Privacy notice

Version 31.10.2026.

1. Who we are

PagoFix (https://pagofix.com) is provided by Nukehive OÜ, registry code 14647290 (Estonian Commercial Register), address Masina tn 20, 10113 Tallinn, Estonia (‘we’). Contact for data protection questions: [email protected]. We have not appointed a data protection officer.

PagoFix is self-service software. It calculates statutory late-payment interest and compensation and prepares drafts of reminder letters and of the European order for payment application (Form A). PagoFix is not a debt collection agency: we do not contact your debtors, do not send letters on your behalf and do not collect money.

2. Using the calculator without an account

You do not need an account. The calculation and the letters are made in your browser, and the invoice data you type or the PDF you drop stays in your browser. We do not store it on our servers. Our hosting provider (section 6) handles your IP address and technical request data to deliver the pages and protect them against attacks; we do not keep web server logs of our own and do not use analytics or tracking cookies.

3. What we store when you create an account

DataWhyLegal basisHow long
Account: identifier, email address (if you add one), name from Google (if you use Google), interface language, creation and last sign-in timeTo run your accountArt 6(1)(b) GDPR: the service you asked forUntil you delete the account; unused accounts: see below
Passkeys: public key, credential identifier, counter. We never receive your fingerprint, face or screen lock.Sign-inArt 6(1)(b)Until you delete the account
Sign-in session (cookie and its hash on our side)Keeping you signed inArt 6(1)(b)30 days
Sign-in log: time, method, success or failure, country/region/city from our hosting provider, browser type, IP addressSecurity and abuse preventionArt 6(1)(f) GDPR, our legitimate interest in the security of the service (recitals 47 and 49)12 months; the IP address is removed after 90 days
Cases you save: invoice data, your and your debtor’s details you entered, status, payment dateShowing your cases, plan and claimYour data: art 6(1)(b). Your debtor’s data: see section 4Until you delete the case or the account
Letters created in your account and the date you marked them as sentKeeping a record of your remindersAs aboveUntil you delete the case or the account
Account log: what happened in your account (sign-ins, cases saved or changed, letters created or marked sent, status changes, data downloads)So you can see what happened when, and for securityArt 6(1)(b) and (f)Entries about a case: as long as the case. Other entries: 12 months
Email log: that a sign-in email was sent, when, and the delivery status (not the content or your address)Sending limits and delivery problemsArt 6(1)(f)400 days
Short-lived security records: one-time sign-in links, passkey challenges, rate-limit countersSign-in securityArt 6(1)(f)Minutes to hours; sign-in links 15 minutes

Unused accounts. If you do not sign in for 24 months, we delete the account with everything in it. If the account has an email address, we warn you by email at the 23rd month, at least 30 days before deletion. An account with only a passkey and no email address is deleted after 24 months without a warning, because we have no way to reach you.

Deleted data can remain in the automatic restore history of the database (Cloudflare D1 Time Travel) for up to 7 days on our current hosting plan. We use it only to recover from a technical failure.

These periods follow the storage limitation principle in art 5(1)(e) GDPR. Deletion runs automatically at least once an hour while the service is in use.

4. Your debtor’s data: you decide, we process for you

When you save a case, it may contain personal data of other people, for example the debtor’s name, email address or the name of a contact person. For that data you are the controller: you decide why and how it is used. We are your processor within the meaning of art 28 GDPR and process it only to provide the features you use. The processing terms are in section 5 of the terms of use.

If you are a debtor named in a case, please contact the business that sent you the letter. If you contact us, we will help that business answer you as far as we can.

5. Cookies and browser storage

NamePurposeDuration
__Host-pf_sessionKeeps you signed in (HttpOnly, only over HTTPS)30 days
pf_liValue ‘1’ only: shows ‘My account’ instead of ‘Sign in’ in the header30 days
__Host-pf_oauthOnly during Google sign-in, protects against forged requests10 minutes
pf-ui (local storage)The interface language you choseUntil you clear it
pf-footer (local storage)Value ‘off’ only: remembers that you removed the ‘Prepared with PagoFix’ line from lettersUntil you clear it or switch the line back on
pf-pending-case (session storage)Holds a case you asked to save while you sign inRemoved after saving or when you close the tab

All of them are strictly necessary for a service you asked for, so under art 5(3) of Directive 2002/58/EC they do not need consent. We do not use advertising or analytics cookies.

Language. On your first visit, if you have not chosen a language yet, our server reads the approximate country that our hosting provider Cloudflare derives from your IP address and uses it only to choose the interface language (art 6(1)(f) GDPR: our legitimate interest in showing the site in a language you understand). Neither the IP address nor the country is stored or logged for this. If you choose a language yourself, your choice always applies.

6. Who else processes the data

Cloudflare and Resend are our processors. In both cases the data processing agreement is part of the terms of service we have accepted: the Cloudflare Data Processing Addendum (cloudflare.com/cloudflare-customer-dpa) and the Resend Data Processing Addendum (resend.com/legal/dpa). Both companies are based in the US and may also process data there. Both are on the EU-U.S. Data Privacy Framework List (checked on 31.10.2026). Under a European Commission decision, the US ensures an adequate level of protection for personal data transferred to organisations on that list (Implementing Decision (EU) 2023/1795, art 1; art 45 GDPR). If the Framework does not cover a transfer for any reason, both agreements provide for the Commission’s standard contractual clauses (Implementing Decision (EU) 2021/914; art 46(2)(c) GDPR). Their own sub-processors are listed at cloudflare.com/gdpr/subprocessors and resend.com/legal/subprocessors.

We do not sell data and do not share it with anyone else, unless the law requires it.

7. Your rights

8. Changes

If we change this notice, we will publish the new version here with a new date. If the change affects data we already hold, we will tell signed-in users in their account.

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council (OJ L 119, 4.5.2016, p. 1). Directive 2002/58/EC (OJ L 201, 31.7.2002, p. 37), as amended by Directive 2009/136/EC. Commission Implementing Decision (EU) 2023/1795 on the adequate level of protection under the EU-U.S. Data Privacy Framework (OJ L 231, 20.9.2023, p. 118). Commission Implementing Decision (EU) 2021/914 on standard contractual clauses for the transfer of personal data to third countries (OJ L 199, 7.6.2021, p. 31).

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