Understandable privacy, tool by tool

Information to complete before publication

This draft describes the processing identified in the repository and configured services. Before marking it as final, verify the retention periods that remain unconfirmed, including Resend event retention, and enter into or accept the applicable data processing agreements.

1. Data controller

The data controller is Seeft di Bufarini Simone, an Italian sole proprietorship with registered office at Via Ponte Pio 6, 60035 Jesi (AN), Italy, VAT number 02983090420, Business Register/REA number AN-297752 (“Seeft” or the “Controller”).

Privacy contacts:

• email: simone@seeft.io;
• certified email (PEC): simone.bufarini@pec.it.

The Controller has not appointed a data protection officer (DPO). Privacy requests may be sent to the contacts above.

2. Scope of this notice

This notice is provided under Articles 12–14 of Regulation (EU) 2016/679 (“GDPR”). It applies to seeft.io, www.seeft.io and tools.seeft.io, including tools, accounts, contact forms, suggestions and related features. Third-party websites and services reached through links apply their own notices.

3. Personal data processed

Depending on the features used, Seeft processes:

• technical and security data: IP address, date and time, requested URL, user-agent, application logs, device information and data needed to prevent abuse;
• account data: name, email, image, OAuth provider and identifier, preferences, role, plan, last sign-in date, sessions and technical authentication tokens;
• account usage data: favorite tools, votes, saved transformation configurations, execution counts and dates;
• tool suggestions: title, descriptions of the problem, current process, expected input and output, frequency, potential audience, external services and the declared data-sensitivity level;
• communications: name, email, company, budget range, project type and contact-form message; for emails sent by Seeft, delivery metadata and data about selected links;
• optional analytics events: pages, referrer, approximate location, browser, operating system and device data, and allowlisted product events;
• optional diagnostic data: errors, stack traces, performance information, technical context and masked session replays;
• privacy choices: random consent identifier, action, accepted and rejected categories and services, language, hostname, policy versions, banner revision and date; for signed-in users, the internal account identifier may also be associated.

Seeft does not use personal data for behavioral advertising and does not sell personal data. It does not combine activity across devices for profiling.

4. Purposes, legal bases and retention

| Processing | Purpose | Legal basis | Intended retention | | --- | --- | --- | --- | | Website delivery, technical logs and security | Deliver pages and APIs, prevent abuse, investigate incidents and protect systems and users | Performance of the requested service; Controller’s legitimate interest in security (GDPR Art. 6(1)(b) and (f)) | Routine logs for the period configured with the host and no longer than 90 days; longer only where required for an incident or legal claim | | Account and OAuth sign-in | Create the account, authenticate the user, maintain sessions and administer access and roles | Contract or steps requested by the user (Art. 6(1)(b)) | For the life of the account; sessions until expiry, normally 30 days; deletion on request unless retention is required by law or for a dispute | | Favorites, votes and saved transformations | Provide user-requested account features | Contract (Art. 6(1)(b)) | Until deleted by the user or the account is deleted | | Suggestions and roadmap | Review suggestions, send status updates and, if approved, publish a non-personal summary | Requested service (Art. 6(1)(b)); legitimate interest in managing and documenting the roadmap (Art. 6(1)(f)) | During review and for up to 24 months after closure; published summaries may remain without a link to the author | | Contact form | Respond to information or commercial enquiries | Pre-contractual steps requested by the person (Art. 6(1)(b)) or legitimate interest in handling general communications (Art. 6(1)(f)) | Up to 24 months after the last communication, unless a contract or legal claim requires longer retention | | Suggestion status emails | Send requested operational communications | Performance of the service (Art. 6(1)(b)) | Until the preference is disabled or the account is deleted | | Click tracking in operational emails | Determine whether and when links in communications are used, assess their effectiveness and diagnose problems | Legitimate interest in improving and securing communications (Art. 6(1)(f)), subject to a balancing assessment | According to Resend’s retention period, which remains to be confirmed; the current code does not receive events through webhooks | | Non-essential product updates, including any click measurement | Send and measure optional communications | Consent (Art. 6(1)(a)) | Until withdrawal; evidence follows the consent-register period; vendor events follow its retention period, which remains to be confirmed | | Umami and first-party product analytics in the browser | Measure usage, journeys and feature adoption to improve the service | Consent (Art. 6(1)(a) GDPR and applicable ePrivacy rules) | Local identifier for 182 days; Umami Cloud retention to be confirmed with the vendor, with a target maximum of 13 months; Seeft events deleted or aggregated within 13 months | | Browser-side Sentry and masked replay | Detect client-side errors and performance problems | Consent (Art. 6(1)(a) GDPR and applicable ePrivacy rules) | 30 days, according to the Sentry project configuration | | Server-side Sentry | Diagnose backend errors without reading or writing identifiers on the user’s device | Legitimate interest in service security and reliability (Art. 6(1)(f)) | 30 days, according to the Sentry project configuration | | Privacy-choice register | Record choices, changes and withdrawals and demonstrate compliance | Legal obligation and legitimate interest in defending claims (Art. 6(1)(c) and (f); Art. 7(1) GDPR) | Five years from the event, unless required for pending proceedings | | Administrative audit trail | Trace privileged operations and investigate abuse | Legitimate interest in security and accountability (Art. 6(1)(f)) | 24 months, unless needed for an incident or dispute |

Where processing relies on legitimate interests, Seeft applies minimization, access restrictions and limited retention. You may ask for information about the balancing assessment and object on grounds relating to your particular situation.

