Privacy Notice
Version 1.1
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NABLA PRIVACY NOTICE
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Nabla - 2D Finite Element Method (FEM) software for electromagnetic and
thermal field simulation.
Published by Pontus Materials, a sole trader business carried on by
Inga Tuzovskaya, of 23 Palmers, Wantage, Oxfordshire, OX12 7HA, United Kingdom,
trading as "Nabla".
Notice version 1.1
Last updated: 8 August 2026
This notice explains what personal data we process when you download, install,
activate or buy Nabla, why we process it, and what you can do about it.
It accompanies the Nabla End User License Agreement (LICENSE.txt, referred to
below as "the License Agreement") and is referred to in its clause 14. It is a
notice and not a contract term: nothing in it requires your agreement, and the
lawful basis for the processing described here is your consent only where
clause B4 says so.
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B1. WHO WE ARE
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B1.1 The controller of the personal data described in this notice is Pontus
Materials, a sole trader business carried on by Inga Tuzovskaya, of
23 Palmers, Wantage, Oxfordshire, OX12 7HA, United Kingdom, trading as
"Nabla".
B1.2 Contact for any data protection question, request or complaint:
info@nabla-fem.com, or by post to the address above.
B1.3 We have not appointed a Data Protection Officer; we are not required to.
Data protection enquiries are handled by Inga Tuzovskaya personally.
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B2. THE SHORT VERSION
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B2.1 We process the minimum needed to sell you a license and keep it working:
your email address, your license key, and one-way hashes that identify the
computers you activated on.
B2.2 The Software sends us no telemetry, no usage analytics, and no part of
your models, meshes or results - ever, in any tier, licensed or not.
B2.3 We do not sell, rent or share your personal data for advertising, and we
do not profile you.
B2.4 Simulation you run offline is invisible to us. Verification of your license
is cryptographic and offline; the Software contacts our server only in the
four cases listed in clause 5.3 of the License Agreement.
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B3. WHAT WE PROCESS, AND WHERE IT COMES FROM
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B3.1 License and activation data, sent by the Software to our license server
when you activate, refresh or deactivate a license:
(a) your License Key;
(b) the product name, edition and version;
(c) the Host Fingerprint values of the computer concerned - salted,
one-way hashes. They do not reveal your hardware identifiers, your
user name or your network address to us in reversible form, and they
cannot be used to identify your computer to anyone who does not
already hold the same fingerprint;
(d) the date and time of the activation, refresh or deactivation, and
whether it succeeded; and
(e) the originating IP address, recorded in the server's access log and in
the rate-limiting records that protect the service from abuse.
B3.2 Purchase data, received from Paddle after you buy:
(a) your name and email address;
(b) your country, and any business or VAT identifier you gave at checkout;
(c) the order reference, the product bought, the amount, the currency and
the renewal dates; and
(d) notification of a refund, cancellation or chargeback.
We never receive, and never store, your full payment card number, your card
security code, or your bank details. Those stay with Paddle and its payment
processors.
B3.3 Correspondence: the content of emails you send us about support, licensing
or an academic application, and our replies.
B3.4 Academic license applications: your name, email address, institution,
position, and the description of intended use that you give us, together
with any evidence of eligibility you choose to send.
B3.5 Website: www.nabla-fem.com is a static site. It sets no analytics or
advertising cookies of its own. The checkout is hosted by Paddle and uses
Paddle's own cookies, described in Paddle's privacy notice (B6.1).
B3.6 What we do not process: the contents of your models, geometry, meshes,
materials, scripts, simulation results or reports; how often or for how
long you use the Software; which features you use; and any file on your
computer. The Software has no mechanism to send us any of these.
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B4. WHY WE PROCESS IT, AND ON WHAT LAWFUL BASIS
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Purpose Lawful basis (UK GDPR Art. 6)
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Issuing your License Key and License Performance of a contract
Token; binding Seats; activation, (Art. 6(1)(b))
deactivation and renewal
Providing support you have asked for Performance of a contract
(Art. 6(1)(b))
Emailing you your key, your renewal Performance of a contract
notices and essential service notices (Art. 6(1)(b))
Keeping accounting and tax records Legal obligation (Art. 6(1)(c))
Detecting and preventing license abuse, Legitimate interests
credential sharing and attacks on the (Art. 6(1)(f)) - our interest in
license server; rate limiting; keeping protecting the business and the
server access logs service, balanced against the
minimal, pseudonymous data used
Assessing an academic license application Steps at your request prior to a
contract (Art. 6(1)(b))
Optional product announcements, if you Consent (Art. 6(1)(a)),
asked for them withdrawable at any time
B4.1 We do not process special category data, and we ask you not to send us
any. We do not carry out automated decision-making that produces legal or
similarly significant effects.
