Privacy and cookies

In short

• The dashboard sends nothing out of your home. Your screens talk only to your Home Assistant. There is no telemetry. The one exception, music covers, is in section 7.
• The integration in Home Assistant talks only to our licence server, and sends only what the licence needs.
• This website sets no cookies of its own and runs no analytics script. Only the payment page, where Paddle's checkout opens, uses Paddle's cookies. The pages with a form load a bot check, Cloudflare Turnstile; the pricing page loads Paddle.js, to show the prices with your country's tax.
• Paddle, which sells you the licence, handles your payment under its own privacy notice, and tells us what we need to issue and manage your licence (section 3.3).
• We keep our database in the European Union. We do not sell data, we show no advertising and we send no marketing e-mails.
• You can object at any time to what we do on the basis of our legitimate interests (section 2), and you have the other rights in section 8.

1. Who is responsible

The controller of your personal data is Iulian Maracineanu, a natural person, Strada Califarului, Pantelimon, județul Ilfov, România: the author of Nucleum Hub. Write to privacy@nucleumhub.com about anything on this page. We have not appointed a data protection officer: the law does not require one for what we do (GDPR, art. 37).

2. Your right to object

3. What we process, why, and for how long

This notice follows art. 13 and 14 of the General Data Protection Regulation (GDPR). The legal bases below refer to its art. 6(1): (b) a contract with you, or steps you asked for before one; (c) a legal obligation; (f) our legitimate interests, which we name each time. We do not rely on your consent for anything on this page.

3.1 Visiting this website

• Data: your IP address, your browser's technical details, the page you ask for and the time.
• Why: to deliver the page and to protect the site against attacks and abuse. Cloudflare does this for us.
• Basis: (f), running a safe website.
• How long: we keep no request logs of our own; we see only total visit counts, which Cloudflare counts on its network, with nothing added to the pages.
• The prices: on the pricing page, your browser loads Paddle.js from Paddle and asks Paddle for the prices with the tax of your country. By placing Paddle.js on the page we cause your browser to send Paddle your IP address and your browser's technical details; for this step Paddle and we decide together, and Paddle then uses them, as an independent controller, to find your country, under its own privacy notice. We receive nothing about you. Basis: (f), showing you the price you would really pay.

3.2 People who start a checkout and do not buy

• Data: Paddle tells us when someone fills in its checkout: Paddle's customer number, the language and, sometimes, the country. We do not keep the e-mail address of anyone who has not bought.
• Why: to recognise the customer when a payment completes.
• Basis: (b), steps before a contract you asked for.
• How long: one day; then we delete the record. We never write to someone who has not bought: an unfinished payment is followed up only by Paddle, under its own notice.

3.3 Purchases and licences

• Where it comes from: Paddle.com Market Limited (London), or the Paddle company that sold to you, tells us about your purchase. We do not receive your card or bank details.
• Data: your e-mail address, which we read from Paddle when your payment completes; your country and language; Paddle's customer, order and subscription numbers; the plan, the amounts, the currency and the discount used; refunds and payment disputes; the periods of a monthly subscription and the year of updates of a one-time licence; the licence, its state and its key, which we keep only as a keyed fingerprint; when we sent you the key. We also keep a list of the messages Paddle sends our server, by their number only, without their content.
• Why: to create your licence and send your key, to give you the updates you are entitled to, to carry out withdrawals, refunds and cancellations, to end a licence that was refunded, to tell you once if a subscription's licence stops for want of payment, and to answer you about your purchase.
• Basis: (b); after the contract ends, (f), keeping proof of what happened in case of a dispute.
• How long: for as long as the licence exists, then 3 years, the general limitation period of Romanian law; the list of Paddle's messages, 12 months. If you ask us to delete your data, we erase your e-mail address without undue delay, within one month at the latest, and keep only what we need as proof, without it. We keep nothing about you for tax purposes: Paddle, the seller, keeps the records of the sale.

3.4 Activating and checking a licence

• Data: the licence; a random identifier of your home created by the integration; a fingerprint of your Home Assistant installation, made from its own identifiers; whether it is your home or your test installation; a renewal code, which we keep only as a fingerprint; the version of the software, and whether a home went back to an earlier version; when we first and last saw the home; your moves; and a record of each signed licence we issue (its number, the home, and when it was issued and expires).
• Your IP address: the integration's requests reach our server from your home's public IP address, with Home Assistant's technical details (the versions of Home Assistant and Python). We keep only a keyed fingerprint of the IP address, to limit how many requests can be made, and delete it after 2 days. We do not store the technical details.
• Why: to activate and check your licence, to offer the updates you are entitled to, and to notice the same licence running in two homes.
• Basis: (b); (f) for preventing abuse of the licence and keeping the service safe.
• How long: for as long as the licence is active in that home, then 24 months after we last saw it; the record of each signed licence, 12 months after it was issued.

