What Lumenda records

If you arrived from a processing agreement or a website's privacy policy, this is the page you came for. Every statement here can be checked against the running system.

Recorded

Per visit: browser, operating system, device type, screen size, language, country, region and city. Per page view: the path of the page, its title, the referring page and the time.

Not recorded

• No cookies. The counting itself writes nothing to your device. The only access is a check for whether you have objected — and that objection is stored, locally in your browser only, if you make it yourself.
• Your IP address is processed but never stored. It is used momentarily to form a non-reversible checksum together with a value that changes daily, and to determine your country from a database held on the same machine. It does not leave that server.
• No full browser identification string.
• No query strings — anything after a question mark in the address is removed before the data reaches the server.
• No transfer to a country outside the EU.

Classification and legal basis

This data is pseudonymised, not anonymous: a connection to you is theoretically possible. It is therefore treated as personal data. The legal basis is the legitimate interest in understanding which content is read (Art. 6(1)(f) GDPR).

Retention

24 months. Older records are removed by a nightly job. Backups are kept for 14 days, so a deleted record can still exist in a backup for that long.

Processors

The instance is operated by the party named in the imprint, engaged under Art. 28 GDPR. The servers are provided by Contabo GmbH (Munich, Germany), likewise under Art. 28: the instance itself runs in a data centre in France, and nightly backups are held on a second server in Germany. Both locations are inside the EU; no transfer to a third country takes place.

Your right to object

You may object at any time under Art. 21 GDPR, and we will exclude you. The contact address is in the imprint. If your browser sends a “Do Not Track” signal, you are not counted either.

The reports portal (reports.lumenda.eu)

Clients read their report at reports.lumenda.eu, logging in with a link sent to their email address. This is a separate processing step from the counting above, with its own data:

• Email address. Stored to send the login link and to recognise you after login. Legal basis: performance of the service contract (Art. 6(1)(b) GDPR). Kept until the session expires after 30 days; when the address is removed from the client list, the session ends at the latest on the next restart.
• Session cookie lr_session. 32 random bytes, HttpOnly, Secure, SameSite=Lax, valid 30 days. Strictly necessary to keep you logged in — no consent required (§ 165(3) TKG 2021). Only a SHA-256 checksum is stored server-side, never the plaintext.
• Rate-limit checksums. To prevent abuse, login requests are counted per address (5/hour) and per IP address (20/hour). Only SHA-256 checksums are stored, for 2 hours — no plaintext addresses, no plaintext IPs.

No access logs: the web server logs no portal visits — no IP addresses, no timestamps. No analytics scripts run on the portal. Login links are stored only as checksums, valid 15 minutes, single-use.

The login mail is sent via toSend (FluentCart Inc., USA) as a processor under Art. 28 GDPR. The email data (recipient address, content) is stored in the EU and sent from Frankfurt (EU); it is deleted after 14 days. The transfer to the US-based processor is based on EU Standard Contractual Clauses. The other servers (portal, analytics) are in France and Germany, inside the EU, as described above.