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B5. HOW LONG WE KEEP IT
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B5.1 Our retention rules are enforced automatically by a job that runs nightly
on the license server, not only stated here:
(a) server event records (activations, failures, administrative actions)
are deleted 730 days (two years) after the event;
(b) records of revoked or deactivated Seats, including their Host
Fingerprint hashes, are deleted 730 days after revocation;
(c) the email address attached to a license is anonymised 2,190 days (six
years) after that license ends, which is the period for which UK tax
law requires us to be able to substantiate the sale;
(d) order and accounting records are kept for six years from the end of
the accounting period, as UK tax law requires; and
(e) support correspondence is kept for as long as it is useful for
supporting you and then deleted, and in any event no longer than six
years.
B5.2 An active license's records are kept for as long as the license is active -
we cannot administer a license whose key we have deleted.
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B6. WHO ELSE SEES IT
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B6.1 Paddle.com Market Limited, our reseller and merchant of record, processes
your purchase. Paddle is a separate controller in respect of the payment
and tax data it holds, and its own privacy notice
(https://www.paddle.com/legal/privacy) applies to that processing. We
receive from Paddle only the data listed in B3.2.
B6.2 Our hosting provider, which operates the virtual server that runs the
license server, acts as our processor under a written contract. The server
and its database are located in the United Kingdom or the European Economic
Area.
B6.3 Our email provider, which delivers license keys and service emails, acts as
our processor under a written contract.
B6.4 Professional advisers (accountant), and HM Revenue & Customs, where the law
requires.
B6.5 We do not sell, rent or trade your personal data. We do not share it with
advertisers, data brokers or analytics companies. There are no third-party
trackers in the Software.
B6.6 International transfers. Where a processor operates outside the United
Kingdom, we rely on UK adequacy regulations or on the International Data
Transfer Agreement or Addendum, as appropriate. Details are available on
request.
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B7. HOW WE PROTECT IT
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B7.1 All communication between the Software and the license server is encrypted
in transit (HTTPS).
B7.2 Host Fingerprints are stored as salted one-way hashes, never as raw
hardware identifiers.
B7.3 The database and the signing key live on a single hardened server with
key-only administrative access, a restricted firewall, an unprivileged
service account and automatic security updates. Access is limited to the
sole trader named in B1.1.
B7.4 License keys and tokens are never written to our application logs.
B7.5 Backups are encrypted and retained for 30 days.
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B8. YOUR RIGHTS
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B8.1 Under the UK GDPR you have the right to:
(a) be told what personal data we hold about you, and to receive a copy
(access);
(b) have inaccurate data corrected (rectification);
(c) have data erased where we no longer need it (erasure) - note that we
cannot keep a license working after erasing the record that
administers it, and that tax records cannot be erased before the
statutory period ends;
(d) restrict or object to processing carried out on the basis of our
legitimate interests;
(e) receive the data you gave us in a portable, machine-readable form; and
(f) withdraw consent at any time, where processing is based on consent.
B8.2 To exercise any of these, email info@nabla-fem.com. We will respond
within one month. We do not charge for this.
B8.3 If you are unhappy with how we have handled your personal data you may
complain to the Information Commissioner's Office: https://ico.org.uk/,
helpline 0303 123 1113. We would rather you told us first, but you do not
have to.
B8.4 Rights in respect of payment data held by Paddle should be exercised with
Paddle, which is the controller of it.
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B9. IF YOU NEVER BUY
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B9.1 The Free Tier requires no account, no registration, no key and no
activation. If you download the Software and use the Free Tier, we hold no
personal data about you at all, and the Software makes no network
connection for licensing.
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B10. CHILDREN
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B10.1 The Software is a professional engineering tool. It is not directed at
children, and we do not knowingly collect personal data from anyone under
16.
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B11. DATA BREACHES
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B11.1 If a breach occurs that is likely to result in a risk to your rights and
freedoms, we will report it to the ICO within 72 hours of becoming aware
of it, and tell you without undue delay where the risk is high.
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B12. CHANGES TO THIS NOTICE
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B12.1 We may update this notice. The current version is always published at
https://www.nabla-fem.com/privacy.html and supplied with each release of
the Software; superseded versions remain available at their own addresses.
Where a change materially affects you, we will tell you by email.
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CONTACT
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Pontus Materials
Sole trader: Inga Tuzovskaya
Trading as: Nabla
23 Palmers, Wantage, Oxfordshire, OX12 7HA, United Kingdom
Email: info@nabla-fem.com
Telephone: 01235 364074
Website: https://www.nabla-fem.com
Billing, invoices, VAT receipts, subscription changes and refunds are
handled by our reseller Paddle: see your receipt email, or
https://paddle.net.
Copyright (c) 2026 Pontus Materials.
All rights reserved.
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END OF NOTICE
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