PRIVACY NOTICE - Hit the Lens Plugin 0.9.0-beta (free beta)

Notice for the free public beta of Hit the Lens Plugin, a test version free of charge until 31 January 2027 inclusive. It covers the data we collect at download and the files the program leaves on your computer.

Notice version: 2026-09-16. Information under art. 13 of Regulation (EU) 2016/679 (GDPR).

This notice explains which personal data we process when you download and use the free beta of Hit the Lens Plugin, why, for how long, and what your rights are. In short: at download you give us your e-mail and your type of photography work; your photos never leave your computer; the program sends no telemetry.

1. Data controller

The data controller is DIGITAL INDEX (hereinafter "DIGITAL INDEX"), Via della Vite 30, 41121 Modena (MO), Italia, VAT no. IT02271330363, e-mail fadege@gmail.com, phone +39 3393277864. For any privacy question or to exercise your rights, write to fadege@gmail.com. No data protection officer (DPO) has been appointed, because the controller's activities are not among the cases in which art. 37 GDPR makes one mandatory.

2. Data collected at download

To download the beta you fill in a short form.

• Required data: e-mail address; type of photography work, chosen from a list (festival and red carpet, events, weddings, portrait, sport, other); confirmation that you accept the beta terms and have read this notice; separate acceptance of the limits of the test version.
• Optional data: consent to receive promotional messages (clause 4).
• We also record the date and time of the confirmations and the version of the texts accepted, so that we can prove the consents.

The form is run by Polar (clause 5) or, if Polar is not available, by a fallback form on the fadege.it website (clause 6). As with any web page, the server that answers also receives the IP address, the date and time and the technical data of the browser.

3. Why we use the data, and on what legal basis

• Giving you access to the beta (download link, managing your registration). Legal basis: performance of the beta terms you accept (art. 6(1)(b) GDPR).
• Service messages about the beta: the notice that the beta is about to end, important updates (for example the fix of a bug that could damage files), changes to the terms. They contain no commercial offers. Legal basis: performance of the beta terms (art. 6(1)(b) GDPR).
• Promotional messages, including the EUR 19 discount code for the paid version reserved to beta users: only with your optional consent (art. 6(1)(a) GDPR and art. 130(1) and (2) of Italian Legislative Decree 196/2003); details in clause 4.
• Understanding in which photography genres the beta is used and reading feedback by genre, in aggregate form. Legal basis: the controller's legitimate interest in improving the product (art. 6(1)(f) GDPR).
• Answering your support requests and the support files you send us. Legal basis: performance of the beta terms (art. 6(1)(b) GDPR).
• Security and operation of the fadege.it website (server logs). Legal basis: the controller's legitimate interest in protecting and running its systems (art. 6(1)(f) GDPR).
• Proving consents, complying with legal obligations and defending legal claims. Legal basis: legal obligation (art. 6(1)(c) GDPR) and legitimate interest (art. 6(1)(f) GDPR).

We take no decisions based solely on automated processing and we do no profiling (art. 22 GDPR).

4. Promotional messages and the EUR 19 code

We write to you to promote the paid version (for example with the EUR 19 discount code for beta users) only if you ticked the optional checkbox. We do not use the so-called "soft spam" exception (art. 130(4) of Italian Legislative Decree 196/2003), because it covers e-mail addresses provided in the context of the sale of a product or service, while the beta is free and is not a sale. Consent is not a condition for receiving the beta (art. 7(4) GDPR): if you do not give it, you download and use the beta in the same way. You can withdraw it at any time with the unsubscribe link in every promotional e-mail or by writing to fadege@gmail.com; withdrawal does not make earlier processing unlawful (art. 7(3) GDPR).

5. Polar, the download form platform

The main download form is a free product on the Polar platform, operated by Polar Software, Inc., 3500 South DuPont Highway, Dover, DE 19901, United States. Polar collects the e-mail and the form answers and makes them available to the controller. Under Polar's Data Processing Addendum (last updated 9 June 2026), for these data the seller using Polar is the controller and Polar is the processor (art. 28 GDPR). Under Polar's privacy policy (effective 8 September 2026), Polar is instead the controller of the other information it collects through its own website and customer-facing activities, and Polar's buyer terms state that Polar processes personal data in accordance with its own privacy policy: for those activities Polar acts as an independent controller. Polar documents: privacy policy https://polar.sh/legal/privacy; Data Processing Addendum https://polar.sh/legal/data-processing-addendum; list of sub-processors https://polar.sh/legal/sub-processors.

6. Fallback form on fadege.it

If Polar is not available, the download goes through a form on the fadege.it website, which stores e-mail, type of work, confirmations and consents in a small database on a server managed by the controller through the Plesk panel. We will tell you the hosting provider and the country where the server is located on request, by writing to fadege@gmail.com. In this case the data do not go through Polar.

