a3c Privacy Policy
Version of 27 September 2026.
In short.
- a3c runs on your Mac. Vehicle data, backups and the operation history stay on your computer and are not sent to the developer.
- The app has no accounts, advertising, analytics or tracking.
- From version 1.1.0, the app asks the developer's server for update status and the catalogue. The request contains no identifiers. The server does not store IP addresses and keeps only daily counters.
- The developer receives personal data only if you write to support.
- Payments are processed by Apple.
1. General
1.1. This Policy explains how the controller processes personal data in connection with the a3c app for macOS, its server and support. It is the controller's policy under Art. 18.1 of Russian Federal Law No. 152‑FZ "On Personal Data" (152‑FZ). For users in the EEA, the United Kingdom and Switzerland, it also provides the information required by Art. 13 of the General Data Protection Regulation (GDPR).
1.2. Terms have the meaning given in 152‑FZ and the GDPR.
2. Controller
2.1. Controller (operator) — Sergei Pavlov, private individual, address: {{OPERATOR_ADDRESS}}, email: thebordev@gmail.com. The controller is personally responsible for organising the processing of personal data.
2.2. Representative in the EU (Art. 27 GDPR): not appointed.
3. Data on your Mac
3.1. The app stores on your computer:
- vehicle data: VIN, control-unit identifiers and versions, codings, adaptations, fault codes, parameter values;
- backups taken before writes and the operation history;
- technical logs;
- app settings.
3.2. This data is processed only on your device. The app does not send it to the controller, and the controller has no access to it. The controller receives it only if you attach it to a support email yourself.
3.3. You can open the data folder via "Help → Show data folder in Finder". You can delete the data yourself; quit the app first and keep any backups you need. Deleting the app may not delete the data folder. Copies in macOS backups (such as Time Machine) are managed separately.
3.4. You enter SFD tokens yourself. The app uses them to unlock a control unit and does not send them to the controller.
3.5. macOS permissions are used only to work with the vehicle and files:
- Bluetooth — to communicate with a BLE adapter;
- local network — for Wi‑Fi adapters and DoIP connections;
- access to files you select — for export and import.
4. The a3c server (from version 1.1.0)
4.1. At launch and then every 6 hours, the app sends a request to the controller's server. It contains:
- app and engine versions and the build channel (App Store, TestFlight or development);
- the list of engine capabilities;
- the major macOS version and processor architecture;
- the interface language;
- the revision of the installed catalogue;
- a "first request of the day" flag.
4.2. The request contains no identifiers of the device or installation, no Apple ID, purchase data, serial numbers or MAC addresses, no VIN or other vehicle data, no name, email, geolocation or cookies.
4.3. The server responds with an "update required?" status and feature flags. The app downloads the catalogue, signed with the controller's key, in separate requests: at launch, the general list of car models; when you open a model, that model's functions, their translations into the interface language and their animations. These requests contain only the catalogue schema number, the build channel, the selected model and the language — no identifiers, as in section 4.2; the server does not record them. The last response and the downloaded catalogue are stored on your Mac so that the app works offline.
4.4. IP address. Like any server on the internet, the server receives your device's IP address — a response cannot be sent without it. The IP address is used only in memory, to deliver the response and to protect the server from overload. It is deleted within minutes. It is not written to logs or databases, access logs are disabled, and it is not linked to the content of the request.
4.5. The server stores only daily aggregated request counters for combinations of the parameters in clause 4.1. Rare combinations are merged into an "other" category so that no individual user can be singled out by an unusual configuration. The server cannot tell whether two requests came from the same computer.
4.6. The server does not collect or store personal data and cannot identify users. Where the law of your country (for example, the GDPR) treats the brief handling of the IP address under clause 4.4 as processing of personal data, the legal basis is the controller's legitimate interest in delivering the requested data and protecting the server (Art. 6(1)(f) GDPR).
4.7. Server location: Russian Federation.
5. Support requests
5.1. This is the only case in which the controller processes your personal data.
| Purposes | to answer your request, solve the problem, handle a claim or a data protection request, and defend the controller's rights in a dispute |
| Data | email address, name (if given), message text, attachments (screenshots, logs, history files — these may contain the VIN and vehicle details), date and technical email headers |
| Data subjects | a3c users and other persons who contact the controller, and their representatives |
| Legal basis (152‑FZ) | performance of the End User License Agreement, including steps taken at your request before it is concluded (Art. 6(1)(5)); fulfilment of the controller's legal obligations — replies to data subject requests and claims (Art. 6(1)(2)); for requests unrelated to the Agreement — your consent, which you give by sending the email and may withdraw (Art. 6(1)(1)) |
| Legal basis (GDPR) | performance of a contract (Art. 6(1)(b)); compliance with a legal obligation under the GDPR — replies to data subject requests (Art. 6(1)(c)); legitimate interest in answering other requests and keeping correspondence to defend against claims (Art. 6(1)(f)) |
| Operations | collection, recording, organisation, accumulation, storage, updating, retrieval, use, disclosure in the cases in clause 5.3, blocking, erasure, destruction |
| Means | automated processing by email |
| Retention | 3 years after the last message in the conversation, which is the general limitation period (Art. 196 of the Russian Civil Code). The data is then destroyed within 30 days |
5.2. Do not send passwords, SFD tokens or unnecessary personal data. Send the full VIN only if it is really needed for the answer. The controller does not request special categories of personal data.
