Privacy Policy

Effective date: 2026-08-07

This policy explains what personal information Zmina collects, why, and what you can do about it. It covers the Zmina website at zmina.app, our two email lists (the pre-launch waitlist and the optional product-updates list, which anyone can join), purchases of the Zmina app, and the app itself.

Who we are

Zmina is developed and sold by Mykhailo Onikiienko, a sole proprietor in British Columbia, Canada.

For privacy questions or requests, contact privacy@zmina.app.

What we collect and why

We keep this short on purpose: we collect as little as possible, and only where there is a clear reason.

If you joined the waitlist

We are no longer accepting new waitlist signups. If you joined before launch, we hold:

Your email address
Your IP address and a timestamp, as the record of your consent (required under CASL and GDPR)
The page or referrer you came from, when available

Nothing else. We do not record your browser or device.

We use this only to send you the launch announcement, and at most one further email about a major v1.1 update. That is the entire waitlist contract: two emails at most. We do not send anything else to this list.

Anyone can choose to receive occasional product-update emails (new releases, notable features, new add-ons), whether or not you own Zmina. This is optional and self-service: you sign up only if you want to, and it is never required to buy or use the app.

If you opt in, we collect:

Your email address
Your IP address and a timestamp, as the record of your consent
The page or referrer you came from, when available

Nothing else. We do not record your browser or device.

Your subscription is confirmed by a double opt-in: you click a link in a confirmation email before we add you. This list is kept entirely separate from the waitlist and is never merged with it. You can unsubscribe from any email at any time, with a one-click link in every message.

If you buy Zmina

Your purchase is handled by Kelviq, our payment provider and Merchant of Record (see “Who else can see your information”). From your purchase we receive only your email address, your order identifiers, and which product you bought, which we use to generate and deliver your license and to keep a record of the sale.

We never receive or store your card number or full payment details. Those are collected and handled by Kelviq under its own privacy policy.

If you use the license recovery page at zmina.app/recover, the email address and order number you enter are used to find and re-send your license. To limit abuse, recent recovery requests are remembered for a short time (minutes, not days).

When you use the Zmina app

The Zmina app collects nothing and sends nothing about you. It runs on your device, with no account, no telemetry, and no analytics.

There is one exception, and it is under your control: the app’s updates. Update checks are on by default, the app tells you about them the first time you run it, and you can turn them off at any time in the app’s settings. When on, the app downloads a couple of small static files from releases.zmina.app, the version information and any security advisory for your version, and checks them on your own device. By default it goes one step further: when a newer version exists, the app downloads the signed release and installs it the next time you quit, so you stay current without doing anything (you can switch this to manual in the app’s settings, in which case the app only tells you an update is ready). Every one of these requests, the version check, the advisory, and the release download, carries no information about you or your license. Your IP address is visible to our content delivery network (Cloudflare) as it would be for any web request; like any site host, Cloudflare can count requests in aggregate, but nothing in a request identifies you, and we do not use these logs for analytics. If you turn update checks off, the app stops making network requests on its own. A “Check for updates” button stays in the app’s settings so you can still fetch a security advisory deliberately; nothing is sent unless you press it.

Your license file is stored only on your device. It contains your email address, unencrypted, so the app can show “Licensed to you” in its settings. That file never leaves your computer, and we do not receive it.

If you email us

Writing to any of our addresses at zmina.app (support@, privacy@, security@, or a personal one like mykhailo@) sends us your email address and whatever your message contains. We use it only to answer you, and you can ask us to delete it at any time (see “Your rights”). If you attach the app’s bug-report bundle, it carries technical logs only; the app never writes what you copy into its logs, and you can open the bundle and remove anything before sending.

Legal basis

For the email lists, our basis is your consent, established when you confirm your subscription (CASL; GDPR Article 6(1)(a) for EU and UK residents). You can withdraw it at any time using the unsubscribe link in any email, or by emailing privacy@zmina.app.
For purchases, our basis is performance of our contract with you, to deliver and support your license (GDPR Article 6(1)(b)), and legal obligation, to keep the sales records that tax and business law require (Article 6(1)(c)).
For the app’s updates (the check, and the automatic download and install of new versions), our basis is legitimate interest (GDPR Article 6(1)(f)): keeping software you installed secure and up to date, which the GDPR itself (Recital 49) recognizes as a legitimate interest in network and information security, and which covers applying updates, not just checking for them. These requests send no identifiers, and you can object at any time by turning them off in the app’s settings, after which the app initiates no request of any kind. (A manual “Check for updates” button remains available so that objecting never costs you access to a security advisory. It acts only when you press it.)
For email you send us, our basis is our legitimate interest in reading and answering it (GDPR Article 6(1)(f)).

