Data processing agreement

This agreement is an annex to the terms of service. It applies automatically when you add the Statsdot script to your websites, with no separate signature. If it and the terms differ on the protection of personal data, this agreement prevails.

1. Parties

Controller: you, the customer who holds the Statsdot account, for the visitor data of your websites.

Processor:

Mihai Stana Ionescu
Tax ID: 03236201D
Address: Ana Frank, 20, Valdemoro Madrid Spain
Email: [email protected]

Your own account and billing data, including the email addresses of the people you invite to your team, are not covered here: for those we are the controller, as described in the privacy policy.

2. Subject matter and duration

We process personal data to provide Statsdot to you. The agreement lasts as long as your account exists, and after that until the data has been deleted as described in section 12.

3. Nature and purpose

Collecting, storing, aggregating and displaying visits to your websites, so that you can measure their audience. The data is used only for your own statistics: never sold, shared with third parties or used for advertising or profiling.

4. Categories of data and data subjects

Visitors of your websites. For each pageview or event, Statsdot stores:

• the page address without query parameters;
• the domain of the referring website, not the full address;
• UTM campaign tags (source, medium, campaign);
• the event name and an optional label, such as the address of an outbound link;
• the country, as reported by Cloudflare;
• the device type, derived from the screen width;
• the browser and operating system;
• the time;
• a visitor code calculated from the IP address, the browser string and a random key that is deleted every day.

The server receives the IP address and the full browser string with every request, as every web server does. They are used in memory to calculate the visitor code and to filter out bots, and are not stored. The IP address is also used to limit the number of requests: the counter is kept under a hashed key that expires after one minute. Because the key behind the visitor code changes every day, the same person cannot be followed from one day to the next.

No special categories of data under article 9 of the GDPR are processed.

5. Instructions

We process the data only on your documented instructions. These terms, this agreement and the settings of your account (sites, goals, shared links, live widget, weekly report) are your instructions. We only process the data otherwise if EU or member state law requires it, and in that case we tell you first unless that law forbids it. If we believe an instruction breaks data protection law, we tell you.

6. Confidentiality

Everyone authorised to process the data is bound by confidentiality.

7. Security

We take the technical and organisational measures in the annex. We may update them, as long as the level of protection does not go down.

8. Sub-processors

You give us a general authorisation to use sub-processors. The current ones are those listed in the privacy policy:

• Hosting: Contabo GmbH, servers in Germany. The statistics and account data are stored there.
• Network and security: Cloudflare, Inc. Requests to statsdot.com and to the tracking endpoint pass through its network, which sees IP addresses in transit but does not store the statistics.
• Email: Mailgun Technologies, Inc., for account emails.
• Payments: Stripe. It processes only your own billing data, never visitor data.

We will tell you by email 30 days before adding or replacing a sub-processor. You can object within that period by writing to [email protected]. If we cannot address the objection, you can cancel before the change takes effect. We impose the same data protection obligations on every sub-processor, and remain responsible to you for their work.

9. International transfers

The statistics and account data are stored in Germany. Requests pass through the network of Cloudflare, Inc., a US company, so data can leave the EU in transit. These transfers are covered by the EU-US Data Privacy Framework and standard contractual clauses.

10. Assistance

We help you, taking into account the nature of the processing and the information available to us:

• to answer requests from data subjects exercising their rights. The visitor data we hold cannot be linked to a named person, which in most cases limits what can be found for a given request;
• with data protection impact assessments and prior consultations with a supervisory authority;
• to meet your security obligations.

11. Personal data breaches

We tell you without undue delay after becoming aware of a personal data breach that affects your data, with the information we have about its nature, likely consequences and the measures taken, so you can meet your own notification duties.

12. Deletion

• Visits are deleted automatically when they are older than the retention of your plan, at most 24 months.
• When you delete a site, its statistics are deleted.
• When you delete your account, all its data is deleted.
• If a trial ends without a plan (the account never subscribed and has no plan granted by hand), visits keep being recorded for 7 days and you are emailed when the trial ends. After those 7 days, all visits of the account's sites are deleted and recording stops. The account and its sites remain.

Copies in backups are overwritten within 30 days.

There is no automatic export of the stored visits yet. If you ask at [email protected] before closing your account, we either give you the data we hold for your sites or delete it, as you choose.

13. Information and audits

On request to [email protected], we give you the information needed to show that this agreement is met. We allow and contribute to audits and inspections by you or an auditor you appoint, with reasonable notice.

Annex: technical and organisational measures

• Encryption in transit: the dashboard, the tracking script and the tracking endpoint are served only over TLS.
• Backups: encrypted and kept for 30 days.
• Access: access to the servers, the database and the backups is limited to the people who run the service. Passwords are stored as a hash. Within an account, team members are viewers or managers; only the account owner manages billing and the team.
• Daily key rotation: the key behind the visitor code is deleted every day, so visitors are counted once per day and cannot be followed across days.
• No cookies or device storage: the tracking script sets no cookies and uses no local storage or fingerprinting.
• Data minimisation: no IP addresses or full browser strings are stored; page addresses are stored without query parameters and referrers as a domain only.
• Retention: visits older than the plan's retention, at most 24 months, are deleted automatically every day.