Legalupdated on
Subprocessors
A subprocessor is a party that processes personal data on our instructions. Today there are two: PostHog, for measurement and crash reports, and Tally, for the waiting list. Beyond that, the site runs at Cloudflare, which processes your IP address in doing so, and your browser reaches a few public data sources directly.
PostHog
PostHog provides the usage analytics, the crash reports and the session recordings. We use the EU environment: events arrive at eu.i.posthog.com and are processed in Germany. On every visit, consent or not, your browser fetches two script files from eu-assets.i.posthog.com. The region is fixed when the project is created and cannot be changed afterwards. PostHog, Inc. is a US company based in San Francisco; the data processing agreement incorporates the EU Standard Contractual Clauses and PostHog participates in the EU-US Data Privacy Framework.
PostHog engages parties of its own. For the EU environment those are Amazon Web Services (storage, Germany), PlanetScale (database monitoring, Germany), Modal Labs (compute, Germany), Wiz (security, Germany and France) and Cloudflare (network and traffic handling).
Open point, still to be checked by a lawyer: for Amazon Web Services, PlanetScale and Modal Labs, PostHog gives the location as “USA (PostHog US Cloud) or Germany (PostHog EU Cloud)”. We are on the EU environment, so for us that reads as Germany. For Cloudflare the location is given as “global edge locations, worldwide” for data in transit. What that means for transfers outside the EU, and whether PostHog's US entity itself can reach the data, has to be established before public launch.
The date on which the data processing agreement with PostHog was accepted will be added here before publication.
Tally
Tally BV (Belgium) provides the waiting-list sign-up form and receives what you enter in it. By its own account Tally stores that data in Europe. According to Tally, its data processing agreement is part of the terms accepted when the account was created; there is no separate signature.
Tally engages parties of its own, among them Google Cloud, Cloudflare, SendGrid, Sentry, Mixpanel and OpenAI; according to Tally some of these may also process form submissions. Which of them sit outside the EU, and what that means for transfers, has to be established before launch.
The embedded form loads on every visit to the home page, consent or not, and sets a Mixpanel cookie inside its own frame on tally.so. See the privacy statement under ‘The waiting list’.
Hosting
tuinontwerp.app runs on Cloudflare Workers. Cloudflare serves the site and processes your request data, including your IP address, in order to deliver the page and to keep abuse out. For 1 percent of requests Cloudflare keeps a log line with the method and the page address, for 3 days on the free plan and 7 days on a paid plan.
Cloudflare is listed here because it is our hosting provider. We do not use an intermediate server to route traffic to PostHog; your browser talks to eu.i.posthog.com and eu-assets.i.posthog.com directly.
Parties your browser reaches directly
When you enter an address, the app looks the parcel up at PDOK, the Dutch government's public data service, and at the Kadaster. That first lookup, at the moment you submit your address, is done by our server. After that your browser makes the requests to PDOK and the Kadaster directly. Building heights come from 3DBAG, but those requests travel through our own server, so 3DBAG never sees your browser.
These parties are not subprocessors. They are public data sources we query. Whatever they record themselves falls under their own terms.
Changes to this list
If a party is added or drops off, we update this page and note the date at the top.
Questions about the parties on this page? Email us at privacy@tuinontwerp.app.