7. Who receives the data, and transfers outside the European Union

We do not sell or hand over your data. They may be processed, only for the purposes of this notice, by:

• Polar Software, Inc. and its sub-processors, mostly in the United States and some in the United Kingdom (clause 5);
• the hosting provider of the fadege.it website;
• Google, which provides the fadege@gmail.com mailbox the controller uses for correspondence;
• the mail service provider used to send service and promotional e-mails;
• advisers and authorities, where the law requires it.

For transfers to the United States made by Polar, Polar's Data Processing Addendum applies the European Commission's Standard Contractual Clauses (Module 2, controller to processor). For the other providers, if they transfer data outside the European Union, we will state the transfer mechanism here; in the meantime you can ask us for the details by writing to fadege@gmail.com.

8. The program: analysis only on your computer, no telemetry

Hit the Lens Plugin analyses photos only on your computer. No photo, preview, file name or analysis result is sent to DIGITAL INDEX or to third parties. The program contains no telemetry, usage statistics or automatic error reporting, and it requires no account and no licence key. The network checks made during development found no connections opened by the analysis engine while it was analysing photos.

9. New version notice

In this beta the program does not check online for a new version: it contacts neither fadege.it nor any other server, and it downloads and installs nothing by itself. We tell you about new versions only by e-mail, with the service messages described in clause 3. An automatic update check is planned only for the future paid version: if it is introduced, this notice will be updated first.

10. Files the program keeps on your computer

The program keeps, only on your computer:

• the XMP files next to the photos and, in the session folder, the file hitthelens_undo_log.json holding the history needed to undo an analysis (next to it, while an analysis is running, an empty hitthelens_undo_log.json.lock file that stops two analyses started at the same time from damaging that history); sessions analysed with earlier versions hold the same file under its name at the time, eyecontact_c1_log.json, which the program still reads and renames at the first new analysis;
• the safety copies of the XMP files taken before changing them, which are what lets undo put them back byte for byte, in %LOCALAPPDATA%\HitTheLens (deleted on their own when the matching analysis is undone);
• the settings, in %APPDATA%\HitTheLens;
• the run logs (commands, arguments including folder paths, outcomes and errors; at most 30 files or 50 MB), in %LOCALAPPDATA%\HitTheLens.

These files are not sent to anyone. Uninstalling does not delete them, so an update or a reinstall does not lose settings and history: you can remove the settings, the logs and the safety copies by deleting the two folders, and the undo history by deleting hitthelens_undo_log.json in the session folder.

11. Support file

The support file is created only when you ask for it in the program, and it is saved on your computer: the program does not send it. It contains the run logs, the settings, the version of the program and of its components, the build type and the detector used, the Windows version, the language, the licence state (without key or signature) and the integrity check of the analysis models. Folder and file paths are replaced by hash codes computed with a random value that is not saved in the file (only the folder depth and the file extension stay visible). It contains no photos, no Windows user name and no machine identifier. It reaches us only if you decide to attach it to an e-mail: in that case we use it only to solve the problem you report, and we delete it within 90 days after the request is closed.

12. How long we keep the data

• E-mail, type of work and confirmations for beta access and service messages: until 6 months after the end of the beta (31 January 2027), then we delete or anonymise them.
• Data for promotional messages: until you withdraw consent, and in any case no longer than 24 months after you last opened or used one of our e-mails.
• Proof of consents (date, time, text accepted): for as long as the processing they refer to lasts, and then for the time needed to defend against a claim.
• fadege.it server logs (download page): for the retention period set by the hosting provider; you can ask us about it by writing to fadege@gmail.com.
• Support e-mails and support files: see clause 11.
• Data Polar processes as an independent controller: according to Polar's privacy policy.
• Files on your computer: until you delete them (clause 10).

13. Required and optional data

E-mail, type of work and acceptance of the terms are needed to conclude the beta agreement: without them you cannot download it (Polar also always requires an e-mail to complete the form). Consent to promotional messages is optional and refusing has no consequences. Using the program does not require any other data.

14. Your rights, and complaints

By writing to fadege@gmail.com you can ask at any time for: access to your data and a copy of them (art. 15 GDPR); rectification (art. 16); erasure (art. 17); restriction of processing (art. 18); portability of the data you provided to us (art. 20). You can object to processing based on legitimate interest (art. 21(1)) and, always and without giving reasons, to promotional messages (art. 21(2) and (3)); you can withdraw consent (art. 7(3)). We answer without undue delay and in any case within one month (art. 12(3)). If you believe the processing infringes the GDPR you can lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (art. 77 GDPR): in Italy it is the Garante per la protezione dei dati personali, https://www.garanteprivacy.it. You may also go to court.

15. Changes to this notice

If we change the way we process data we update this notice and its version date; if the change is significant we tell registered users by e-mail before it applies. This notice exists in Italian, English and French with the same structure.

End of notice. Text generated automatically (version of 2026-09-16).