Who else can see your information

We rely on a small number of providers to operate:

Kelviq, Inc. (payments), our Merchant of Record, processes your purchase and receives the information needed to complete and tax it. It is an independent controller of that payment information under its own privacy policy: https://www.kelviq.com/buyer-privacy/.
Emailit (email delivery) receives your email address to send confirmation, launch, and product-update emails.
Cloudflare (hosting, database, and content delivery) stores our data and serves the site and downloads on its infrastructure.

None of these sells your data or uses it for advertising. We do not share your information with anyone else.

Where your information is processed

We operate from Canada, which the EU recognizes as providing adequate protection for data handled in commercial activity. Our email provider, Emailit, is based in the European Union and states that it does not move personal data outside it. Cloudflare and Kelviq are United States companies, so data they handle can be processed in the United States and other countries: Cloudflare under its data processing terms with us, which include the EU’s standard contractual clauses, and Kelviq as an independent controller under its own privacy policy.

How long we keep it

Waitlist: kept until we have sent the launch announcement and any v1.1 announcement, and then for at least 60 days after that final email, because the unsubscribe link in it has to keep working for that long under CASL. After that we delete the list. If you unsubscribe sooner, your record is deleted within 30 days. Unconfirmed signups are deleted automatically after 7 days.
Product-updates list: kept until you unsubscribe, after which your record is deleted within 30 days. Unconfirmed signups are deleted automatically after 7 days.
Purchase records: kept for as long as Canadian tax and business-records law requires (generally six years from the end of the relevant tax year), then deleted. We keep these even if you unsubscribe from emails, because we are legally required to.
License records: kept for as long as your license is valid, so we can re-send your license if you ever lose it. For a perpetual license that means we keep it until you ask us to delete it, which you can do at any time, understanding that we then cannot recover a lost license for you.
The app: we hold nothing. Your license file stays only on your device.

Children

Our site and email lists are not directed at children under 16, and we do not knowingly collect their information. If you believe a child has subscribed, email privacy@zmina.app and we will delete the record.

What we do not do

We want to be specific, because it is the point:

No analytics. No Google Analytics, Plausible, Fathom, or anything like them, anywhere on this site.
No tracking cookies. This site uses no cookies for tracking. Any cookie that exists is there only to make the site work.
No advertising and no ad pixels. No Facebook pixel, no Google tags, no LinkedIn insight tag, nothing of that kind.
No hidden or pre-checked sign-ups. Our only marketing list is the optional product-updates list, and you are on it only if you asked to be and clicked the confirmation link. We never pre-check a box, auto-subscribe you after a purchase, or buy or rent email lists. If you would rather follow Zmina with no email at all, the changelog has an RSS feed that needs no address.
No selling or trading of personal information. Ever.
No telemetry in the app. The app never sends data about you or how you use it. Its only network activity is the update cycle described above, the check plus the download and install of new versions, none of which carries identifiers, and all of which the app stops doing on its own if you turn it off.

Your rights

Under CASL, GDPR, and BC’s Personal Information Protection Act (PIPA), you have the right to:

Access the personal information we hold about you
Correct inaccurate information
Receive a copy of the information you gave us, in a portable format
Delete your information (subject to records we must keep by law, such as purchase records)
Withdraw consent to further email
Restrict our use of your information while a request is being resolved
Object to specific uses

To exercise any of these, email privacy@zmina.app. We respond within 30 days, at no charge.

You also have the right to complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or your local data protection authority.

Changes to this policy

If we change this policy in a way that materially affects how we use your information, we will note it here with a new effective date. Where a change affects an active email subscription, we will tell affected subscribers by email and give you the chance to withdraw consent first.

Smaller, non-material changes (clarifications, contact updates) are reflected here with a new effective date.

Contact

privacy@zmina.app for anything about this policy or your personal information. Mykhailo Onikiienko is the designated privacy officer for Zmina.

For general inquiries: support@zmina.app.

Zmina · developed and sold by Mykhailo Onikiienko · British Columbia, Canada