--- title: "LangRelay Data Processing Agreement for Site Analytics" description: "How LangRelay processes the data of your website's visitors on your behalf for Site analytics: what is kept, for how long, where, and by which sub-processors." url: "https://www.langrelay.com/dpa" --- 1. [Home](https://www.langrelay.com/) 2. Data Processing Agreement Last updated: 19 October 2026 # Data Processing Agreement ## 1. Parties and Roles This Data Processing Agreement ("DPA") is between you, the customer who adds a website to LangRelay as a Site ("you"), and Chris Jayden, trading as LangRelay, an Eenmanszaak (sole proprietorship) registered in the Netherlands ("LangRelay", "we"). It forms part of our[Terms of Service](https://www.langrelay.com/terms)and applies for as long as we process personal data on your behalf under them. **Chris Jayden (trading as LangRelay)** Enschede, Overijssel The Netherlands [support@langrelay.com](mailto:support@langrelay.com) For the personal data described in section 3, you are the controller and we are your processor, within the meaning of Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR"). This covers Site analytics, revenue tracking where you turn it on for a Site, and the requests your visitors send through LangRelay's proxy where your Site uses it. For the data about you and your account, we are the controller, as our [Privacy Policy](https://www.langrelay.com/privacy)describes. ## 2. Subject Matter, Nature and Purpose **Subject matter:**counting the visits to your website that LangRelay serves, or that LangRelay's script on your pages reports, so that you can see in your LangRelay dashboard how many people visit, from where, on what kind of device and in which language, and, where you turn it on, your revenue per language. **Nature:**receiving the requests for your pages that pass through LangRelay, reducing each page view to the facts listed in section 3, computing a daily visitor hash, storing those facts, and adding them up for your dashboard. Where revenue tracking is on, we also receive order facts from your shop's server and store them, and the pseudonymous profile keys of your logged-in customers where your shop sends them (section 3.2). Where your Site is served through LangRelay's proxy, we also pass your visitors' requests to your server and your server's responses back to them, translating pages into the visitor's language on the way, without storing the requests or the responses. **Purpose:**only to serve your translated pages, to show you these figures, and to suggest which pages to translate next from them. We do not use this data for our own purposes, combine it with other customers' data, profile visitors across websites, sell it or use it for advertising. ## 3. Categories of Data Subjects and Personal Data ### 3.1 Data subjects - Visitors of your website whose page views LangRelay serves (Site analytics). - Buyers in your shop, and customers logged in to your shop, only where you turn on revenue tracking for the Site. - Visitors of your website whose requests pass through LangRelay's proxy, where your Site uses it. ### 3.2 Personal data we store **For each page view:** - the page's path, without its query string; - the visitor's language as your website names it, and whether the page was shown in that language; - the referring website's host name only; - the country, as our hosting provider Cloudflare reports it; - the type of device, browser and operating system (for example "mobile", "Safari", "iOS"); - a daily visitor hash, and whether the view started a visit or ended after one page. The daily visitor hash is a one-way code computed from the visitor's IP address, their browser's identification and your Site, using a random key that changes every day (UTC). To tell a new visit from a continuing one, the day's hash, the time of the last view and a count of views are also kept briefly in Cloudflare's cache at the data centre that counted the view, until an hour after that day ends at the latest. **For each order, where revenue tracking is on:**the order's number in your shop, its total and currency, whether it was paid, refunded (and by how much) or cancelled, when, and the language your shop was in at checkout. Where your shop passes on the IP address and browser identification of the checkout request, that day's visitor hash is computed for the order as for a page view. **For each customer logged in to your shop, where revenue tracking is on:**a pseudonymous profile key. Your shop's server computes it from the customer's account in your shop and a secret we hand your shop; it is never computed from an email address, and it does not name the customer. We store it on that customer's page views and with their orders. Unlike the daily visitor hash, it links that customer's visits across days, so that you can see which pages your customers came in on before they ordered. We store no other facts about the customer with it. ### 3.3 Personal data that passes through without being stored Where your Site is served through LangRelay's proxy, each