Privacy Policy
Last updated: September 13, 2026
The data controller for this website and our services is Capablanca Digital OÜ, registry code 16449972, Lootsa tn 2a, 11415 Tallinn, Estonia. Contact: info@capablanca.digital.
1. An important distinction
JFPay is software that other businesses install and operate. For any data processed inside a customer's installation (their users, transactions, KYC documents), that operator is the data controller, not us. This policy covers only this website, our demo, and our direct relationship with buyers.
2. What we collect
- Contact and billing data: when you write to us or buy a license — name, email, company details, invoicing information. Legal basis: contract and legal (accounting) obligations.
- Demo data: anything you enter in the public demo. It is visible to other demo visitors and is deleted automatically every night. Do not enter real personal data there.
- Technical logs: our sites run behind Cloudflare, which processes IP addresses and request metadata for security and delivery. We keep standard server logs for security. Legal basis: legitimate interest.
- Lightning network service: for installations using our Lightning infrastructure we process payment metadata (amounts, invoice identifiers, timestamps) needed to operate nodes and calculate service fees. We do not receive your customers' identity data.
3. What we do not do
We do not sell personal data, we do not run advertising trackers on this site, and we do not use your data for purposes other than providing and invoicing our services.
4. Processors and transfers
We use a small set of service providers to operate: Cloudflare (site delivery and security), hosting providers for our servers within the EU, and our accounting service in Estonia. Where a provider processes data outside the EEA, transfers rely on standard contractual clauses.
5. Retention
Correspondence is kept as long as needed to serve you; invoicing data is kept for seven years as required by Estonian accounting law; demo data is deleted nightly; security logs are kept for a short rolling period.
6. Your rights
Under the GDPR you can request access, correction, deletion, restriction, portability, and object to processing based on legitimate interest. Write to info@capablanca.digital. You can also lodge a complaint with the Estonian Data Protection Inspectorate (AKI) or your local authority.
7. Changes
We will post any changes to this policy on this page with a new date.