3.5 The trial

• Data: the random identifier of your home, the fingerprint of your Home Assistant installation, and when the trial started and ended. No e-mail and no card.
• Why: to give the 60-minute trial, and only once per installation and once per home.
• Basis: (f), preventing abuse of the free trial.
• How long: 12 months after the trial ended, then we delete it. If you buy a licence, the home's data continues under 3.4.

3.6 Withdrawals and cancellations

• Data: what you send on Withdraw from contract here, on Cancel your subscription here or by e-mail: your e-mail address and name; the order number, or your licence key, which we keep only as a keyed fingerprint and its last 5 characters; the plan, the dates you give, the kind of cancellation and its reason, your note; the date and time we received it, its reference, and how and when we settled it.
• Why: to carry out your withdrawal or cancellation, to send the confirmations that consumer law requires, and to keep proof of them.
• Basis: (b), carrying out your request; (c), where the law places on us the confirmations required by Government Emergency Ordinance 34/2014 (art. 11^1) and, for buyers in Germany, §312k of the German Civil Code; (f), keeping proof of it.
• How long: 3 years after we settled the request.

3.7 Messages to support and the form on this site

• Data: your e-mail address, your message and its type (problem, idea, something else), the language and the version you give, the diagnostics file if you attach it, and a reference number. For the form also a keyed fingerprint of your IP address that limits how many messages can be sent, deleted after 2 days; the bot check (3.12) leaves nothing with us.
• Why: to answer you and to fix what does not work.
• Basis: (b) when you are a customer; (f) otherwise, answering the people who write to us.
• How long: 24 months after we close your request.

3.8 Feedback sent from the dashboard

The integration does not send feedback yet: until a later version does, the dashboard gives you our e-mail address and a QR code to the support page, and 3.7 applies. When it does, this is what it sends:

• Data: the type and the message; an e-mail address if you give one (administrators may see it filled in from the licence); the language and the version; for a report next to an error, the kind of page and card, the time and the error text, with entity IDs removed; the diagnostics file only if you tick it, after "See what it contains". The integration adds the plan, the licence state, the versions of the software and of Home Assistant, and the fingerprint of your Home Assistant installation.
• Never sent: names of rooms, people or devices, entity IDs, tokens or photos.
• The route: from the screen to your Home Assistant, then from the integration to our server. A screen never sends it directly.
• Why, basis, how long: as in 3.7.

3.9 The e-mails we send

• Which: your key after a purchase; the confirmations of a withdrawal, a cancellation or a message you sent us; one e-mail if the licence of a subscription stops because a payment did not go through; and the messages that the terms of sale promise (a price change, a change to the terms, the end of the product). We send no newsletter and no offers. Paddle sends the receipts, invoices, refunds and the e-mails about a failed payment.
• Data: your e-mail address, the type of message, the language and whether it was delivered. In our log the address is kept only as a keyed fingerprint.
• Basis: (b); (c) for the confirmations that consumer law requires, where it places them on us.
• How long: the log, 12 months.

3.10 Security reports

• Data: what you send to security@nucleumhub.com.
• Why: to fix the problem and, where the law requires, to report it to the authorities.
• Basis: (f), keeping the software safe; (c) where a report is required.
• How long: 24 months after the fix is published.

3.11 Our own audit log

What support did on a licence (for example, a move or a refund), by whom and when. Basis (f), keeping our records correct and being able to show what we did. Kept 12 months.

3.12 The bot check on our forms (Cloudflare Turnstile)

• Where: only on the pages with a form: support, withdrawal and cancellation. No other page loads it.
• Data: when you open one of these pages, your browser loads Turnstile's script from challenges.cloudflare.com. Cloudflare sees your IP address and your browser's technical details and runs a short check in your browser. We receive a one-time token, which our server confirms with Cloudflare, sending it your IP address, for that one form. We keep nothing from the check.
• Why: to keep bots from sending spam or false requests through our forms. Nothing else.
• Who: Cloudflare acts as our processor for the check. It also uses the same signals, as a controller of its own, to improve Turnstile and its bot detection, as its Turnstile privacy addendum describes; that addendum also says how long Cloudflare keeps them.
• Basis: (f), protecting the forms and the people who use them.

3.13 Copies in our mailbox

The messages you send us, and copies of the confirmations and of the messages sent through the forms, also arrive in our mailbox (support@nucleumhub.com).