request and response passes through LangRelay on its way between the visitor and your server. That includes whatever your visitors and your server put in them: the visitor's IP address, cookies, what they send in a form, and pages made for a logged-in visitor. We pass these on and translate the page, and keep none of it beyond the facts in section 3.2. A translated page your server sent to a visitor who was not logged in may be kept for a short time in Cloudflare's cache; a page sent to a logged-in visitor never is. ### 3.4 What we never store We never store an IP address or a browser's full identification: both are used in memory to compute the visitor hash and the device, browser and system types, and then discarded. We never store a page title, a query string, the page or search that referred a visitor, a city or coordinates, or a visitor hash for longer than section 4 allows. We set no cookies and store nothing on visitors' devices. We never receive the name, email address, postal address, phone number or customer number of a buyer; a logged-in buyer's orders may carry a pseudonymous profile key instead (section 3.2). We do not count a visitor whose browser sends a Global Privacy Control signal (`Sec-GPC`) or a Do Not Track signal (`DNT`), known crawlers, or automated clients. No special categories of personal data (Art. 9 GDPR) are processed. ## 4. Duration and Retention We process this data for as long as you have a Site with Site analytics on, and then only for the retention below. You can switch Site analytics off for a Site in the LangRelay dashboard at any time; while it is off, nothing is counted, and what was counted before stays available to you. - **Page views**, with their daily visitor hash, are deleted automatically by our hosting provider Cloudflare three months after they were counted. They cannot be deleted earlier one Site at a time, so they also run out their three months after a Site is deleted. - **Each day's random key**is deleted automatically about a day after its day ends. After that, nobody, LangRelay included, can work out a past day's hash from an IP address. - **Daily totals**per Site, which hold no visitor hash, are kept for as long as the Site exists. - **Orders**are kept for as long as the Site exists. An order's visitor hash is removed 90 days after the order; the order keeps its language. - **Profile keys**of logged-in customers are deleted automatically with the page views that carry them, three months after each was counted, and are kept on orders as long as the order. When you ask us to forget a customer's key (your shop's eraser does, when the customer asks you to erase their data), we delete it from their orders at once; the page views that carry it cannot be deleted one at a time, so they run out their three months. - When you delete a Site, its daily totals and orders are deleted once its 30-day restore period has passed. Restoring the Site within that period keeps them. ## 5. Instructions and Confidentiality We process this personal data only on your documented instructions. Those instructions are this DPA, our Terms of Service and the settings you choose for each Site in the LangRelay dashboard (Site analytics on or off, revenue tracking, and how the Site is served). We process it otherwise only where EU or Dutch law requires us to, and then tell you first unless that law forbids it. If we believe an instruction infringes the GDPR, we will tell you. Everyone we authorise to process this data is bound by confidentiality. LangRelay is run by one person, Chris Jayden; anyone who later works on it will be bound in writing before they get access. ## 6. Security Measures We take the technical and organisational measures that Art. 32 GDPR requires, including these: - **Data minimisation.**Page views are reduced to the facts in section 3.2 when they are counted; the IP address and browser identification are never written to storage. - **Pseudonymisation.**Visitors are told apart only by a one-way hash under a random daily key, which is deleted about a day after its day ends. A logged-in customer's profile key is computed in your shop's server under a secret per Site, never from an email address; switching revenue tracking off and on again replaces the secret, so no key computed before matches again. - **Encryption in transit.**Traffic to and from LangRelay, and between LangRelay and its database, is encrypted with TLS. - **Access control.**In the dashboard, only members of your organisation can read a Site's figures, and only members allowed to configure the Site can change its analytics settings. Every such change is recorded in an audit log that cannot be edited. Access to our hosting accounts is limited to LangRelay's operator, and our infrastructure secrets are stored encrypted. - **Limits.**Collection is rate-limited and capped per Site by its plan, so a flood of requests cannot grow the data without bound. ## 7. Sub-processors You authorise us to use these sub-processors for the data in section 3. Each is bound by a data processing agreement with obligations no weaker than this DPA's. - **Cloudflare, Inc.