DC ESCRYPTPrivacy Policy
DC ESCRYPT ("we") operates the Raposa Aval human approval service and the signed agent infrastructure available at dcescrypt.com. This policy explains what personal data we process, why, and what rights you have under the GDPR (Regulation (EU) 2016/679).
1. Controller
DC ESCRYPT SL (NIF B55413975, Registro Mercantil de Málaga), Calle Torrebermeja 2, Urb. Marbella Views V 8, 29679 Benahavís (Málaga), Spain — full provider identification on the Legal page. Contact for all privacy matters: [email protected]. Abuse reports: [email protected]. We have not appointed a data protection officer: our core activity is not large-scale monitoring or processing of special-category data (Art. 37 GDPR).
2. What we process
| Category | Examples | Legal basis |
|---|---|---|
| Approval requests | Action name, free-text context supplied by the customer's agent, requester identifier | Art. 6(1)(b) — performance of a contract |
| Decisions | Approve/reject, operator identifier, timestamp, optional comment | Art. 6(1)(b); Art. 6(1)(f) — auditability |
| Audit log | Hash-chained record of every event above | Art. 6(1)(f) — legitimate interest in tamper-evident records |
| API credentials | SHA-256 hashes of API keys and panel passwords — never the values themselves | Art. 6(1)(b) |
| Correspondence | Email you send to contact@ or abuse@ | Art. 6(1)(b) / Art. 6(1)(f) |
| Server logs | IP address, user agent, request line, timestamp | Art. 6(1)(f) — security and abuse prevention |
| Billing | Email address, plan, Stripe customer and subscription identifiers, invoice status — card numbers are entered on Stripe's pages and never reach us | Art. 6(1)(b); Art. 6(1)(c) — tax and accounting law |
We do not run advertising or behavioural profiling on customer approval data, and we do not sell personal data.
3. Content you send us
The context field of an approval request is free text controlled by the customer. Customers decide what goes into it and remain the controller for that content; DC ESCRYPT acts as processor for it. Do not place special-category data (Art. 9 GDPR) in that field.
4. Where data is processed
Application servers and the approval database are hosted in Germany (OVH); encrypted backups are stored in France (Contabo). Transactional email is delivered through Resend in the EU (eu-west-1); inbound mail for our published addresses is routed by Cloudflare. DNS and edge proxying are provided by Cloudflare.
Approval data is stored only in the EU. If a customer enables Telegram or Slack approvals, the action and context text of each approval request is delivered to approvers through Telegram or Slack, which process it under their own terms and may do so outside the EEA. Error reports from our pages and service go to Sentry's EU data region; Sentry (Functional Software, Inc.) is a US company. Transfers outside the EEA also concern the public marketing pages: if you accept the cookie banner, Google (Analytics) and Meta (Pixel) may process your IP address and browsing events in the United States. Both companies are certified under the EU-U.S. Data Privacy Framework, and their standard contractual clauses (Art. 46(2)(c) GDPR) apply as a fallback.
5. Retention
- Approval records and audit log: retained for the life of the customer account, then 12 months, unless a longer period is required by law.
- Server logs: 30 days.
- Email correspondence: 24 months.
The audit log is append-only and hash-chained by design. Deleting an individual entry would break the chain; erasure requests are therefore satisfied by removing or pseudonymising the underlying personal data while retaining the hash.
6. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection, and — where processing rests on consent — the right to withdraw it at any time without affecting earlier processing. Write to [email protected]; we answer within 30 days. You may also lodge a complaint with your supervisory authority; ours is the Agencia Española de Protección de Datos (aepd.es).
We make no decisions about you by automated means alone (Art. 22 GDPR): Raposa Aval exists precisely so that a human decides. Providing data to us is contractual, not statutory; without an email address we cannot answer an enquiry or deliver credentials.
7. Processors
| Processor | Purpose | Location |
|---|---|---|
| OVH | Application hosting, database | Germany |
| Cloudflare | DNS, edge proxy, inbound email routing | EU edge |
| Resend (Amazon SES) | Outbound transactional email | EU (eu-west-1) |
| Contabo | Encrypted off-site backups of the approval database (age-encrypted before transfer; the decryption key never resides on that host) | France |
| Google Ireland | Website analytics (Google Analytics 4) — only after consent, see section 8 | EU |
| Stripe Payments Europe | Subscription payments and invoices; Stripe is an independent controller for the card data it collects on its own pages | Ireland (EU) |
| Sentry (Functional Software, Inc.) | Error monitoring of our public pages and of the approval service; approval context, emails and tokens are not sent | EU data region; US company |
| Telegram, Slack — only if the customer enables them | Delivery of approval requests (action and context text) to approvers and their button presses | Outside our EU hosting — see the providers' terms |
8. Cookies and analytics
No measurement cookie is set until you press "Accept" in the banner. If you accept, the Meta Pixel (dataset 3249689061907532, operated by Meta Platforms Ireland) is loaded and reports a page view together with your IP address and browser data, so we can tell which campaigns bring visitors. Google Analytics 4 (measurement ID G-Y0KPWP8Q31, operated by Google Ireland) is loaded under the same consent and reports page views and aggregate usage. Legal basis for both: consent, Art. 6(1)(a) GDPR. If you decline, neither is loaded and the choice is remembered in your browser's local storage under the key raposa_consent; clearing site data brings the banner back and withdraws the consent.
Web fonts are loaded from Google Fonts, which receives the visitor's IP address as part of the request. Every page also loads Sentry's error-monitoring script (Functional Software, Inc.; data stored in Sentry's EU region): loading it reveals your IP address to Sentry, and when a script error occurs it sends the page URL, browser and device data and technical error details so that we can fix faults. Legal basis: Art. 6(1)(f) GDPR — keeping the pages working. No other third-party script runs on these pages.
The service is for businesses and is not directed at children; we do not knowingly process data of anyone under 16. Links to other sites (documentation hosts, payment pages, source repositories) lead to services with their own privacy terms.
9. Security
API keys and panel passwords are stored only as SHA-256 hashes. The agent signing key is Ed25519, generated on the server, permissions 0600, and has never left it. All traffic is served over TLS. The approval service listens only on loopback behind nginx.
10. Changes
Material changes are announced at this URL with a new "last updated" date.