Privacy

What we record when you use tolven.eu or the API, why, and for how long.

The controller

Tolven is a trade name of Zielmaker (KvK 69300399), in the Netherlands. Zielmaker is the controller for everything described here. Write to hello@tolven.eu. The address reaches the operator.

What the API records

We do not store IP addresses. The API writes one record per request. The record holds the method, the route and its parameters, the zone you asked for, the status, the response time and the size. It also holds your user agent, the host of the referring page, a two-letter country code and a client identifier.

We derive the identifier from your IP address with a key that exists only in server memory. The key is replaced every day. We cannot reverse the identifier. We cannot follow it from one day to the next.

If the API refuses a request, the record also says which rule the request broke. It may also name the parameter involved. It does so only when what you sent looks like a parameter name. It does not add any value you gave a parameter.

Requests with an API key

The API records a request made with a key the same way, with one difference. In place of the daily identifier, the record carries your key's name. The name is a random code that does not say who you are. We keep the link between the name and you in one place, outside our servers.

The name stays the same for as long as the key exists. That lets us see how you use the key over time. The API also counts requests per key, route and status. It never records the key itself.

What the website records

The web server writes one line per page request: time, method, path, status, size, referring host and user agent. The line carries no address and no identifier.

What we hold briefly

Rate limiting counts requests per IP address, or per key when you send one. The API holds the address in memory for the seconds a counter lives. It never logs the address. Cloudflare delivers the site and the API on our behalf. It handles your address to do so.

Purpose and legal basis

We use the records to learn whether the API has users. They tell us whether a burst of traffic is one client or many. They show which series and zones people want. Refused requests show where the API or its documentation trips people up. The legal basis is our legitimate interest, GDPR Article 6(1)(f). We wrote the assessment down. We send it on request.

If you have a key, we use it and your contact details to provide the access the key grants. That is necessary for our agreement with you, or for a trial you asked for before one. The legal basis is GDPR Article 6(1)(b). We need a contact to issue a key. If the key belongs to your organisation, we keep your contact details to reach it, on our legitimate interest, Article 6(1)(f). We also record how you use the key. Those records tell us whether key holders use their keys, and which series they want in depth. That rests on our legitimate interest, Article 6(1)(f).

Retention

We keep both logs for 30 days. Then the log store deletes them. We share them with nobody. Apart from the link between a key's name and its holder, we combine them with no other data.

We keep per-key request counts for up to 13 months, in less detail after the first 30 days. The counts carry only the key's name. When our dealings with you end, we delete our record of who held the key. We do so once nothing still needs that record. Your contact details go with it.

Our server configuration keeps each key's name and the dates we added and removed it. We keep that history without a time limit. That history does not say who held the key.

The site sets no cookies, has no accounts, and runs no analytics or advertising scripts.

Your rights

You can ask for access, erasure or restriction. You can object to the processing. Write to the address above. Without a key, we will usually be unable to find your records, because nothing in them says whose they are. If you send a user agent, a date and rough times, we will look.

If you have a key, we can find your records by its name. Ask, and we will send them to you, or delete the link between the name and you. We will also correct your contact details, or send them to you in a common format. If you object to us recording how you use your key, we may have to revoke the key. The API cannot yet leave one key out of its records.

You can also complain to the Dutch regulator, the Autoriteit Persoonsgegevens.