Privacy policy
Last updated: October 21, 2026
Draft: the highlighted details are still to be filled in before the site goes live.
This policy explains what personal data the UPAN website (upan.tools) collects, why, who else sees it, how long we keep it and what you can do about it. We collect as little as we can: no analytics, no advertising, no tracking cookies, no third-party scripts.
Who is responsible
The controller of your data is Kyrylo Beliaiev s.p., [to be added: address], Slovenia — the maker and seller of UPAN. Write to [to be added: privacyEmail] about anything in this policy. We answer within one month.
In short
| What you do | What we keep | Why |
|---|---|---|
| Join the waitlist or press “Notify me” | Email, product, country, what you want to automate | To tell you when it is available — with your consent |
| Buy | Order, email, country, VAT ID if given; Stripe keeps the card and the address | To deliver the order and to keep the books |
| Create an account | Email, and what you add: name, company, VAT ID, language, newsletters | To show your orders, devices and tickets |
| Register a device | The link between your account and the serial number | Firmware news, security bulletins, support |
| Open a support ticket | Email, name if given, messages, attachments, device and order | To help you, and for warranty claims |
| Talk to the agent | Your messages and its answers, the packages it builds | To answer you — and our team reads conversations to improve the agent and UPAN |
Looking at products, reading the documentation, trying presets and the simulator, and opening a device page from its QR code need no personal data.
What we collect and why
Waitlist and “Notify me”
Your email, the product you are waiting for, your country, the language of the site and, if you write it, what you want to automate. Nothing counts until you confirm the address with the link we send (double opt-in).
Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time by writing to us.
Orders and payment
The order itself (products, prices, VAT, shipping zone, country), the email you paid with and the VAT ID if you entered one. Payment runs on Stripe: your card details, name and delivery address are entered on Stripe’s page and stay with Stripe; we see what we need to ship and invoice. Stripe Tax works out the VAT from your country and VAT ID. Your name and delivery address, and your email for delivery notices, go to DHL.
Legal basis: the contract (Art. 6(1)(b)) and our legal duty to keep accounting records (Art. 6(1)(c)).
Your account
You sign in with a link sent to your email — there is no password. The account holds your email and what you choose to add: name, company, VAT ID, language and the newsletters you want. Orders and tickets appear in it by your email address; devices, once you register them. Security bulletins for a device you registered are sent regardless of newsletter settings, because they concern the safety of the device.
Legal basis: the contract (Art. 6(1)(b)); security bulletins — our legitimate interest and duty to keep products safe (Art. 6(1)(f), Cyber Resilience Act).
Registered devices
When you register a UPAN by its serial number, we link that serial to your account. The device page behind the QR code on the enclosure never shows who owns the device. We never ask for, store or show the device password.
The agent
When you describe your project to the agent at /build, we keep the conversation: your messages, the agent's answers and the packages, wiring and parts lists it builds, with the time and what each answer cost us. Before you sign in, the conversation is tied to your browser by a random key in a cookie; signing in moves it to your account. If you take a virtual UPAN Core, we keep its serial with your account and an order for €0.
Our team reads these conversations to see where the agent is wrong or unclear, and to learn what people want to build. Please do not put passwords, Wi-Fi keys or other people's personal data into the chat.
The answers are written by Anthropic's Claude models: each message is sent to Anthropic to produce the answer. Under its commercial terms Anthropic does not use these messages to train its models.
Legal basis: answering you and building your package — the contract, or steps you asked for before one (Art. 6(1)(b)); reading conversations to improve the agent and the product — our legitimate interest (Art. 6(1)(f)). You can object to it by writing to us; we then leave your conversations out.
Support tickets
Your email, your name if you give it, the messages, the files you attach (photos, logs, PDFs) and the device and order you pick. Without an account you get a private link to the ticket by email; anyone with that link can read the ticket, so keep it to yourself.
Legal basis: the contract and warranty (Art. 6(1)(b)), or our legitimate interest in answering questions (Art. 6(1)(f)).
Emails
We send emails only when you ask for something (a confirmation, a sign-in link, an order or ticket update) or agreed to receive it. They go through Brevo (Sendinblue SAS, France).
Who else receives your data
We do not sell or share your data for advertising. These services process it for us:
- Stripe (Stripe Payments Europe Ltd., Ireland) — payments, VAT calculation, card data.
- DHL — delivery of your order.
- Anthropic (Anthropic PBC, USA) — writes the agent's answers from your messages.
- Email sending: Brevo (Sendinblue SAS, France).
- Hosting: Hetzner Online GmbH, Germany.
Stripe may transfer data to the United States; it does so under the EU–US Data Privacy Framework and the European Commission’s standard contractual clauses. Anthropic processes the agent's messages in the United States under the European Commission’s standard contractual clauses. All other data stays in the EU.
How long we keep it
| Data | How long |
|---|---|
| Unconfirmed waitlist or “Notify me” sign-ups | 30 days, then deleted automatically |
| Confirmed waitlist and “Notify me” | Until you ask us to remove it, or until we have told you the product is available |
| Orders and invoices | 10 years after the end of the year of the invoice — required by Slovenian VAT law |
| Account | Until you delete it. Your orders stay (see above) |
| Sign-in links | 20 minutes; deleted within a day |
| Sign-in on a browser | 30 days, or until you sign out |
| Support tickets and attachments | 3 years after the ticket is closed, then deleted automatically |
| Conversations with the agent before signing in | 90 days after the last message, then deleted automatically |
| Conversations with the agent in your account | Until you delete the account |
| Copies of emails in the sending queue | 7 days after sending; an email that could not be sent, up to 14 days |
| Web server logs | [to be added: serverLogs] |
Cookies and storage in your browser
We only use what the site needs to work, so there is no cookie banner.
| Name | What for | How long |
|---|---|---|
upan_session (cookie) |
Keeps you signed in to your account | 30 days, or until you sign out |
upan_admin (cookie) |
Signs in our staff to the admin; never set for customers | 12 hours |
upan.cart.v1 (local storage) |
Your cart; it stays in your browser and is not sent to us until you check out | Until you empty the cart |
Stripe’s payment page is Stripe’s own site and sets its own cookies for fraud prevention. Fonts are served from our own server; we load nothing from Google or other third parties.
Your rights
You can ask to see your data, to correct it, to delete it, to restrict or object to its use, and to get it in a portable form. In your account, Profile and data lets you download everything we hold about you and delete the account yourself. For anything else, write to [to be added: privacyEmail].
If you think we handle your data wrongly, you can complain to the Slovenian supervisory authority, the Information Commissioner (Informacijski pooblaščenec, Dunajska cesta 22, 1000 Ljubljana, www.ip-rs.si), or to the authority in your country.
Security
Sign-in links, sessions and ticket keys are random and long; sign-in links and sessions are stored only as hashes. Admin access needs a password and a code from an authenticator app. Attachments are checked by their content and served so that they cannot run as a web page.
Children
The site is for people who build machines and is not aimed at children under 16.
Changes
When we change this policy, we update the date below. If a change affects how we use data you already gave us, we tell you by email first.