Privacy

This page is about this website. It is not about Culma itself. When you use Culma, your notes are encrypted on your own device and our server holds sealed bytes it cannot read — what it stores, what we can read and for how long is set out on the security page, and business customers also receive a processing agreement. This page covers what happens when you visit culma.eu and when you buy.

Who is responsible

ZNIPP GmbH, Underschwändlistrasse 10, 6048 Horw, Switzerland (CHE-105.642.181). Culma is a product of ZNIPP GmbH. Write to contact@znipp.ch or call +41 41 589 80 75; the full company details are in the legal notice.

When you open a page

Our server receives your IP address, which page you asked for, your browser's identification, the page that referred you if there was one, and the languages your browser says it accepts. It cannot answer you without the first of these.

These appear in the web server's access log. We use it to run the site and to look into faults and attacks, and we keep it for 14 days. We do not claim to log nothing — we log this, and this is the list.

The site runs on servers operated by Hetzner Online GmbH in Germany.

Legal basis: Art. 6(1)(f) GDPR — our interest in a working, secure website. In Switzerland: Art. 31(1) FADP.

The language and currency you see

We work out which country you are in so that prices appear in the right currency, and which language to show you.

The country is determined by looking your IP address up in a database file stored inside our own server. No request leaves our server to do this, and nothing about the lookup is stored. The language comes from the Accept-Language header your browser already sends.

If you choose a different country or language, we remember the choice in two cookies, culma_lang and culma_country. Each holds two letters. They contain no identifier, they are set by this site and by nobody else, and they expire after a year. They exist so that the page you asked for is the page you get, which is why there is no cookie banner on this site: there is nothing to consent to. (§ 25(2) TDDDG; Art. 6(1)(f) GDPR.)

Whether you chose the light or the dark theme is kept by your browser in its own storage, under culma_theme. It is never sent to us.

When you start a trial

A trial includes syncing, and syncing needs an account — the server has to know whose seat it is. So a trial asks for an email address and nothing else: no card, no name, no company, no address. You give it to us directly rather than through anybody else, and we use it for the things in the next section.

The free app on one device asks for none of this. No account, no address, nothing sent to us at all.

When you buy

Licenses are sold by Paddle.com Market Limited, United Kingdom, which is the merchant of record: it sells to you in its own name, takes the payment, issues the invoice and accounts for the tax. The checkout is Paddle's own, and it runs on a separate address of ours (buy.culma.eu) rather than on this site — which is what keeps the paragraph below true for everybody who is only reading.

Paddle receives what a sale requires: your name, your email address, your country, your payment details and what you bought. We never receive your card details. Paddle is responsible for that processing in its own right, under its own privacy notice.

From Paddle we receive your email address, your name, your country and what you bought, so that we can give you your license and support it. Legal basis: Art. 6(1)(b) GDPR — performing the contract — and Art. 6(1)(c) for what invoicing and bookkeeping law requires us to keep.

When we write to you

We use the address you gave us — for a trial or a purchase — for these things, and this is the whole list: sending you your license, telling you before these terms or a renewal price change, warning you before the server's copy of a lapsed subscription is deleted, reaching you about a security problem you need to know about, and answering you when you write.

It is never a channel for anything inside a vault. We cannot see what you write or when, and we do not use a billing address to report that something changed in a vault — that would join the payment to the activity, which is the join this architecture exists to prevent. The app does that on your own device.

And it is joined to nothing on the storage side. Our billing records hold no vault, folder or storage identifier. The server that stores your sealed bytes never receives your email address. The tokens your devices present to that server are signed without us learning which device asked for them. A payment and a stored byte therefore cannot be set side by side, by us or by anybody who takes the billing database.

No marketing mail unless you ask for it, and no newsletter at all today.

What this site does not do

No analytics of any kind. No tag manager, no advertising pixels, no cross-site tracking. No fonts, scripts or styles loaded from anyone else's server. No embedded video, no social media widgets, no error-reporting service, no A/B testing. Nothing on this site makes a request to a third party while you are reading it — the checkout is a page of its own, at its own address, reached only when you decide to buy.

There is no contact form and no booking tool: the way to reach us is the email address and the phone number above.

The browser version of Culma

demo.culma.eu is the application rather than this website, and what it does is described on the security page: a vault created in your browser, encrypted in your browser, in your browser's own storage.

Links that leave this site

The download page links to the Apple App Store, Google Play and the Microsoft Store. Those are other companies' sites and their own privacy notices apply once you follow the link; we learn nothing about whether you did. Our own downloads are served from our own infrastructure. Buying leaves this site too, for the checkout described above.

When you write to us

If you email us, we keep the message and your address so that we can answer, and for as long as the matter is live. Legal basis: Art. 6(1)(b) and (f) GDPR.

Who else is involved

Two companies, and no others, are involved in running this site and selling through it:

Who	Where	What for
Hetzner Online GmbH	Germany	the servers this site runs on
Paddle.com Market Limited	United Kingdom	the sale: checkout, invoice, tax, payment

What the Culma service itself involves is a separate and equally short list, on the security page.

Where your data goes

Our company is in Switzerland, our servers are in Germany, and the sale goes through the United Kingdom. The European Commission has recognized both Switzerland and the United Kingdom as providing an adequate level of data protection, so no further instrument is needed for data moving from the EU to either. We use no sub-processor controlled from outside Europe for this website.

Your rights

You can ask us what we hold about you, have it corrected or deleted, ask us to restrict how we use it, object to our using it, and ask for a copy in a portable form. Write to contact@znipp.ch and we will answer.

If you are in the EU or the EEA, these are Arts. 15 to 21 GDPR, and you may complain to the supervisory authority of the country where you live or work. If you are in Switzerland, these are Arts. 25 and 32 FADP, and you may contact the Federal Data Protection and Information Commissioner (FDPIC) in Bern.

What Paddle holds as the seller is Paddle's to answer for, and its privacy notice says how to ask.

Changes to this page

We date this page and keep its previous versions. If something here stops being true, it is corrected here first.