Privacy Policy

1. Controller

This policy applies to personal data processed by Asqav where Asqav acts as controller: your account, authentication, website visits, analytics, transactional and newsletter email, and support correspondence.

Where Asqav processes data you place inside receipts and signature metadata on your behalf, Asqav acts as your processor. For that data, your organization is the controller and the Data Processing Agreement governs. Data subjects whose data appears in receipts should contact you (the customer) directly.

Contact for privacy questions: info@asqav.com. We have not appointed a Data Protection Officer; privacy questions go to the same address. You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or your local supervisory authority.

We do not use automated decision-making that produces legal effects on data subjects.

2. What we collect and why

Purpose Data Legal basis
Account creation, login, MFA Email, password hash (Argon2id), org membership Art 6(1)(b) contract
Providing the service API keys, agent records, signature metadata, usage counters Art 6(1)(b) contract
Security: access logs, auth logs, fraud prevention IP, user agent, key-access log rows, auth events Art 6(1)(f) legitimate interest (security of the service)
Breached-password screening at signup 5-char SHA-1 prefix of password only, never the password Art 6(1)(f) legitimate interest
Transactional email (Resend) Email address, message content Art 6(1)(b) contract
Newsletter Email address Art 6(1)(a) consent, withdrawable via unsubscribe
Product analytics (Mixpanel EU) Usage events, device identifiers Art 6(1)(a) consent via the banner, withdrawable
Bookkeeping and tax records Invoicing and account records Art 6(1)(c) legal obligation

3. Data Security

4. Data Retention

We retain your data for as long as your account is active or as needed to provide services. Signature record retention by plan:

When an organisation signs any receipt in compliance mode or declares a regulated regime via compliance_regimes, the longest applicable retention floor governs in addition to the plan baseline above. Signing in compliance mode alone extends retention for all of the organisation's signature records and activity logs to at least 184 days, or longer where a specific regulation requires it. The full regime-by-regime table is on /data-handling. The per-regime mapping is at /docs/compliance. The receipt format itself is profiled in the IETF Internet-Draft draft-marques-asqav-compliance-receipts.

The server is backed up daily through Hetzner's automated snapshot service, held on separate backup infrastructure in the EU. A database-level dump is also retained for 7 days on the primary server, with a secondary copy retained for 14 days; both dump copies are stored on the same server today, not at a separate off-site location.

5. Your Rights

Under GDPR you have the right to:

We respond to requests within 30 days. If we need longer for a complex request we tell you why and when.

6. Sub-processors and International Transfers

The canonical sub-processor list is published at /security. Sub-processors include: Hetzner (Germany, EU, cloud hosting), Resend (US, transactional email), Mixpanel (EU endpoint, analytics on consent), Vercel and Cloudflare (US, website delivery and DNS only, no customer API data), trust services receiving cryptographic hashes only (OpenTimestamps calendars including Eternitywall, FPS BOSA, Izenpe), and GitHub (US, code hosting, no runtime customer data).

Customer and account data is hosted exclusively in the EU (Hetzner, Falkenstein, Germany). Mixpanel uses an EU data-residency endpoint (api-eu.mixpanel.com); its US parent is subject to Data Privacy Framework safeguards. Resend (US) processes transactional email addresses. Vercel and Cloudflare handle website traffic only and do not process customer API data. Where data flows to a sub-processor outside the EEA, we rely on Standard Contractual Clauses.

7. Cookies and analytics

Asqav uses two kinds of storage in your browser. Essential storage is always on. Analytics storage runs only after you agree to it.

Essential. These keep the site working and you signed in. The asqav_access cookie holds your session and a CSRF token guards form submissions, while a few local entries remember interface preferences. None of this tracks you, so we set it without asking and you cannot turn it off while you use the site.

Analytics. With your agreement, we load Mixpanel to measure usage events and find what to improve. It stores its data in your browser under localStorage through an EU endpoint, and we never load it until you opt in. The data lasts until you clear it or withdraw your agreement. Analytics do not use your email address to identify you; events are associated with a random device identifier only.

You can change your mind whenever you like. Clear cookies and site data in your browser to reset your choice, and the consent banner asks again on your next visit. Turning analytics off stops Mixpanel right away and keeps it from loading again.