4. Who helps us, and who else receives data

• Cloudflare, Inc. (United States) hosts this website, our server, the database, the files you download and the bot check on the forms. The database is stored in the EU; a request is processed in the Cloudflare data centre closest to the person who makes it.
• Brevo (France) sends our automatic e-mails and stores their data in the EU.
• Zoho Corporation B.V. (Netherlands) hosts our mailboxes (support@nucleumhub.com, privacy@nucleumhub.com, security@nucleumhub.com) in its EU data centre.
• Paddle is an independent controller for the data you give in the checkout and for the sale. Paddle's privacy notice applies to it, and questions about a payment go to Paddle. We use the data Paddle gives us only for the purposes in 3.2 and 3.3. When we carry out a withdrawal, a refund or a cancellation, we send Paddle the order or subscription number and the instruction; to send your key, we read your e-mail address from Paddle.
• GitHub: we may record a bug there, without any personal data.
• Authorities and courts, only when the law requires it.
• A company of the author: if the author transfers his contracts to a company that he controls (terms of sale, section 17), that company receives the data it needs to continue them, on the basis of (f), continuing the service you bought. We tell you by e-mail at least 30 days before.

Cloudflare, Brevo and Zoho work for us under data processing agreements and only on our instructions.

5. Transfers outside the European Economic Area

Cloudflare is a United States company: transfers to it rely on its certification under the EU-US Data Privacy Framework and, should that fall away, on the EU standard contractual clauses. Zoho's support staff may access data from India, under standard contractual clauses. Paddle's companies in the United Kingdom and outside the EEA are covered by Paddle's own notice; the United Kingdom has an adequacy decision of the European Commission. You can ask us for a copy of the safeguards at privacy@nucleumhub.com.

6. Do you have to give us data?

To buy, you give your e-mail address to Paddle, and we need it to send your key: without it there is no contract. The trial and the demo need no data from you. The forms need an e-mail address, so that we can reply and confirm.

Nucleum Hub is not meant for children, and we do not knowingly collect data about children.

7. What the dashboard and the integration send

• The screens talk only to your Home Assistant. There is no telemetry.
• The diagnostics file is created on your device when you ask for it, and leaves only if you attach it to a message.
• The integration talks only to our licence server, api.nucleumhub.com. It sends only the data in 3.4 and 3.5, plus feedback when someone sends it (3.8).
• One exception: music covers come through Home Assistant or the Music Assistant in your home, and a cover the screen cannot show (for example Apple TV artwork on an Android tablet) is converted inside your home by our integration. Only if that fails too does the screen fetch the picture from the music service on the internet, as a last resort, so that service sees the screen's IP address. You can switch this off in the dashboard's Settings, under Privacy.

8. Your rights

• You can ask to see your data and get a copy, to correct it, to delete it, to limit its use and to receive it in a portable format, and you can object as section 2 says.
• Write to privacy@nucleumhub.com. It is free. We answer within one month; if a request is complex, we may take two more months, and we tell you so within the first month. We may first ask you to confirm the request from the e-mail address we know.
• Deleting has limits: we keep what the law obliges us to keep and what we need as proof in a dispute (3.3, 3.6), and nothing more.
• You can complain to the Romanian data protection authority, ANSPDCP: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, Romania, anspdcp@dataprotection.ro, dataprotection.ro; or to the data protection authority of the EU country where you live or work.

9. No automated decisions about you

We make no decisions about you based only on automated processing that have legal or similarly significant effects, and we do no profiling. The licence checks only apply the contract you made: for example, a refunded licence ends. When the same licence runs in two homes, nothing is blocked automatically. If you think a licence state is wrong, write to support@nucleumhub.com: a person looks at it.

10. Cookies and local storage

We need no cookie banner, because we store or read nothing on your device except what is strictly needed for a service you ask for (Romanian Law 506/2004, art. 4).

Cloudflare's bot protection that sets the __cf_bm cookie stays switched off; if we ever switch it on, we list it here first. There is no customer area with a sign-in yet; when there is one, we describe it here before it opens.

11. How we protect your data

All traffic is encrypted. In our database, licence keys, renewal codes, IP addresses and the e-mail addresses in our logs are kept only as keyed fingerprints, never in clear. Access to our server and to the support tools is limited to the author, with two-factor sign-in. If a breach puts your data at risk, we tell the authority within 72 hours and, where the risk is high, we tell you too.

12. Changes to this notice

We publish every new version on this page, with its date. If a change affects how we use data we already hold about you, we tell you by e-mail first.

13. Contact

Iulian Maracineanu, Strada Califarului, Pantelimon, județul Ilfov, România · privacy@nucleumhub.com