Privacy notice
What personal data DataAttendant receives, why, who else receives it, and how long it is kept, with the rights of people in the EU, the UK, and the EEA.
1. The short version
- Your files never reach us. DataAttendant reads and protects your CSV and Excel files in your browser. Their contents, names, column names, and values are not sent to us or to anyone else.
- Your saved data stays in your browser. Your types, rule sets, plans, lists, history, and Protection keys are kept in your browser. We never receive them.
- We receive only what an account needs. That is your email address, a random ID for your account, your level, your credits, and your payment IDs.
- We use no analytics and no advertising. The website sets no cookie.
In this notice, "the Service" means DataAttendant: the application, its account pages, and the website. "We" means the controller named in section 2.
2. Who is responsible for your data
The controller of your personal data is C Kakoushis, a sole trader in the Czech Republic, trading as UNIT7. The address is Melnicka 6, Praha 5, 150 00, Czech Republic. You can write to us about your data at support@dataattendant.com.
The business is planned to move to a successor company. When it moves, that company becomes the controller. Your account and the data in section 4 then pass to it, so that it can continue to provide the Service. We will tell you at least 30 days beforehand, and we will update this notice.
We have not appointed a data protection officer. For any question about your data, write to support@dataattendant.com.
3. What we never receive
These stay in your browser, on every level and with every setting:
- the contents of your files, and every value in them;
- the names of your files, their columns, and their worksheets;
- your plans, rule sets, types, test cases, and lists;
- your Protection keys, your passphrase, and your recovery key;
- your protected copies and restored files;
- the history of your exports.
We keep a list of every request the application makes, and our tests check that nothing else is sent.
4. What we receive, and why
| What | Why |
|---|---|
| Your email address and your account password, or a sign-in code sent to that address | To create your account and sign you in |
| A random ID for your account, and the date it was created | To keep your account separate from others; it is not derived from your email address |
| Your level, its periods, and every change to your credits | To give you your allowance and the credits you bought, and to check each export against them |
| For each export: a random job ID, the number of records or credits, and the time | To reserve and use the right number of credits |
| The IDs of your Stripe customer record, your subscription, and your payments, with their status and periods | To give you the level and the credits you paid for |
| Records of payments and refunds | To keep accounting records |
| Signs of unusual use, such as many very small exports | To detect abuse of the Service; a person reviews each sign, and nothing is blocked automatically |
| The address of your device (IP address), for one minute | To limit how many requests one address can make |
| What Cloudflare's security check collects on the Account page (section 6) | To tell people from automated sign-ups |
| Your messages to support@dataattendant.com | To answer you |
Our server keeps no name, no postal address, and no amount of money. Its log has one line for each request, with the route, the result, the time, and the account and job IDs. It never holds an address, a header, a password, a message body, or a query.
We make no decision about you by automated means that has a legal or similarly significant effect on you.
5. Who else receives your data
We use these services to run DataAttendant. Each receives only what is listed, and only for that purpose.
| Recipient | What it does for us | What it receives | Where |
|---|---|---|---|
| Vercel (Vercel Inc., United States) | Hosts the website and the application's files | Your IP address and your browser's request for each page and file | United States and Vercel's other locations |
| Railway (Railway Corporation, United States) | Runs our server, which checks and records credits | The account and job IDs, the credits, and your IP address (section 4) | Our server runs in the European Union. Railway is established in the United States |
| Supabase (Supabase Pte. Ltd., Singapore) | Signs you in, sends the sign-in emails, and holds our server's database | Your email address, your password or sign-in code, your sign-in session, your IP address, and everything in section 4 that our server keeps | Our database is in the European Union. Supabase is established in Singapore |
| Stripe (Stripe Payments Europe, Limited, Ireland) | Takes payments | What you enter on Stripe's pages (card, name, billing address, and tax number), and from our server only your account's random ID and what you buy | The European Union and the United States |
| Cloudflare (Cloudflare, Inc., United States) | Runs the security check on the Account page, when it is turned on | Your IP address, your browser's characteristics, and the page's address | United States and Cloudflare's other locations |
| Resend (Plus Five Five, Inc., United States) | Planned: will send emails about your account, such as a failed payment. It is not used yet. We will update this notice before it is | Your email address and the email's text | United States |
Stripe also uses payment data for its own purposes, such as preventing fraud and meeting its legal obligations. For those purposes, Stripe is a controller in its own right, under Stripe's privacy policy.
We do not sell your data, and we do not share it with advertisers.
6. The security check on the Account page
When the security check is turned on, the Account page shows Cloudflare Turnstile. It appears before you sign up, sign in with a password, request a sign-in code, or reset a password. Cloudflare's script runs only on the Account page, never on a page where a file is open.
Cloudflare's script collects your IP address, your browser's characteristics, and the page's address, to tell a person from a program. It never receives your files, your email address, or your password. It returns a single-use pass, which goes to Supabase with your sign-in and is not kept. See Cloudflare's Turnstile privacy addendum.
7. Where your data is processed
Our database (Supabase) and our server (Railway) run in the European Union. Even so, some of your data can be processed outside it:
- The providers are established outside the European Union. Vercel, Railway, Cloudflare, and Resend are companies in the United States. Supabase is a company in Singapore. Their staff and their own providers may process data from other countries.
