PrivacyTermsCookiesDPASubprocessorsRecords of processingPortuguês
On this page1. As controller2. As processor (on behalf of the customer organizations)3. Where the data is, and transfers4. Security measures (art. 32)

Records of processing

Version 1

⚠️ Draft for legal review. The highlighted fields must be filled in before there are paying customers.

The GDPR (art. 30) asks whoever processes data to keep this list and show it to the supervisory authority if asked. We publish it for everyone.

1. As controller

Controller: [COMPANY NAME], tax number [TAX NUMBER], [ADDRESS]. Privacy contact: [PRIVACY EMAIL].

ProcessingPeopleDataLegal basis (art. 6)Kept for
AccountsUsersName, email, protected password, photo, preferencesPerformance of the contractWhile the account exists
Account securityUsers2FA, sign-ins, device and network (only as a digest)Legitimate interest (security)12 months
Service and security emailsUsersEmail, namePerformance of the contract · legitimate interestSending record: 6 months
Acceptance of the termsUsersWho, which version, whenLegal obligation · legitimate interestWhile the account exists, plus 5 years
GDPR requestsWhoever makes the requestThe request and the answersLegal obligation (art. 12)3 years after they close
Error logsUsersWhere it failed, code, account, organization and browser (no content)Legitimate interest90 days (what comes from the browser, 7 days)

2. As processor (on behalf of the customer organizations)

ProcessingDataInstructionsKept for
Project managementTickets, comments, pages, attachments, hours, activity logData processing agreement (DPA)While the organization exists; 30 days after the contract ends
AI features (if the organization uses them)The text of each AI requestDPANot kept by the provider for training
GitHub connection (if connected)Commits, branches and pull requests linked to ticketsDPAWhile connected
Notice emailsName and email of the recipient, the ticket titleDPASending record: 6 months

3. Where the data is, and transfers

Database and files in Ireland (EU); application servers in Dublin (EU). Emails, AI and GitHub leave the EU, with the GDPR safeguards (art. 44 to 49). The full list, with the safeguards, is in «Subprocessors».

4. Security measures (art. 32)

  • Encrypted connections and disks.
  • Separation between organizations inside the database itself, with automatic tests.
  • Two-step verification, which each organization can make mandatory.
  • Passwords checked against known data leaks; request limits and CAPTCHA.
  • Activity log; backups; an independent security review of every version.

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