Compliance

A compliance summary of the service — for town clerks, comptrollers and data protection officers.

Privacy: No Cookies on the Town Website

Each town’s public website (archive, magazines, map and routes) uses no cookies and stores nothing in the visitor’s browser, with no third-party analytics or advertising. No consent banner is needed.

What is processed, and nothing else:

Technical server logs (IP address, browser, requested page) for security and operation, kept for at most 90 days. The IP address is also used for a few minutes to rate-limit the search, the chat and the play counter.
Questions to the magazine chat: the text is sent to Google (Gemini) to generate the answer; it is not stored in the database or linked to anyone.
Stats: aggregate counts per stop, language and day, without IP addresses or identifiers.
The staff backoffice uses one technical session cookie, exempt from consent.
Staff sign-in (and the trial sign-up form, once it opens) goes through Cloudflare Turnstile (Cloudflare, Inc.), a bot check that prevents automated access and abuse. Cloudflare processes the IP address and technical data about the browser and device (such as the user agent and TLS fingerprint); legal basis: legitimate interest in the security of the service (Art. 6(1)(f) GDPR). It sets no cookies on our domains (no pre-clearance). The town’s public website does not load it.

The town council is the controller of its website; En Antena Produccions SL (EnaCast) is the processor, under a standard data processing agreement (DPA).
Every town website publishes its own legal notice, privacy policy and accessibility statement (footer), filled from the council details configured in the backoffice.

Where the Data Lives

Server and database: OVHcloud, Frankfurt (EU).
Public website: Vercel, with functions pinned to Frankfurt (fra1); Vercel is a US company (transfer covered by the EU-US Data Privacy Framework).
Image and audio files: Backblaze B2, in the United States (us-east-005). Moving them to EU storage is planned; until then we do not claim that all data stays in the EU.
AI: Google (Gemini) for photo restoration and the magazine chat. Langfuse only receives model, usage and cost, never content.
Bot check on staff sign-in: Cloudflare Turnstile (Cloudflare, Inc.). It acts as a processor and, when it uses these signals to improve its bot detection, as an independent controller; it may process the data outside the EU under its data processing terms (Turnstile privacy addendum).

Accessibility (EN 301 549 / WCAG 2.1 AA)

Designed to meet level AA; each town’s statement says partially compliant (self-assessment) and lists the non-accessible content.
Full transcript next to every audio track.
Semantic HTML, labelled controls, visible focus, skip-to-content link.
Native browser audio controls (screen-reader compatible).
Plaques mounted at accessible height (90–140 cm).

Image and Voice Rights

Rights-assignment contracts with every narrator; only cleared images are published; scripts are EnaCast’s original work with an indefinite usage licence for the town.

AI Transparency (AI Act)

Photos restored or re-imagined by AI always carry an “AI-generated” label; the magazine chat is presented as an “AI assistant” and warns that its answers may contain mistakes. Unreviewed machine translations show a visible “automatic translation” label; synthetic narrations are labelled “automatic voice”. Once a human reviews the content, the label disappears — the indicator always reflects the current provenance.

Service Continuity

Permanent, remappable QR codes with destination monitoring; content also delivered as open files; visitors never pay or register.