This Data Policy explains how Sitelens ("we", "us", "our") processes data on behalf of our customers when they use our analytics platform. It is distinct from our [[Privacy Policy]], which covers visitors to the sitelens.cx website. This policy is designed to ensure transparency for businesses that subscribe to and deploy Sitelens.

1. Purpose of This Policy

When you install the Sitelens analytics script on your website, Sitelens acts as a Data Processor under GDPR. You, the customer (website owner), remain the Data Controller. This policy outlines what data is collected, how it is processed, and what safeguards are applied.

2. What Data We Collect via Sitelens Analytics

Sitelens is designed to provide useful insights and an overview of key performance indicators, without collecting personally identifiable information (PII). We process only:

• Event Types: Page views, clicks, element visibility, outbound link clicks, engagement metrics, and optional custom events.
• Data Fields: Site token, domain, session ID (anonymous), event type, element selectors/paths, page URL (without query strings), referrer domain (not full URL), device type/width, timestamp, country (derived from IP, IP not stored), and optional custom properties.
• Session IDs: Random, anonymous IDs stored in localStorage per site and browser. They do not identify individuals and are not shared across websites.

3. What We Do Not Collect

• No IP addresses (only country code is derived)
• No cookies for analytics tracking
• No cross-site identifiers
• No personal data such as names, emails, or payment information within analytics events

4. Custom Events

Customers may choose to send additional custom event properties. It is the customer's responsibility to ensure that no personal data is included unless proper consent has been obtained. Sitelens will process any received data under the same security safeguards, but disclaims liability for inappropriate data submissions.

5. Data Ownership and Access

• Customers retain full ownership of their analytics data.
• Sitelens acts only as a processor, storing and aggregating the data.
• Data is never sold, shared, or used for purposes other than providing the analytics service.

6. Hosting and Security

• All analytics data is hosted in EU-Central (Germany) via Digital Ocean and/or Hetzner.
• Data is encrypted in transit (HTTPS) and stored securely.
• Session IDs are stored locally in the browser only.

7. Data Retention

• Anonymous analytics data is retained for the period required to provide any Customer with the service that they have subscribed for, as detailed out in our subscription packages.
• After this period, data is permanently deleted from our systems.

8. Third-Party Providers

Sitelens uses a limited set of third-party services:

• Email Delivery (e.g., SendGrid, Postmark) for account-related notifications
• Payment Processing (if applicable) for subscription billing

These providers do not have access to customer analytics data, only to the business contact and account data, necessary for the service operation.

9. Cookies for Subscribers

While Sitelens analytics is cookie-free, our subscription platform uses cookies to:

• Store business account login sessions
• Remember authenticated users
• Store subscriber email addresses for platform access

These cookies are functional and necessary for account management, not for analytics.

10. International Data Transfers

Analytics data remains within the EU. In the event of international transfers of account data (e.g., to third-party providers), we rely on Standard Contractual Clauses (SCCs) and equivalent safeguards.

11. Legal Basis

For analytics processing, Sitelens relies on the legitimate interests of the customer to understand website usage without infringing on user rights. For subscriber account data (emails, billing), processing is based on contractual necessity.

12. Contact

For questions regarding this Data Policy:

Sitelens (operated by S.C. Haktos Creative S.R.L.)

Str. Panselelor 1, bl. P11, ap. 14, Sannicolau-Mare, Timis, Romania

Email: privacy@sitelens.cx