Privacy policy

Controller

Tobias Bucci
Mühlenweg 51, St. Sigmund
39030 Kiens (BZ), Italy
Email: buccitobias774@gmail.com

Scope

This policy covers the website www.digitalesregister.com, the notification service api.digitalesregister.com and the admin area. The app “Digitales Register” (also “Schulregister Südtirol”) has its own app privacy policy.

Website and notification service

Each request technically involves: IP address, user agent, requested path with parameters and time. For the notification service this adds the parameters platform, app version and language.

The purposes are delivering pages and notifications, security, abuse protection and rate limiting. The legal basis is Art. 6(1)(f) GDPR: our legitimate interest is secure and reliable operation.

The website uses no analytics, no advertising and no content from other servers.

Server logs and retention

The web server (Caddy) and the notification server write no access log.

For rate limiting, the IP address (for IPv6 the first 64 bits) is held in memory only. It is not written to disk and is lost when the service restarts or the table is cleaned up.

Only on a server error (HTTP status 5xx) does the web server write the IP address, the requested address with parameters and the request headers, without cookies, to the server’s system log. The system log is deleted after 15 days at the latest.

Notification service

The service is public and needs no account or login. The app sends platform, app version, language and technical values for paging and caching (limit, cursor, ETag). It sends no account, school or grade data, no device identifier and no advertising ID.

The server stores nothing from these requests, except in the error case described above. There are no push services (no APNs, no FCM), no cookies and, in this phase, no usage analytics. Read and dismissed notifications are recorded on the device only.

Cloudflare

The website, the notification service and the admin area run through Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare provides DNS, proxy and CDN, TLS termination, DDoS protection and, for the admin area, Cloudflare Access. Because encryption ends at Cloudflare, Cloudflare sees IP addresses, request headers and the requests themselves.

According to Cloudflare, it is a processor for customer logs and a controller for other personal data. Cloudflare states that it primarily stores data in the United States and the European Economic Area, so a transfer outside the EU is possible. As safeguards Cloudflare names its certification under the EU-U.S. Data Privacy Framework and, should that lapse, standard contractual clauses.

Responses carry Cloudflare headers for Network Error Logging, with which supporting browsers can report connection errors to Cloudflare. The legal basis is Art. 6(1)(f) GDPR.

Details: Cloudflare privacy policy (4 November 2025), Data Processing Addendum (version 6.4, 3 April 2026), sub-processors.

Hosting at Oracle

The server is a virtual machine on Oracle Cloud Infrastructure (Always Free) in the Milan region, Italy (eu-milan-1). According to Oracle, it acts as a processor. For transfers from the European Economic Area, Oracle names binding corporate rules for processors or standard contractual clauses, and the EU-U.S. Data Privacy Framework.

Details: Oracle Services Privacy Policy, Oracle Data Processing Agreement.

Admin area

The admin area is for the operator only. Access is protected by Cloudflare Access with a one-time PIN sent by email and by a separate login with a session cookie. If someone enters an email address on the Cloudflare Access login page, Cloudflare processes it to check access.

Failed logins are counted without a plain IP address and deleted after one day; backups are deleted after 14 days. The legal basis is Art. 6(1)(f) GDPR.

Cookies and local storage

The public pages set no cookies, use neither localStorage nor sessionStorage and load nothing from other servers. That is why there is no cookie banner.

Cookies exist only in the admin area, and all are strictly necessary: __Host-dr_session keeps the session (ends after 30 minutes without activity, after 12 hours at the latest), __Host-dr_challenge lasts 5 minutes during login. Cloudflare Access sets its own authentication cookies, for example CF_Authorization and CF_AppSession.

Under Art. 122 of the Italian Privacy Code (D.Lgs. 196/2003), technical cookies need no consent. The legal basis is Art. 6(1)(f) GDPR.

The app

Register data travel directly between the device and the chosen school register; the app’s operator does not receive them. The school and its register provider are responsible for the data in the register. Only with consent does Google (Firebase Crashlytics, Google Analytics for Firebase with export to BigQuery in the EU) process diagnostic and usage data. Details are in the app privacy policy.

Recipients and transfers

The recipients are Cloudflare and Oracle as described above. Data on the server stay in the Milan region; transfers outside the EU are possible at Cloudflare. Beyond that, we pass on data only where the law requires it. We do not sell data.

Your rights

You have the right of access, rectification, erasure, restriction of processing and data portability (Arts. 15 to 20 GDPR). You can object to processing based on legitimate interests (Art. 21 GDPR) and withdraw consent at any time for the future. Write to buccitobias774@gmail.com. We use your address and message only to answer you; the mailbox is hosted by Google.

Because there are no accounts and no access log, we usually cannot link requests about connection data to a person.

Complaints

You can complain to the supervisory authority: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it.

Obligation to provide data, automated decisions

You are not obliged to provide data. Without the technically necessary connection data, however, pages and notifications cannot be delivered. There is no automated decision-making and no profiling.

Changes

Version 5 of 7 November 2026 is the first complete version for the website, notification service and admin area. Changes are published here with a new date.