivery and security involve processing technical connection data, including IP addresses, timestamps, requested addresses, and browser and device information. The purpose is a secure and reliable website. The legal basis is Article 6(1)(f) GDPR; our legitimate interest is the secure operation of this service.

We use Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, for hosting, database services and spam protection. The database was created with a Western Europe location preference, which does not guarantee exclusively European processing. Cloudflare also processes data internationally. Its Privacy Policy and Data Processing Addendum describe processing, retention and international transfers. The latter includes standard contractual clauses for relevant transfers. We do not keep additional personal access logs in our application database.

3. Early access waitlist

Signing up stores your email address, the time, language and version of your consent, and the source “landing page” in Cloudflare D1. The data is used only for news about Mapryva and potential test access. The legal basis is your consent under Article 6(1)(a) GDPR. Providing this information is voluntary; without your address and consent you cannot join the waitlist. No purchase is involved.

No automatic confirmation email is sent, so ownership of the address is not verified. Signing up does not guarantee test access or a launch date. Addresses are not sold and this website does not send automated emails. Any future email delivery provider would need to be configured separately and reflected in this notice.

Consent wording, version 2026-10-22-v1, English translation: “I would like to receive email updates about Mapryva and test access. I have read the privacy notice. I can withdraw my consent at any time by contacting fristly.app@icloud.com. Checking this box loads Cloudflare spam protection.”

Entries are retained for up to 365 days after signup and then removed by a daily cleanup. Signing up again with the same address does not extend this period. Entries are deleted earlier following withdrawal, a valid erasure request, or if the purpose ends early. Contact fristly.app@icloud.com to request this. Withdrawal does not affect the lawfulness of processing before withdrawal. Technical backups may retain deleted data until their backup period expires; Cloudflare D1 Free provides a recovery history of up to seven days.

4. Spam protection and request limits

Cloudflare Turnstile is loaded only after you actively check the consent box. This may transmit your IP address and technical browser and connection information to Cloudflare. We verify the resulting token on the server to help prevent automated signups. Loading the service is based on your consent in the form, Article 6(1)(a) GDPR. Without the check, the online form cannot be submitted. See the Turnstile Privacy Addendum for details.

We also limit requests using a secret-key HMAC of your IP address that changes with each hourly time window. We store that pseudonymised value, a counter and an expiry time, rather than the raw IP address. The purpose and legitimate interest are abuse prevention and operational security, Article 6(1)(f) GDPR. Counters apply to an hourly window. Expired counters are deleted during subsequent requests and by daily cleanup. In normal operation, they are retained for no more than approximately 25 hours. Cloudflare itself continues to process the connection data needed for its services.

5. Cookies, external content and the desktop app

The application code does not set analytics, advertising or tracking cookies, use local storage, or load external fonts. No analytics or advertising services are integrated. Turnstile may process information on your device as part of its technical checks. After unchecking the box or withdrawing consent, reload the page to stop previously loaded Turnstile code.

The planned local processing in the desktop app is separate from this website: the website and waitlist are online services. No CSV, Excel or JSON files are uploaded or processed here.

6. Your rights

Subject to the applicable legal conditions, you may request access, rectification, erasure, restriction of processing and data portability. You may withdraw consent for future processing at any time. For processing based on legitimate interests, you may object on grounds relating to your particular situation. Contact fristly.app@icloud.com. To prevent unauthorised changes, we may reasonably ask for evidence that you control the address concerned.

You may also complain to a supervisory authority, particularly in the member state of your habitual residence, place of work or the alleged infringement. The European Data Protection Board provides a list of authorities. There is no automated decision-making with legal or similarly significant effects, or related profiling.

7. Version

22 October 2026. This notice will be updated if the service changes.