Privacy Policy

Effective 30 October 2026

1. Who is responsible

The controller of your personal data under the General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") is:

Name

Anton Lazouski, sole trader "Anton Lazouski", trading as Cobaltsmith

Address

ul. Gerberowa 20/19, 52-221 Wrocław, Poland

NIP / REGON

8992897077 / 388636852

E-mail

[email protected]

We have not appointed a data protection officer, as the law does not require one for us. Write to the address above about anything in this policy.

This policy covers the website cobaltsmith.com, the Cobalt Photo app for Windows (its Viewer, Manager and Converter and the helper that shows the drop panel) and our support by e-mail. "We" and "us" mean the controller above.

2. The website

Hosting and delivery

The website is hosted and delivered by Cloudflare. When you open a page, your browser sends what every browser sends: your IP address, the address of the page, the time, the page you came from and your browser and system type. Cloudflare uses these to deliver the page and to protect the site from attacks, and may keep them in its logs for a short time. We do not keep logs of visits ourselves and do not use these data to find out who you are.

Legal basis: our legitimate interest in running a secure website (Article 6(1)(f) GDPR).

No cookies, no analytics

The website sets no cookies, uses no analytics or advertising tools and loads nothing from other companies — no fonts, scripts or embedded content. It keeps only two small notes in your browser's local storage, and only after you act:

These notes stay in your browser, are never sent to us, and are strictly necessary for a function you asked for — so, under Article 5(3) of the ePrivacy Directive (2002/58/EC) and the national laws implementing it, no consent banner is needed. You can delete them at any time by clearing this site's data in your browser.

Links to other sites

Links to other sites (photo credits, the Microsoft Store) take you to those sites, whose own privacy policies apply.

3. The Cobalt Photo app

What stays on your PC

Cobalt Photo works with your files on your computer. Your pictures, their metadata, file and folder names, searches, ratings and tags, and where your photos were taken are processed on your PC only. Settings, the thumbnail cache, details read from pictures, backups of pictures you replaced (kept for a week) and your watermark logos are stored in the app's own folder on your PC, which Windows removes when you uninstall the app. Places are found with maps built into the app, without going online.

When you open a map

If you click Open map on a photo, your browser opens that photo's coordinates on the map service you chose in Settings (Google Maps, Bing Maps, Apple Maps or OpenStreetMap). Only that one place is sent, only when you click, and that service's privacy policy applies to it.

Error reports — only if you send them

If Cobalt Photo meets an unexpected error, it shows you a window with the error message. Only if you tick Send to the developers there (or have chosen to send reports automatically) does it send a report to our server. A report contains:

• the error message and its type, and where in Cobalt Photo's code it happened (the call stack), with user names and file and folder names removed before sending;
• the version of Cobalt Photo and which part of it was running;
• the version of Windows, whether the PC is x64 or Arm, and the time of the error.

It contains no pictures, no file names and nothing that names you. We use reports only to find and fix errors.

Legal basis: your consent (Article 6(1)(a) GDPR, and Article 5(3) of the ePrivacy Directive). Kept: up to 12 months.

Usage statistics — only if you agree

The first time Cobalt Photo starts, it asks whether you allow it to send usage statistics. If you agree, it sends from time to time:

• which windows and features are used and how often (for example, that Convert was used and to which format, or that a crop was applied in the editor);
• the version of Cobalt Photo and which part of it is used, the version of Windows and whether the PC is x64 or Arm;
• whether the free viewer, the Pro trial or a Pro subscription is in use;
• a random installation ID (see below).

It never sends your pictures, file or folder names, paths, metadata, places, the words you search for, or your language. We use the statistics only to see which parts of the app are used, so we know what to improve.

Legal basis: your consent (Article 6(1)(a) GDPR, and Article 5(3) of the ePrivacy Directive). Kept: up to 14 months with the installation ID; after that only as totals that cannot be linked to any PC.

The installation ID

To count how many PCs use a feature without knowing whose they are, Cobalt Photo makes a random number when you allow statistics. It is not taken from your PC, your Windows or your Microsoft account, it is stored only in the app's folder, and you can see it, make a new one or delete it in the app's Settings. Uninstalling the app deletes it.