The periods above must be implemented in deletion procedures and verified in Vercel, Neon, Sentry, Umami and Resend settings before final publication.

5. Locally processed tools

Tools marked as “local” process inputs, files and outputs in the browser. Their content is not intentionally sent to Seeft. Data remains under the user’s and device’s control, however, and browser extensions, local software or networks not managed by Seeft may have independent access.

Do not enter personal, health or criminal-offence data, credentials, secrets or third-party data unless you have a lawful basis and appropriate safeguards. If a future feature requires cloud processing, that fact must be disclosed before upload.

6. Required and optional data

Fields marked as required are needed to provide the requested feature. Without them, that feature cannot be provided, but public tools that do not require an account remain available. Analytics, browser diagnostics and product updates are optional; refusing them does not restrict essential features.

7. Sources

Data comes from the user, the device and interactions with the service. When the user signs in, Google or GitHub provides the profile data authorized by the user. If a suggestion is published, its summary is derived from the submission but is managed separately from the author’s identifying data.

8. Recipients and vendors

Authorized personnel and contractors access data only where necessary. The following parties may also process it, depending on the feature used:

| Vendor | Function and indicative role | Main area/configuration | | --- | --- | --- | | Vercel | Hosting, CDN and server functions; processor for service data | Functions configured in Frankfurt (fra1), with potentially international infrastructure and support | | Neon | PostgreSQL database; processor | Project intended/configured in Frankfurt | | Google and GitHub | OAuth providers; independent controllers for their accounts and processors or recipients for the authentication flow | Global infrastructure | | Resend | Email delivery, delivery metadata and click tracking; processor for data sent by Seeft | United States and the vendor’s listed subprocessors | | Umami Software, Inc. | Umami Cloud analytics, Hobby plan; processor | EU account region | | Functional Software, Inc. (Sentry) | Error, performance and replay monitoring, Developer plan; processor | EU data region, using the Germany ingestion endpoint (ingest.de.sentry.io) |

OAuth providers also apply their own notices: Google and GitHub. Vendor documents include Vercel, Neon, Resend, Umami and Sentry.

For Seeft’s email domain, Resend click tracking is enabled and open tracking is disabled. Resend replaces tracked links with unique links that pass through its systems before reaching the destination; this allows the selected link and click time to be associated with the message and may involve processing the IP address, browser and device data. No tracking pixel is inserted merely to detect that an email was opened. This activity is not controlled by the website cookie banner because it occurs when a recipient selects a link in an email.

Seeft may also disclose data to public authorities, advisers or counterparties where required by law or to establish, exercise or defend rights. Data is not made public except for roadmap summaries intentionally published without the author’s identifying data.

9. Transfers outside the European Economic Area

Some vendors or their subprocessors are established or operate outside the EEA. Where applicable, transfers must rely on an adequacy decision, including the EU–US Data Privacy Framework for certified recipients, or the European Commission’s Standard Contractual Clauses and any necessary supplementary measures. You may request information or a copy of the relevant safeguards from the Controller.

Before final publication, applicable DPAs and subprocessor lists must be verified and retained, and data-residency and deletion settings must be documented. The Umami account is in the EU region and the Sentry project uses the EU data region.

10. Consent and privacy choices

Optional technologies remain disabled on the first visit. Users may accept all, reject all or select individual services. Closing the banner rejects optional technologies. Choices may be changed or withdrawn at any time through “Cookie preferences” in the footer. Withdrawal does not affect the lawfulness of earlier processing.

The individual technologies are described in the Cookie policy.

11. Data subject rights

Where Articles 15–22 GDPR apply, individuals may request access, rectification, erasure, restriction, portability and objection, and may withdraw consent. They may opt out of non-essential communications at any time.

Requests may be sent to the Controller’s contacts. Proportionate information may be requested to verify identity. A response is normally provided within one month, extendable by two months in the complex cases allowed by the GDPR.

You may lodge a complaint with the Italian Data Protection Authority or the authority for your residence, workplace or the place of the alleged infringement, and seek a judicial remedy.

Residents of other jurisdictions may exercise additional rights granted by applicable local law. Seeft does not sell personal information or share it for cross-context behavioral advertising.

12. Children

The service is not directed to children under 14 and Seeft does not knowingly collect their data. In Italy, a person aged 14 or over may consent to data processing for information-society services within the limits of applicable law; this does not give them capacity to enter every contract independently. Users aged 14–17 may use free features, but purchasing a paid plan or taking an action that requires contractual capacity requires authorization from a parent or legal guardian. If non-compliant collection is identified, the data will be deleted or restricted.

13. Automated decisions and profiling

Seeft does not make solely automated decisions that produce legal or similarly significant effects. Usage statistics are not used for behavioral advertising or individual scoring.

14. Security

Seeft applies proportionate technical and organizational measures, including authenticated access, administrative roles, minimization, request limits and replay masking. No system is risk-free; any breach will be handled under applicable notification and remediation duties.

15. Changes

The version and effective date appear at the top of this page. Material changes will be communicated by proportionate means. A new choice will be requested when consent-based purposes, categories or services materially change.