# Privacy Policy — lake8.dev **lake8.dev** (entity in the process of incorporation) Contact: legale@lake8.dev Version 1.0 — April 2026 --- ## 1. Data Controller The controller of personal data processing is **lake8.dev** (an entity in the process of incorporation), operating under the lake8.dev trade name, reachable at the electronic address **legale@lake8.dev**. --- ## 2. Data Collected When registering with the lake8.dev licensing system, we collect only the following data: | Data | Nature | Purpose | |------|--------|---------| | Company name | Public data (Business Register) | Identification of the licensee | | VAT number / Tax code | Public data (Business Register) | Verification of the legal entity via VIES | | Contact person's first and last name | Personal data | Communications relating to the licence | | Email address | Personal data | Sending the activation token and service communications | | Installer's VAT number | Public data (if provided) | Association with the certified installer | | Machine ID | Anonymous technical identifier | Binding the licence to the specific device | | Software version | Technical data | Compatibility management and support | **We do not collect** data relating to: - Production or management data processed by the installed software - Data of the licensee's own customers - Banking or payment data (in the current beta phase) - Browsing data or profiling cookies - Geographic location --- ## 3. Self-Hosted Nature of the Software lake8.dev products (MRP Scheduler, Business Intelligence Lake8 and others) are distributed on a **self-hosted** basis: the software is installed and run exclusively on the licensee's own servers and computer systems. **lake8.dev has no access**, in any form or manner, to the production, management or any other data processed by the licensee through the software. Such data remains entirely at the disposal of and under the exclusive control of the licensee, who is its sole data controller. --- ## 4. Purposes of Processing The data collected is processed solely for the following purposes: - **Licence management**: registration, activation, renewal and revocation of the software licence - **Service communications**: notices about licence status, upcoming expiry dates and updates to the Terms of Service - **Legal entity verification**: checking the VAT number through the European Commission's VIES system - **Technical support**: assistance relating to licence activation and operation - **Reseller management**: association of the licence with a certified lake8.dev installer, where indicated - **Legal compliance**: fulfilment of applicable regulatory obligations --- ## 5. Legal Basis for Processing The processing of personal data is based on the following legal grounds pursuant to Article 6 GDPR: - **Performance of a contract** (Art. 6(1)(b)): processing is necessary to manage the licence relationship - **Legal obligation** (Art. 6(1)(c)): compliance with applicable regulatory obligations - **Legitimate interest** (Art. 6(1)(f)): prevention of fraudulent use of the licensing system --- ## 6. Method of Processing and Retention Data is processed by means of computer systems with adequate security measures and retained for the entire duration of the licence relationship and for any subsequent period required by applicable law. Data is stored on servers located in Italy (a Raspberry Pi at the controller's operating premises) with access restricted to authorised personnel only. **Machine ID and licence tokens** are stored locally on the licensee's device. The controller retains in its own system only the Machine ID necessary to bind the licence, with no further information about the device. --- ## 7. Disclosure of Data to Third Parties Personal data is **not sold, assigned or disclosed to third parties** for commercial or profiling purposes. Data may be disclosed exclusively to: - **Certified lake8.dev installers**: limited to the data necessary to manage the support relationship (company name, contact person's email), and only where the licensee has explicitly indicated an installer at registration - **Technical service providers**: email providers used to send service communications, bound by confidentiality agreements - **Competent authorities**: in the cases expressly provided for by law --- ## 8. Rights of the Data Subject The data subject has the right to: - **Access** (Art. 15 GDPR): obtain confirmation of processing and a copy of the data - **Rectification** (Art. 16 GDPR): correct inaccurate or incomplete data - **Erasure** (Art. 17 GDPR): request deletion of the data, subject to retention obligations - **Restriction** (Art. 18 GDPR): restrict processing in certain cases - **Objection** (Art. 21 GDPR): object to processing based on legitimate interest - **Portability** (Art. 20 GDPR): receive their data in a structured format To exercise these rights, the data subject may send a written request to **legale@lake8.dev**. The controller will respond within 30 days of receipt. The data subject also has the right to lodge a **complaint with the Italian Data Protection Authority** (www.garanteprivacy.it). --- ## 9. Cookies and Tracking Technologies The lake8.dev licensing system uses only: - **Technical session cookies**: necessary for the operation of the administration panel (authentication). They do not persist beyond the session. - **No profiling cookies** or third-party tracking. --- ## 10. Changes to the Privacy Policy The controller reserves the right to amend this Privacy Policy at any time. Changes will be communicated through: - Email notice to the address provided at registration - Update of this page with a new version date Continued use of the software after the changes have been communicated constitutes acceptance of the new version. --- ## 11. Governing Law This Privacy Policy is governed by Italian law and by Regulation (EU) 2016/679 (GDPR). Any dispute falls within the jurisdiction of the court of the place of the controller's operating office. In the event of any discrepancy between the Italian version and this translation, the Italian version prevails. --- **lake8.dev** (entity in the process of incorporation) legale@lake8.dev *Last revised: April 2026 — Version 1.0*