- Their agreements say where they process data. Railway's agreement says its main processing takes place in the United States. Vercel's says its main facilities are in the United States. Supabase's keeps data in the region the customer chooses, which for us is in the European Union.
- Stripe and Cloudflare process data in more than one country. Stripe's agreement allows transfers to Stripe, LLC in the United States. Cloudflare's allows processing outside the European Economic Area.
Section 11 lists the safeguards for these transfers.
8. How long we keep your data
| Data | How long |
|---|---|
| Your account: your email address, your sign-in, your level, and your credits | While your account is open. We delete them within 30 days after it is closed, except what the rows below keep |
| The record of credits | Three years after your account is closed, so that a question about credits can still be settled. That is the general period for bringing a claim. It holds your account's random ID, not your email address |
| Records of payments and refunds | As long as accounting and tax law requires: up to 10 years after the end of the year of the payment |
| Your IP address for the limit on requests | One minute, in our server's memory |
| Our server's log | 7 days: the period of the Railway plan we use (Hobby) |
| The hosting services' own logs | Supabase's logs of requests and of the database: 7 days (the Pro plan we use). Vercel's runtime logs: 1 hour, and its build logs: for each deployment (the Hobby plan we use). These are the periods of the plans in use. A provider's own backups and records are separate, under its own terms |
| Your messages to support | Until the matter is closed, and 12 months after that |
| What you keep in your browser | Until you delete it on the Saved data page, or clear your browser's data. We cannot see or delete it |
9. Planned: storing your definitions on our server
A later version will let paid levels store definitions on our server: types, rule sets, plans, and test cases. This is not available yet. When it is:
- it will be off unless you turn it on;
- each definition will be encrypted in your browser before it is sent. Only you will hold the key, so we will not be able to read it;
- your Protection keys, your passphrase, your lists of real values, and your file values will never be sent;
- the definitions will be deleted 30 days after your account is closed;
- the rules we deliver to an account will carry one inert ID per account, so that a leaked copy can be traced. It is never derived from your data, and it never appears in your protected copies.
We will update this notice before this feature starts.
10. How your data is protected
- The application may connect only to its own address, our server, and Supabase. Browsers enforce this through the Content-Security-Policy. The Account page may also load Cloudflare's check when it is turned on.
- Our server's database is reachable only through our server's own connection. Row security keeps every other role out.
- The record of credits cannot be changed or deleted by any role.
- Our keys and passwords for the services above are held in those services' settings, not in our code.
- Your Protection keys are encrypted in your browser with AES-256-GCM, under a key derived from your passphrase with PBKDF2 (600,000 rounds). Your passphrase never leaves your browser.
- Every connection uses HTTPS.
11. If you are in the EU, the UK, or the EEA
The General Data Protection Regulation (GDPR), and the UK's version of it, give you the rights below. Under them, we must state the legal basis for each use of your data. We must also state the safeguards for data processed outside the European Economic Area.
Legal bases
- The contract with you: your account, your sign-in, your level and credits, each export's record, and your payments (GDPR article 6(1)(b)).
- A legal obligation: the records of payments and refunds that accounting law requires (article 6(1)(c)).
- Our legitimate interests: detecting abuse of the Service, limiting requests, the security check on the Account page, and answering questions sent to support (article 6(1)(f)).
- Passing the business to a successor: our legitimate interest in transferring the business, together with the contract with you (article 6(1)(f) and (b)).
We do not ask for consent for any of this, because none of it requires consent.
Safeguards for transfers
Each safeguard comes from the provider's own agreement:
- Supabase: the European Commission's standard contractual clauses.
- Railway: the Data Privacy Framework where the recipient takes part in it, and otherwise the standard contractual clauses. The transfer to Railway rests on the standard contractual clauses.
- Vercel: the standard contractual clauses. Vercel's privacy policy also says that it takes part in the EU-US Data Privacy Framework.
- Stripe: its data transfers addendum, with the standard contractual clauses. Stripe's privacy policy says that Stripe, LLC takes part in the EU-US Data Privacy Framework.
- Cloudflare: the EU-US Data Privacy Framework, and the standard contractual clauses if its participation ends.
- Resend, once it is used: the Data Privacy Framework and the standard contractual clauses.
For transfers from the UK, each agreement adds the UK's own addendum to these clauses. You can ask us for a copy of these safeguards at support@dataattendant.com.
Your rights
You have the right to:
- see the personal data we hold about you, and get a copy;
- have it corrected;
- have it deleted, unless the law requires us to keep it;
- have its use restricted;
- receive it in a common machine-readable format, and have it sent to another service;
- object to its use for our legitimate interests.
To use a right, write to support@dataattendant.com from the address of your account. We answer within one month. We may ask you to confirm that the account is yours.
You may also complain to a data protection authority. Ours is the Czech authority, Úřad pro ochranu osobních údajů (the Office for Personal Data Protection), at uoou.gov.cz. You may also complain to the authority where you live or work.
12. Requests from other places
You may live in a US state, or anywhere else, with its own privacy rights. You may then write to support@dataattendant.com with a request about your data.
13. Children
DataAttendant is for professional use. It is not meant for children, and we do not knowingly collect a child's data.
14. Changes to this notice
We will update this notice when what we receive, or who receives it, changes. We will tell account holders by email before a change that affects them. The version number and the date at the top of this page show which text applies.