Changing your mind

You can allow or stop error reports and usage statistics at any time in the app's Settings, as easily as you allowed them. Stopping them does not affect what was sent before. Cobalt Photo, including Pro, works the same whether you allow them or not.

Our server

Error reports and statistics are sent over an encrypted connection (HTTPS) to our server, which runs on Cloudflare. Like every connection, it reveals your IP address to the server; we do not store it and do not use it to find your location.

4. Buying Pro in the Microsoft Store

Cobalt Photo is distributed through the Microsoft Store. Buying and renewing Pro, payment, refunds and checking that your licence is valid are done by Microsoft, which acts as an independent controller under its own Microsoft Privacy Statement (privacy.microsoft.com). We do not receive your name, e-mail address, Microsoft account or payment details.

Microsoft gives us, in its Partner Center, reports such as the number of installs and purchases by country, the ratings and reviews you publish in the Store, and error reports that Windows collects under your Windows diagnostic settings. We use them to understand where the app is used and to fix errors (our legitimate interest, Article 6(1)(f) GDPR).

5. When you write to us

If you write to [email protected] or [email protected], we receive your e-mail address, your name if you give it, your message and whatever you attach. We use them to answer you and to solve what you wrote about. To read and answer messages in languages we do not speak, we may use a machine translation service.

Legal basis: our legitimate interest in answering you (Article 6(1)(f) GDPR) or, when your message is about your use of Cobalt Photo, the steps needed for our agreement with you (Article 6(1)(b)). Kept: as long as needed to answer you, and then up to 2 years, so that we can follow up on the same matter — unless the law requires us to keep it longer or we need it to establish or defend legal claims. Pictures and files you send are deleted once your matter is solved.

6. Who else handles the data

We do not sell personal data, do not use it for advertising and do not share it with anyone except these service providers, who process it on our behalf and only on our instructions:

• Cloudflare, Inc. (USA) — hosting the website and our server for error reports and statistics, and forwarding e-mail to our mailbox;
• our e-mail provider — keeping the mailbox where your messages arrive;
• a machine translation service — only for messages in languages we do not speak.

Microsoft and the map service you open act as independent controllers (sections 3 and 4). We may also disclose data where the law obliges us to, for example to a court.

7. Transfers outside the European Economic Area

Cloudflare and some of our other providers may process data in the United States or other countries outside the EEA. Where they do, the transfer is protected by the European Commission's adequacy decision for the EU–U.S. Data Privacy Framework (for certified companies, such as Cloudflare) or by the European Commission's standard contractual clauses (Article 46(2)(c) GDPR). You can ask us for a copy of these safeguards.

8. Your rights

Under the GDPR you have the right to:

• access your data and get a copy of it (Article 15);
• have it corrected (Article 16) or erased (Article 17);
• restrict its processing (Article 18);
• receive it in a portable format (data portability, Article 20);
• object to processing based on our legitimate interest (Article 21);
• withdraw your consent at any time, without affecting what was done before — for the app, simply in its Settings (Article 7(3)).

Write to [email protected]; we answer within one month. Because error reports and statistics carry no name, we can only find the data of your PC if you send us its installation ID from the app's Settings.

You also have the right to lodge a complaint with a data protection supervisory authority — in Poland, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl), or the authority of the country where you live or work.

9. More you should know

• Providing data is voluntary. You can use the website and Cobalt Photo, including Pro, without sending us anything. If you write to us without an e-mail address, we cannot answer.
• No automated decisions. We make no decisions about you by automated means and do no profiling (Article 22 GDPR).
• Children. Our website and app are not directed at children under 16, and we do not knowingly collect their data.
• Security. Data is sent only over encrypted connections, kept to the minimum we need, and only we can access it.

10. Changes to this policy

If what we do with data changes, we will update this page and its date above; a change that needs your consent will be asked for in the app first. Earlier versions are available on request.

This policy is published in several languages. If they differ, the English version prevails, unless the law of your country requires otherwise.