**(USA): runs LangRelay's proxy, serves your pages through LangRelay, computes the visitor hash, keeps the brief visit markers in its cache, stores page views and each day's random key, and stores each Site's daily totals in its EU jurisdiction. - **Neon, Inc.**(USA): hosts LangRelay's database, in Frankfurt, Germany (AWS eu-central-1), which holds each Site's analytics settings and, where revenue tracking is on, orders. - **PostHog, Inc.**(USA): receives LangRelay's own records of how the dashboard is used (Privacy Policy, section 2.4), hosted in PostHog's EU cloud in Frankfurt, Germany. It receives none of the data in section 3: the dashboard screens that show it are blocked from recording, and the model-call metrics it receives carry no content. We will tell you by email at least 14 days before we add or replace a sub-processor for this data. If you object on reasonable grounds and we cannot address it, you may switch Site analytics off or end the agreement for the affected Sites. We remain responsible to you for our sub-processors' performance. ## 8. International Transfers Cloudflare handles each request at the data centre nearest the visitor, which may be outside the European Economic Area (EEA), and the storage we use for page views and the daily keys is not limited to the EU; each Site's daily totals are stored in Cloudflare's EU jurisdiction. Cloudflare, Inc. and Neon, Inc. are based in the United States. These transfers are covered by the Standard Contractual Clauses approved by the European Commission, which are part of each provider's data processing agreement. LangRelay's database itself is hosted in Germany. ## 9. Assistance with Data Subjects' Rights We will help you answer requests from data subjects exercising their rights under Chapter III of the GDPR, as far as we can. If a data subject contacts us directly, we will pass the request on to you without undue delay and not answer it ourselves unless you ask us to. Because we never store an IP address and delete each day's key about a day after its day ends, neither we nor you can usually tell which page views belong to a given visitor; such views expire within three months. A logged-in customer of your shop is the exception, where revenue tracking is on: their page views and orders carry the profile key your shop computes for them, so they can be found by that key. When you ask, we will help you answer that customer's request: we delete the key from their orders at once, and the page views that carry it run out their three months. We will also give you the information you reasonably need for a data protection impact assessment or a prior consultation with a supervisory authority about this processing. ## 10. Personal Data Breaches We will notify you without undue delay after becoming aware of a personal data breach affecting the data in section 3, by email to your organisation's owner. We will tell you what we know: what happened, the data and number of people likely affected, the likely consequences, and what we have done or propose to do. Where we do not yet know everything, we will send what we know and follow up as we learn more. ## 11. Deletion or Return at the End of the Service When you delete a Site or your account, we delete the personal data in section 3 as section 4 describes, and keep no copy beyond it. If you ask us before you delete the Site, we will first send you a copy of the orders and daily totals we hold for it. Page views without a profile key cannot be returned per person, because we cannot tell whose they are. ## 12. Audits and Information On request, we will give you the information you reasonably need to show that this DPA is being followed, including our sub-processors' current certifications and reports where they make them available. Where that is not enough, we will allow an audit by you or an independent auditor you appoint, bound by confidentiality, on 30 days' notice, once a year at most unless a breach or a supervisory authority requires another. ## 13. Your Responsibilities As controller, you decide the legal basis for this processing, tell the visitors of your website about it (for example in your own privacy policy), and decide whether your website needs to ask for consent. We describe how Site analytics works so that you can make that decision; we do not give legal advice about it. ## 14. Liability, Precedence and Governing Law Liability under this DPA is subject to the limits in our Terms of Service. Where this DPA and the Terms of Service conflict about the processing of personal data, this DPA prevails. This DPA is governed by the law of the Netherlands, like the Terms of Service. ## 15. Changes and Contact We may update this DPA to reflect changes in the law or in how Site analytics works. We will notify registered users by email and update the "Last updated" date at the top of this page at least 14 days before changes take effect. For any question about this DPA, contact us at[support@langrelay.com](mailto:support@langrelay.com).