Legal
Privacy policy
This policy explains what personal data NEOMANERA LTD processes, why, on what legal basis, and what rights you have. We have written it to be read rather than to be survived.
In effect from
We designed our products and this website to work with the least personal data we could manage. This policy describes what remains.
Who we are
NEOMANERA LTD (“NEOMANERA”, “we”, “us”) is the data controller for the personal data described in this policy. We are a private company limited by shares registered in England and Wales under company number 17462296.
- Registered office
- 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
- Contact for data protection
- developer@neomanera.co.uk
We are not required to appoint a Data Protection Officer. Data protection matters are handled by the company directly at the address above.
What this policy covers
This policy covers personal data processed through:
- this website, at neomanera.co.uk;
- correspondence with us by email or post;
- software products published by NEOMANERA.
Individual products may have their own privacy notice where they process data this policy does not describe. Where that is the case, the product’s notice is published with the product and takes precedence for that product.
This policy does not cover third-party websites we link to. Following an external link takes you somewhere governed by someone else’s policy.
Data we process: this website
This website is a set of static files. It contains no analytics software, no advertising software, no third-party tracking scripts and no social media embeds. It sets no cookies.
The only personal data associated with a visit is:
- Server request logs. Our hosting provider records technical information about requests — IP address, timestamp, the page requested, HTTP status, and the browser’s user-agent string. These logs exist to deliver the site, diagnose faults and detect abuse.
- A theme preference. If you switch between the light and dark appearance of this
site, that choice is stored in your browser’s local storage under the key
neomanera-theme. It never leaves your device, is not a cookie, and is not transmitted to us. Clearing your browser’s site data removes it.
Data we process: correspondence
When you email us, we process the content of your message, your email address, and any personal data you choose to include. We use it to answer you and to keep a record of the matter.
Please do not send us information you would not want retained. If you need to send something sensitive, write first and ask.
Data we process: our products
Our products are designed to require as little personal data as they can. Where a product needs personal data to function, the categories are:
- Account data, where the product has accounts: an email address and authentication credentials, held as salted hashes rather than as recoverable passwords.
- Transaction records, where the product is paid for: what was purchased and when. Card details are handled by the payment provider or application store and are never received or stored by us.
- Diagnostic data, where it is enabled: crash reports and error traces used to fix defects. Where a platform allows it, this is opt-in.
- Support correspondence, as described above.
We do not build advertising profiles, we do not sell or rent personal data, and we do not share personal data with data brokers.
Lawful bases
We rely on the following lawful bases under Article 6 of the UK GDPR:
| Processing | Lawful basis |
|---|---|
| Serving this website and keeping server logs | Legitimate interests — operating and securing our website |
| Answering your correspondence | Legitimate interests — responding to enquiries addressed to us |
| Providing a product you have an account with | Performance of a contract |
| Optional diagnostics and crash reporting | Consent, which you may withdraw at any time |
| Keeping accounting and tax records | Legal obligation |
Where we rely on legitimate interests, we have assessed that our interest does not override your rights and freedoms. You may object to that processing — see Your rights.
Who we share data with
We share personal data only where it is necessary, and only with:
- Service providers that operate infrastructure on our behalf — hosting, email delivery, error reporting and payment processing. They act on our written instructions and may not use the data for their own purposes.
- Application stores, where a product is distributed through them. The store operates as an independent controller for the purchase relationship under its own policy.
- Professional advisers — accountants and lawyers — where they need the information to advise us.
- Authorities, where we are legally required to disclose. We assess every such request, require it to be properly made, and disclose no more than is required.
We do not sell personal data. There is no circumstance in which we would.
International transfers
We prefer to keep data within the United Kingdom or the European Economic Area. Where a service provider processes data outside those areas, we rely on UK adequacy regulations or on the International Data Transfer Agreement (or the UK Addendum to the EU Standard Contractual Clauses), together with any additional safeguards the transfer requires.
How long we keep data
| Category | Retention |
|---|---|
| Server request logs | Up to 30 days, then deleted or aggregated beyond identifiability |
| Correspondence | Up to 24 months after the matter is closed |
| Account data | For as long as the account exists, then deleted within 90 days of closure |
| Transaction and accounting records | Six years, as required by UK tax law |
| Crash and diagnostic reports | Up to 12 months |
| Speculative job applications | 12 months, then deleted |
How we protect data
We apply technical and organisational measures appropriate to the risk, including encryption in transit for all public endpoints, encryption at rest for stored personal data, least-privilege access to production systems, secrets held in managed secret storage, automated dependency vulnerability scanning, and a written incident response procedure.
Where a personal data breach is likely to result in a risk to your rights and freedoms, we will report it to the Information Commissioner’s Office within 72 hours of becoming aware of it, and will tell you directly where the risk is high.
Your rights
Under UK data protection law you have the right to:
- be informed about how your personal data is used — this policy;
- request a copy of the personal data we hold about you;
- have inaccurate personal data corrected;
- request erasure of your personal data in certain circumstances;
- request that we restrict processing in certain circumstances;
- receive your data in a portable, machine-readable format;
- object to processing carried out on the basis of legitimate interests;
- withdraw consent at any time, where we rely on consent.
To exercise any of these, email developer@neomanera.co.uk and say which right you are exercising. We will respond within one month. If a request is complex we may extend that by up to two further months, and we will tell you if that happens and why. Exercising these rights is free; we will only charge a fee for a request that is manifestly unfounded or excessive, and we will explain the reason if we do.
We may need to verify your identity before acting on a request, so that we do not disclose your data to someone else.
Children
Our products and this website are intended for adults and are not directed at children. We do not knowingly collect personal data from a child under 13. If you believe a child has provided us with personal data, contact us and we will delete it.
Changes to this policy
We update this policy when our processing changes. The effective date at the top of this page shows when the current version took effect. Where a change materially affects you, we will take reasonable steps to bring it to your attention rather than relying on you to notice.
Contact and complaints
For any question about this policy, or to exercise a right, email developer@neomanera.co.uk or write to NEOMANERA LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
If you are unhappy with how we have handled your personal data, we would like the chance to put it right. You also have the right to complain to the UK supervisory authority:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom — ico.org.uk