Privacy policy

Who is responsible

Alex Ostermann, Hauptstraße 142, 10827 Berlin, Germany, is responsible for operating PageClay. Contact: support@pageclay.com.

This policy covers the platform. Creators who collect personal data through their own pages determine the purpose of that collection and must give visitors their own privacy information.

Website delivery and security

Requests transmit your IP address, request time, requested resource, browser and connection information to our infrastructure so it can deliver content and protect the service. We process this information for our legitimate interest in reliable, secure operation (Article 6(1)(f) GDPR).

PageClay does not store IP addresses or browser user agents in account sessions. Short-lived, protected hashes derived from IP addresses limit abusive requests. Expired counters are cleaned up. These hashes are pseudonymous, not anonymous.

Cloudflare may retain technical request and error logs for up to seven days, depending on the plan. Application error events do not contain Account keys, response contents or uploaded files.

Your workspace and Account key

Creating a page starts a guest workspace. Simply viewing the home page does not create an account. Account identifiers, access-key hashes, sessions and activity timestamps provide and protect your requested workspace (Article 6(1)(b) and (f) GDPR).

The necessary sign-in cookie lasts up to 30 days and renews with use. We store a verification hash of your Account key, rather than the readable key. Your account reference identifies the workspace but does not grant access. Your chosen password manager processes saved credentials under its own terms and settings.

Google sign-in is disabled in the launch configuration. Without the necessary access information, we cannot provide access to a workspace or reliably restore an anonymous account.

Pages, images and publication

We store the page content, drafts, settings, formulas and images you provide to deliver your requested service (Article 6(1)(b) GDPR). Access to drafts and saved responses is restricted to their owning account.

Published pages and embedded images are publicly accessible through their links. A link is not password protection. Other people may share links or retain copies. Unpublishing stops public delivery but does not delete your draft or saved responses.

Visitor inputs and saved responses

Inputs and calculations initially stay in the visitor’s browser memory. A Send Response button sends the current inputs and calculated results only when the visitor activates it. Preview mode does not save a real response.

A saved response includes submitted values, results, timing information and the corresponding published page snapshot. The creator can view and delete it. Such content may contain personal data; the creator determines its purpose and must provide an appropriate lawful basis and visitor information.

Where we process personal data on a creator’s behalf, a separate data processing agreement is required before that processing. The information page below does not itself conclude an agreement.

Cookies and browser storage

Necessary cookies support sign-in and account security. The editor also stores local recovery copies containing draft content, revision and time information. Copies older than 14 days are rejected when read; this does not automatically erase browser storage while the browser is closed.

An unfinished account deletion may temporarily store a random retry ticket in the tab’s sessionStorage. It is removed after completion. The admin area uses a separate necessary session cookie that expires within 30 minutes.

Storage strictly necessary to provide a function you request is used under section 25(2)(2) TDDDG; related personal-data processing follows the purposes and legal bases described here. Clearing browser data may remove guest access before the underlying content is deleted.

No optional tracking at launch

Optional PageClay visitor measurement is disabled. It does not set visitor IDs or statistics cookies. The application includes no advertising trackers, remotely loaded fonts or social-media embeds.

If optional measurement or another non-essential service is introduced, we will update this information and obtain consent where required before it runs. Necessary infrastructure and security processing is separate from optional analytics.

Cloudflare and STRATO

Cloudflare provides DNS, HTTPS delivery, the application Worker, D1 database and R2 image storage. The database and image bucket use EU jurisdiction. This does not mean that every network, security or support activity takes place exclusively in the EU.

Cloudflare’s services can involve international processing, including in the United States. Applicable processor terms and transfer safeguards must cover that processing; EU storage alone is not a transfer safeguard. Cloudflare publishes its data processing terms and information on standard contractual clauses and the EU–US Data Privacy Framework.

STRATO provides our email service. When you email us, STRATO processes sender/recipient details, message contents and delivery metadata to receive, store and transmit the correspondence. Email is not used to send Account keys. Service providers may also process information to meet their own applicable legal obligations.

Support, content reports and administration

When you contact support@pageclay.com, we process your contact details and message to answer requests, handle rights or review reported content. Depending on the request, this is based on Article 6(1)(b), (c) or (f) GDPR. We keep correspondence while needed to resolve the matter and any necessary follow-up, then delete it unless a legal obligation or a concrete dispute requires retention.

In-app reports contain the report category, description and publication reference. Reports and moderation records are normally cleaned up after 90 days, including after ordinary page deletion. Admin sign-in and deletion audit records are also normally retained for 90 days. Only the operator manages access to the service.

Retention and deletion

Secured workspaces and their content normally remain until deleted or the service ends. You can delete individual responses, pages or your account. Account deletion removes associated drafts, publications, responses and images through a coordinated process; a technical failure leaves deletion pending until it can complete.

Empty guest workspaces may be deleted after seven inactive days once sessions have expired. Unpublished guest drafts enter a 30-day grace period after 90 inactive days. Workspaces secured with an Account key and guest workspaces with published pages are excluded from this automatic guest cleanup. Valid sessions and active uploads hold cleanup.

Completed account-deletion receipts are normally retained for seven days. Pending deletion jobs remain for retry. Database recovery copies expire within up to 30 days, depending on the Cloudflare plan. We cannot recall copies other people have downloaded or retained in their browsers.

Your rights and complaints

Subject to the legal conditions, you may request access, correction, erasure, restriction and data portability. You may withdraw consent for future processing. You may object to processing based on legitimate interests on grounds relating to your particular situation; an objection to direct marketing does not require those grounds.

Contact support@pageclay.com to exercise your rights. We may ask for appropriate proof that you are entitled to make the request. Never send your Account key. For a page operated by another creator, contact the controller identified on that page about their collection.

You may complain to a supervisory authority, particularly where you live or work or where you believe a violation occurred. For a Berlin-based operator, the local authority is the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin, Germany.

Automated decisions

PageClay does not itself profile visitors or make automated decisions about them with legal or similarly significant effects. Page results reflect the formulas and inputs configured by their creator. Creators must assess the requirements of their particular use.