5.3. Recipients. Emails are stored by the email provider Google LLC (Gmail), which processes them on the controller's behalf; under the GDPR it is a processor. Data is disclosed to public authorities only where the law requires it. The controller does not sell personal data or share it for advertising.
5.4. Storage location. The database (mailbox) is located in: the United States and other countries where Google operates data centres.
5.5. Cross-border transfer: yes — correspondence is stored on servers of Google LLC (USA).
6. Apple and payments
6.1. App Store downloads, purchases, the a3c Pro subscription and refunds are handled by Apple as an independent controller under Apple's privacy policy.
6.2. The controller does not receive card numbers, billing details or Apple Account data. The app checks the subscription on your Mac using StoreKit and does not send purchase information to the controller. Apple provides the controller only with aggregated sales reports that do not identify buyers.
6.3. If you have allowed sharing analytics with app developers in macOS settings, Apple may pass crash reports and de-identified statistics to the controller under Apple's rules.
7. International transfers (for users in the EEA, the UK and Switzerland)
7.1. The controller is located in the Russian Federation. There is no European Commission adequacy decision for Russia. When you write to support, you send your data directly to the controller in Russia yourself. This is not a transfer by an exporter in the EU, but the level of protection may differ from that in Europe. The controller applies the measures in section 9.
7.2. The email provider stores emails in the location given in clause 5.4.
8. Your rights
8.1. Under 152‑FZ, you have the right to:
- obtain information about the processing of your data (Art. 14);
- require that your data be updated, blocked or destroyed if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the purpose of processing;
- withdraw consent;
- appeal against the controller's actions to Roskomnadzor or in court (Art. 17).
The controller does not make automated decisions that have legal effects for you (Art. 16). Data is not used to promote goods (Art. 15).
8.2. Under the GDPR, you have the right to:
- access your data (Art. 15);
- rectification (Art. 16);
- erasure (Art. 17);
- restriction of processing (Art. 18);
- data portability (Art. 20);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent at any time without affecting the lawfulness of processing before withdrawal (Art. 7(3));
- lodge a complaint with a supervisory authority, in particular in the country where you live or work or where the alleged infringement took place (Art. 77).
8.3. How to make a request. Write to thebordev@gmail.com or to {{OPERATOR_ADDRESS}}. To confirm that the request comes from you, the controller may ask you to write from the email address used in the correspondence. A request under 152‑FZ must contain the information listed in Art. 14(3) of 152‑FZ; an electronic request must be signed with an electronic signature.
8.4. Time limits. The controller replies within 10 working days of receiving the request. This period may be extended by up to 5 working days with a reasoned notice (Art. 14(3), Art. 20 of 152‑FZ). Under the GDPR, the reply is given without undue delay and within one month at the latest (Art. 12(3)). After consent is withdrawn or the purpose of processing is achieved, the data is destroyed within 30 days (Art. 21 of 152‑FZ). Requests are handled free of charge.
8.5. Whether you must provide data. Providing personal data is not a statutory or contractual requirement. The app works without contacting support. Without an email address we cannot reply to you.
8.6. There is no automated decision-making or profiling (Art. 22 GDPR).
9. How we protect data
Measures under Art. 18.1 and 19 of 152‑FZ and Art. 32 GDPR:
- legal: this Policy, internal processing rules, a harm assessment, a data destruction procedure;
- organisational: only the controller has access to personal data; data is processed only for the purposes in section 5 and kept no longer than the stated period;
- technical: email is transmitted over an encrypted connection (TLS); the mailbox is protected by two-factor authentication; the controller's device disks are encrypted; software is kept up to date;
- minimisation on the server: requests without identifiers, IP addresses not recorded, access logs disabled, a signed catalogue that cannot be substituted.
10. Children
The app is intended for persons over 18 and is not designed for children. The controller does not knowingly process children's data. If such data reaches the controller, it will be deleted.
11. Changes to this Policy
A new version is published at https://a3c.resaleapp.ru with its date. The controller announces material changes in the app. If the app starts processing new data or using data for new purposes, this Policy will be updated before that happens.
12. Contact
Sergei Pavlov, {{OPERATOR_ADDRESS}}, thebordev@gmail.com.