Controller: Pintelly, Türkiye. Send privacy and data-subject requests to [email protected]. Pintelly currently has no establishment or appointed representative in the EU. The need for an Article 27 representative will be reassessed before actively offering the service to, or regularly monitoring people in, the EU.
1. Scope and our roles
Pintelly is the controller for account registration, membership and team administration, its marketing website, the public SEO checker, support, security and service communications.
When a Pintelly customer enables the widget, visitor analytics, heatmaps, video analytics or session replay on their own website, that customer generally determines why and how visitor data is processed. The customer is the controller and Pintelly acts as its processor under the customer's instructions. Visitors should normally direct requests to the website owner first.
2. Categories of personal data
- Account data: email address, password hash, OAuth provider identifiers, language, time zone, role and account timestamps.
- Project and team data: domains, invited-member emails, roles, permissions, project settings and audit records.
- Consented visitor and device data: random visitor/session identifiers, IP-derived approximate location, IP or masked IP, browser, operating system, device, referrer and page URL. Where the customer enables consent gating, this category is collected only after a positive consent signal.
- Anonymous measurement data: pre-consent PageViewed, numeric page-performance metrics and SEO checklist results stripped of content text, plus a daily-rotating HMAC derived from IP and user-agent. Raw IP/UA are not retained and no visitor or session profile is built.
- Behaviour and performance data: page views, clicks, scrolling, cursor movement, engagement time, video playback, Core Web Vitals, errors, console records and anomaly signals.
- Session replay data: DOM structure, visible text and mutation events. Password and form fields are protected by masking settings; customers remain responsible for configuring collection on their pages.
- Feedback data: written feedback, rating, optional name/email, screenshot, page context and customer-team comments.
- Monitoring and SEO data: checked URL/host, HTTP and SSL results, response time, titles/descriptions, heading structure, links, robots.txt/sitemap results and Search Console metrics.
- Integration data: Google or GitHub account email/login, authorisation tokens, selected property/repository and imported search or commit data.
- Communications, security and logs: notifications, service emails, administrator audit records, error records and technical anti-abuse data.
3. Purposes and legal bases
Providing account email and authentication data is necessary to enter into and perform the service contract. Without it, Pintelly cannot create or secure an account. Optional integrations, contact fields and consent-gated visitor features are not required to maintain a basic account.
- Provide accounts, authentication, projects, collaboration, monitoring, analytics, feedback and requested integrations: performance of a contract or steps before a contract (Article 6(1)(b)).
- Secure the service, prevent abuse, diagnose faults, keep audit trails and improve reliability using proportionate statistics: legitimate interests (Article 6(1)(f)).
- Process IP and user-agent for pre-consent pageview, page-performance and content-stripped SEO measurement for (i) a 60-second in-memory client rate-limit and (ii) a daily-rotating, irreversible uniqueness digest (HMAC): legitimate interests in service security, abuse prevention and proportionate measurement (Article 6(1)(f)). Raw IP/UA are not written into anonymous events or a persistent visitor profile; the digest becomes uncorrelated at each UTC day boundary.
- Comply with tax, accounting, regulatory and lawful authority requirements: legal obligation (Article 6(1)(c)).
- Operate non-essential analytics/recording technologies where consent is required: consent (Article 6(1)(a)); consent may be withdrawn prospectively at any time.
- Establish, exercise or defend legal claims: legitimate interests and applicable law.
4. Sources and collection methods
Data comes from Pintelly's website and dashboard, browser cookies and local storage, the JavaScript SDK installed by customers, API and WebSocket requests, PintellyBot server-side crawls, feedback forms, system logs, and Google Search Console or GitHub only when a user connects those services. Where a customer is the controller, data originates from that customer's website and its visitors.
5. Recipients and international transfers
We disclose data only as needed to hosting/storage, database, email, security, queue/cache and technical-support providers; to Google and GitHub when the relevant user enables those integrations; and to competent authorities where legally required.
Pintelly does not send data to OpenRouter automatically or in the background. A transfer starts only when an authorised dashboard user deliberately clicks “Analyze with AI” or regenerate. OpenRouter then receives only the limited content needed for that specific analysis. Before session analysis, Pintelly removes email- and phone-like strings and excludes the user identifier and raw user-agent. Free text can still contain personal data, so customers must assess the content and lawful basis before clicking the button.
Where data leaves the EEA, we rely on an adequacy decision where available or appropriate safeguards under Article 46, such as the European Commission's Standard Contractual Clauses, together with supplementary measures where required. Information about current subprocessors, locations and safeguards can be requested at [email protected].
6. Retention
- Visitor analytics events: up to 2 years from creation.
- Monitor-check history: 90 days.
- Session replays: 60 days by default; deployment configuration may set a different SESSION_REPLAY_RETENTION_DAYS value.
- Refresh tokens: up to 30 days, or earlier logout/revocation.
- Account, project, feedback, team, SEO, notification and integration data: while the account/project or feature remains active, then as required for legal obligations and claims.
- Projects scheduled for deletion: permanently processed after a 3-day recovery period; associated PostgreSQL and ClickHouse domain data is deleted.
- Public SEO-check logs and system/AI error logs: until the security, anti-abuse and audit purpose ends. No fixed automatic deletion period is currently configured for these records; their necessity must be reviewed periodically.
7. Profiling and AI-assisted analysis
Pintelly derives analytics, anomaly indicators, SEO scores and AI-generated summaries to help customers understand their websites. These outputs are advisory and do not produce legal or similarly significant effects about an individual. Pintelly does not use solely automated decision-making within Article 22. Customers must not repurpose these features for consequential decisions about people without their own lawful basis and safeguards.
8. Security
- Passwords are stored as non-reversible bcrypt hashes; integration credentials are encrypted and access-controlled.
- Ownership and role-based checks restrict project access, and administrator actions are audited.
- Session replay uses field masking, content-addressed storage and scheduled deletion.
- No system is completely secure. Suspected breaches are handled through containment, assessment and legally required notification procedures.
9. Your GDPR rights
Send requests to [email protected] with enough information to verify your identity and locate the relevant account or customer website. We normally respond within one month. That period may be extended by two further months for complex or numerous requests, with notice of the extension. Requests are generally free unless manifestly unfounded or excessive.
- Access, correction, erasure and restriction of your personal data.
- Object to processing based on legitimate interests and object at any time to direct marketing.
- Receive data you provided in a structured, commonly used, machine-readable format where portability applies.
- Withdraw consent at any time without affecting earlier lawful processing.
- Lodge a complaint with the supervisory authority in your habitual residence, place of work or place of the alleged infringement.
11. Changes and contact
We update this notice before materially changing a processing purpose or method. The current version and effective date appear on this page. Questions and rights requests can be sent to [email protected].