Skip to content

Record of processing activities

Article 30 of the GDPR requires us to keep a record of what we do with personal data. This is that record, published in full.

It is not a summary written alongside the register. The page reads the register: the same rows the retention job and the admin console read. If a line here is wrong, the platform is wrong, not the wording.

Everything is stored in the European Union. The database is created in Cloudflare’s Western Europe region and object storage in its EU jurisdiction. Cloudflare is the only processor in the list below, and it is US-headquartered, so its data processing addendum and the standard contractual clauses in it cover any access that follows from that.

Every entry last reviewed on or after 28 October 2026.

The activities

Index of processing activities, with lawful basis and whether a data protection impact assessment is required.
RefActivityLawful basisImpact assessment
PA-01Account and organization managementContract (Art. 6(1)(b))Not required
PA-02Event invitations and RSVPsConsent (Art. 6(1)(a))Required
PA-03Trail registryLegitimate interests (Art. 6(1)(f))Not required
PA-04Project updates and digestsConsent (Art. 6(1)(a))Not required
PA-05Award votingConsent (Art. 6(1)(a))Required
PA-06Moderation and auditLegitimate interests (Art. 6(1)(f))Not required
PA-07Data subject requestsLegal obligation (Art. 6(1)(c))Not required
PA-08Aggregate analyticsLegitimate interests (Art. 6(1)(f))Not required

PA-01. Account and organization management

PA-01: Account and organization management
PurposeAuthenticate organizers, maintain organizations, teams and roles so projects have accountable owners.
Lawful basisContract (Art. 6(1)(b))
ControllerCommons
Categories of personal dataemail, display name, avatar, session metadata.
Categories of data subjectorganizers, members.
RecipientsCloudflare (hosting, database, email delivery).
Transfers outside the EUNone beyond the processor described above.
RetentionUntil account deletion; sessions expire after 30 days.
Security measuresTLS in transit, data at rest in EU jurisdiction, magic-link auth with no stored passwords, role-based access.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-02. Event invitations and RSVPs

Special category dataImpact assessment required
PA-02: Event invitations and RSVPs
PurposeInvite named people to events, record their response, manage capacity and waitlist, and confirm attendance.
Lawful basisConsent (Art. 6(1)(a))
ControllerCommons and the organizing organization (joint)
Joint controllerThe organizing organization decides whom to invite; Commons provides the means.
Categories of personal dataemail, display name, RSVP response, attendance, custom answers.
Special category data (Art. 9)dietary requirements (may reveal religion or health), accessibility requirements (health).
Categories of data subjectinvitees, attendees.
RecipientsCloudflare (hosting, database, email delivery), the organizing organization.
Transfers outside the EUNone beyond the processor described above.
RetentionUnconfirmed invitations 90 days. Special-category notes hard-deleted 90 days after the event. Attendance records retained by the organizer.
Security measuresDouble opt-in before any mailing state; invitation tokens stored only as hashes; no account created without the subject's action.
Impact assessmentSpecial-category data at scale; DPIA required before public launch.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-03. Trail registry

PA-03: Trail registry
PurposePublish walking and cycling routes submitted by organizations, and review them for official registration.
Lawful basisLegitimate interests (Art. 6(1)(f))
ControllerCommons
Categories of personal datauploader identity, route geometry.
Categories of data subjectorganizers.
RecipientsCloudflare (hosting, object storage), the public.
Transfers outside the EUNone beyond the processor described above.
RetentionPublished routes retained indefinitely as a public registry; uploader attribution detached on erasure.
Security measuresGPS timestamps and device extensions (heart rate, cadence) stripped at ingest; exports regenerated from stored geometry rather than the original upload; optional trimming of route start and end.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-04. Project updates and digests

PA-04: Project updates and digests
PurposeSend followers an opt-in digest when a project they follow posts an update or schedules an event.
Lawful basisConsent (Art. 6(1)(a))
ControllerCommons
Categories of personal dataemail, follow relationships, digest preferences.
Categories of data subjectfollowers.
RecipientsCloudflare (email delivery).
Transfers outside the EUNone beyond the processor described above.
RetentionUntil the follow is withdrawn or consent revoked.
Security measuresSeparate consent purpose from platform email; one-click unsubscribe; suppression list consulted before every send.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-05. Award voting

Impact assessment required
PA-05: Award voting
PurposeRun time-boxed public voting rounds with one verified vote per person.
Lawful basisConsent (Art. 6(1)(a))
ControllerCommons
Categories of personal dataverified identity hash, ballot choice, IP hash, user agent hash.
Categories of data subjectvoters.
RecipientsCloudflare (hosting, bot protection).
Transfers outside the EUNone beyond the processor described above.
RetentionBallots retained for the round plus one year to allow challenge; identifiers hashed throughout.
Security measuresUniqueness enforced by a database constraint rather than application logic; ballots append-only; Turnstile on the ballot form.
Impact assessmentPublic voting is a high-abuse surface; assess before first round.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-06. Moderation and audit

PA-06: Moderation and audit
PurposeReview projects and trails before publication, and keep a tamper-evident record of platform decisions.
Lawful basisLegitimate interests (Art. 6(1)(f))
ControllerCommons
Categories of personal dataactor identity, action metadata, IP hash.
Categories of data subjectorganizers, administrators.
RecipientsCloudflare (hosting).
Transfers outside the EUNone beyond the processor described above.
RetentionRoutine entries two years; security-severity entries seven years.
Security measuresAppend-only; actor pseudonymized rather than deleted on erasure so the record of the erasure itself survives.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-07. Data subject requests

PA-07: Data subject requests
PurposeHandle access, portability, rectification and erasure requests within the statutory period.
Lawful basisLegal obligation (Art. 6(1)(c))
ControllerCommons
Categories of personal dataemail, request correspondence, export bundle.
Categories of data subjectany data subject.
RecipientsCloudflare (hosting, object storage).
Transfers outside the EUNone beyond the processor described above.
RetentionNo export bundle is stored: it is built on request and streamed. The download token expires after 15 minutes; the request record is retained as proof of compliance.
Security measuresIdentity verified by session before fulfilment; download links are a single 256-bit token, stored only as a hash, scoped to the requesting account, time-limited and capped at three redemptions.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

PA-08. Aggregate analytics

PA-08: Aggregate analytics
PurposeUnderstand which pages are used, without identifying anyone.
Lawful basisLegitimate interests (Art. 6(1)(f))
ControllerCommons
Categories of personal datapath, day, country, device class, referrer host.
Categories of data subjectvisitors.
RecipientsCloudflare (Analytics Engine).
Transfers outside the EUNone beyond the processor described above.
RetentionAggregated daily; rows deleted after ~2 years.
Security measuresWritten server-side only — no client beacon, no cookie, no IP or user id retained. Not personal data by construction, so no consent is required.
Impact assessmentNot required for this activity.
Last reviewed28 October 2026. Next review due 28 October 2027.

If something here is wrong

Tell us and we will correct the register, not the page. Contact details are on the imprint.

To see what we hold about you specifically, or to have it deleted, use your data page. You do not have to write to anyone.

The privacy page says the same things in plain language, including how long each kind of record is kept.