Data processing agreement

The processor processes personal data on behalf of the controller for a single purpose: providing the web analytics service contracted on pisi.to. Nothing else. We do not use your visitors' data for any purpose of our own, we do not sell it, we do not share it and we do not combine it with other customers' data.

Controller: you, the customer who owns the pisi.to portal, as owner of the websites you measure.

Processor: Beaglo Labs S.L., a Spanish company, with the identifying details stated in the privacy policy and on your invoice. Contact for anything about this agreement: privacidad@pisi.to.

The agreement takes effect when the portal is created and lasts for as long as the subscription does, free trial included, plus the retention and deletion period of clause 12. Aggregates of a deleted flat are fully purged after 30 days.

Aggregate audience measurement of the controller's websites: visitor and visit counts, page views, bounce, duration, time on page and scroll, traffic sources, approximate location down to city level, browser, OS, device and language, and the conversions the controller defines as goals.

Processing consists of receiving the event, deriving those dimensions in memory, storing the event with no identifying data and aggregating it by hour and by day. There are no profiles, no automated decisions and no cross-site tracking.

The data subjects are the visitors of the controller's websites.

The data is detailed in the annex at the end of this page. In short: the IP address and the User-Agent are read in memory and never stored; from them we derive country, region, city, browser, OS, device type and a visitor identifier that expires every day. Plus the URL without query string except utm, the referrer, the language and the window size.

Beaglo Labs S.L. undertakes to:

These are the third parties involved in the service. Only the first one touches visitor data; the other two process your customer data exclusively. The current list is published in the privacy policy and any change is announced 30 days ahead.

There are no transfers of visitor data outside the European Economic Area. Ingest, database and aggregation are in the European Union (France).

Stripe and Resend may have administrative access from outside the EEA under the European Commission's standard contractual clauses; in both cases they only touch customer data, never visitor data. Should a transfer of visit data ever become necessary, it would be notified in advance and covered by standard contractual clauses.

The article 32 GDPR measures we apply today:

If a visitor asks you for access, rectification or erasure, we will help you answer. But you should know in advance what you will be able to tell them: neither you nor we can locate their data, because no field identifies them. We do not store their IP, there is no cookie with their identifier and the number their visit was counted with was computed with a salt destroyed that same night.

This is the case of article 11 GDPR: when the data subject cannot be identified, there is no obligation to keep additional information just to be able to. It is explained at length in the privacy policy and on the opt-out page, which you can link from your website.

If we detect a security breach affecting data processed on your behalf, we will notify you without undue delay and, in any case, within 24 hours of becoming aware of it, at the email addresses of your portal's members.

The notification will include what we know at that point: the nature of the breach, the categories and approximate volume of data affected, the likely consequences and the measures taken or proposed. What we do not know yet we will fill in as we go. We will help you with whatever you need to notify the supervisory authority within the 72 hours of article 33.

When the subscription ends, or when you delete a flat or the portal, you have 30 days to export whatever you want from the dashboard as CSV. After that, events and aggregates are fully purged, backups included in their normal rotation.

Raw events already delete themselves after 30 days during the life of the service, so at cancellation all that remains are aggregates with no personal data in them. If you prefer return over deletion, ask at privacidad@pisi.to before the deadline.

This agreement is governed by Spanish law and by the GDPR. The Spanish courts have jurisdiction over any dispute. Each party's liability is limited as set out in the terms of service; nothing written here reduces the rights the GDPR grants to data subjects.

What comes in, what is derived and how long it lasts, with the same detail as the data page.