Privacy notice
Version 2026-10-19. This notice is about the Selmion website, selmion.pages.dev. The Selmion software has its own Terms of Use (version 2026-10-19) and its own data statement.
1. Who we are
This notice is about the Selmion website, where a business can read about Selmion, ask for a demo and ask to buy it. "We" and "us" mean David Balazs Horvath, trading as Selmion, of Clemence Suits, 504 Devil's Tower Road, Gibraltar GX11 1AA, who decides why and how the personal data described here is used (the "data controller"). You can contact us at davehorvath7@gmail.com.
2. What this notice covers, and what it does not
It covers this website and the emails that follow from it.
The Selmion software runs on your computer and makes no network connection. It never sends anything to us by itself. If a person chooses to email or save a problem report or a file reading report, we receive what that report shows. A file reading report holds only the layout of the file unless the person ticks the box to include its first lines. Those lines, up to 40, can include medicine names, quantities and supplier details. Section 5 of the Terms of Use and the Selmion data statement say exactly what each report can contain, and the person can read it on screen first.
We do not otherwise receive delivery data from the software. We read the activity record kept inside the software only to diagnose a fault in Selmion or a dispute between you and us about its use, only when the licensee (the business) has agreed by email and the computer concerned is made available to us, and we keep no copy unless the licensee agrees in writing (Terms of Use, section 6).
3. What this website does and does not collect
This website is a set of ordinary pages. It has no accounts, no sign-in, no forms that send data to us, and no cookies. It uses no analytics, advertising or tracking, and it loads nothing from other websites. The demo page writes an email for you in your own browser. We receive it only if you send it.
Cloudflare, which hosts the website, handles the network address and details of each request in order to deliver and protect the site, under its own terms. We do not receive those records, and we do not use them beyond the summary figures that Cloudflare's dashboard shows.
4. What we collect, where it comes from, why, and on what basis
| What | Where it comes from | Why | Basis |
|---|---|---|---|
| Business name, premises address, country | You, in your demo request email | To check that the business is real and to name the demo licence | Taking steps at your request before a contract. Where the business is a sole trader or a partnership this is personal data. |
| The name of the register and the registration or licence number | You | To look the business up, and to refuse a second demo for the same registration | The same, and our legitimate interest, explained below |
| A copy of a business licence, if you send one | You | A person checks it when no online check is possible | The same |
| Your name and email address | You | To reply, to send the demo or licence file, and to send notices | The same, and our legitimate interest in running the service |
| Licence records: the licence reference number, type, dates and the business it names | Us | To provide and renew licences and keep proof of what was issued | Contract, and our legal obligation to keep records |
| Order and payment records: the order form, the invoice, the amount, currency and date, and the details shown on the bank or PayPal record of a payment | You, and your bank or payment provider | To invoice, to match payments and to keep tax records | Contract, and our legal obligation to keep accounting records |
| Reports you choose to send us | You | To deal with the problem and to improve Selmion | Your request, and our legitimate interest in fixing faults |
| Emails you send us | You | To answer them | Our legitimate interest, or your request |
Our legitimate interests are: stopping a business receiving repeated free demos, checking that a business is real before giving it a licence, running the service, fixing faults, answering your emails, and keeping records to deal with disputes. We have weighed these against your interests and rights, and you can object (section 9).
Do you have to give us this? Yes, to receive a demo or a licence. Without it we cannot check the business or issue a licence. You do not have to give anything else.
We do not use your data for advertising and we do not sell it. We send no marketing unless you ask for it.
5. How the check against the official register works
A person looks the registration number up at the official source for your country and compares the name, address and status. Nothing is decided by a computer on its own. We use only what we need to compare the name, address and status of the business.
If there is no online register for your country, or the result is unclear, we may ask you for a copy of your business licence, and a person checks it. If we cannot verify the business, we refuse the demo and tell you why, and you can ask us to look again. Refusing a demo has no legal effect on you beyond not receiving it.
The lookup tells the register that someone asked about that number.
6. How long we keep it
| What | How long |
|---|---|
| The registration number | Deleted from our email and notes as soon as the check is finished, and in any case within 30 days of receiving it. We keep only a coded fingerprint of it, on our own computer: the number combined with a secret key that we hold, so that someone who obtained only our list of fingerprints could not recover the numbers without the key. We cannot read the number back from the fingerprint, but we can recognise the same number again. The fingerprint is kept in a ledger with the business name, the licence reference and the dates of the demo, for 3 years after the demo ends, because without it we could not refuse a second demo to the same registration. |
| A business licence document you sent | Deleted as soon as a person has decided, and in any case within 30 days of receiving it. The reply we send you stays in our mailbox with the other correspondence. |
| The licence file and the package we send you | We keep a copy of the licence file and of the package we send you (the Selmion file with your licence inside, which names the business and holds no delivery data), with the licence reference, type and dates, as licence records (below). The email we send you, with the package attached, is kept with the record it belongs to. |
| Business name, address, contact name and email, and licence records (the register of licences, the licence files and the packages we sent) | While a licence exists and for 6 years after it ends, for accounting records and disputes. For a demo that does not become a licence, 12 months after it ends, apart from the ledger entry described in the first row. |
| Order and payment records | 6 years, as accounting records. |
| Reports you send | Only as long as needed to deal with the problem, then 6 months. |
| Emails to us | With the record they belong to, for the period shown for that record. Other emails are deleted after 12 months. |
Copies of these records may also sit in our own backups. When we delete a record we delete it from our backups the next time we make one. You can ask us to delete your data sooner. We will do so unless we must keep it, for example for tax records or to stop a business receiving a second demo.
7. Who else handles it
- Cloudflare, which hosts this website.
- Google (Gmail), which provides the mailbox we send and receive email with, including demo requests and any licence document you send.
- Your bank and ours, and PayPal if you pay that way, when you pay us.
- The official registers we look businesses up in, which learn the registration number we ask about.
- Our accountant.
We do not give your data to anyone else unless the law requires it, or to protect our legal rights.
8. Transfers outside Gibraltar, the UK and the EU
The providers above run services in several countries, including outside Gibraltar, the UK and the EU. Each publishes how it protects personal data that it moves between countries, for example by standard contractual clauses or an adequacy decision, and we rely on that.
9. Your rights
You can ask to see your data, correct it, delete it, restrict its use, object to its use (including where we rely on our legitimate interests), or receive a copy in a common format. We will answer within one month. Write to davehorvath7@gmail.com.
You can complain to the Gibraltar Regulatory Authority, 2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar (telephone +350 20074636, email info@gra.gi), or to the data protection authority in the country where you live or work.
10. Security
The website is delivered over an encrypted connection and holds no data about you. The emails we receive and the records we keep are held in our mailbox and on our own computer, protected by passwords. If a breach puts people at risk we will tell the regulator within 72 hours and tell you where the law requires it.
11. Changes
We will put the date of any change at the top of this notice and, if the change matters to you, tell you by email.