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Records of Processing Activities (RoPA)

Last updated: 25 October 2026

This is JL Apps LLC’s register of processing activities under Article 30 GDPR. The small-entity exemption does not apply to routine website/CRM/billing processing, so we maintain this record. Controller and EU-representative position are in the Privacy Policy.

Controller & representative

Controller: JL Apps LLC (United States (Washington, non-EU)); registered agent address (for legal mail): 100 N Howard St, Ste R, Spokane, WA 99201, United States. Contact privacy@zonavra.com. Art 27 EU representative: Data Protection Representative Limited (trading as DataRep) (datarequest@datarep.com). Supervisory authority: none leads — as a controller established outside the EU there is no one-stop-shop, so complaints go to the competent EU authority, for the pilot market the Autoriteit Persoonsgegevens (Dutch DPA).

Processing activities

ActivityPurposeData categoriesSubjectsLegal basisRecipientsRetentionTransfers
Account & consumer onboardingCreate/operate accounts; record acceptance of the consumer termsEmail, terms version and acceptance time; company name / VAT number only for accounts that gave them at an earlier sign-upCustomersContract (6(1)(b))Clerk (auth), Neon (database); European Commission VIES only if a stored VAT number is re-entered (VAT number only)Until the account is deleted (self-service, immediate cascade); no separate time-based deletionUS (SCCs where applicable); VAT check to the EU
Billing & taxTake payment, issue invoices, remit VATBilling name, address, payment & invoice records; sign-in e-mail and account id sent by our servers to Paddle at checkout; cancellation and withdrawal requests (kind, time, subscription reference, the name given in a withdrawal statement, provider confirmation)CustomersContract (6(1)(b)); legal obligation (6(1)(c))Paddle (Merchant of Record / independent controller)Invoices are held by Paddle under statutory accounting retention. Our minimised webhook log is kept for seven years for anti-replay/payment integrity; provider references are pseudonymous while linkable to an accountUK/EU
Service usage & storageSaved parcels, projects, entitlement meteringSaved parcel refs and coordinates; project names, descriptions, pipeline status and free-text notes; usage counts; account idCustomersContract (6(1)(b))Neon (database), Vercel (hosting)Until the account is deleted (cascades with the account row)EU — functions pinned to Frankfurt (fra1); Neon project in an EU region
Security & abuse preventionRate limiting, logging, fraud/abuse preventionIP address/request metadata in hosting logs; on the public site: HMAC fingerprint of the client network — the IPv4 address or the IPv6 /64, no user-agent (fixed key, so stable across days) — and daily anonymous-preview count in Neon; timestampsAll visitorsLegitimate interest (6(1)(f))Vercel (hosting), Neon (durable anonymous-preview counter)Short-window rate-limit counters are discarded within minutes; anonymous-preview rows are keyed by UTC day and, where the production service uses a server database, deleted by a daily scheduled job once dated more than 31 days before the current UTC date (a missed run delays deletion); request logs follow Vercel's retention; deleted rows persist in Neon point-in-time recovery history for the provider's restore windowEU/US
Map & search deliveryRender the map and resolve address / parcel-ID searchesIP address and tile/feature requests (browser-to-provider); search terms and selected-parcel coordinates (via our servers)All visitorsLegitimate interest (6(1)(f)) — delivering the requested mapIndependent recipients: PDOK/Kadaster, 3D BAG, DSO-LV, European Commission VIESNot stored in our database. Search text and coordinates travel in request URLs and can be recorded in hosting request logs, which follow Vercel's retentionEU/US (per provider's own terms)
Optional analyticsAggregated product-usage insight (if enabled)Pseudonymous usage eventsConsenting visitorsConsent (6(1)(a))— none active todayNot applicable — no consent-based analytics is in use. Our servers do count a few page events (a landing or guide page view, the sample report or the plan dialog opened), each stored only as the event, a campaign label and the time — no identifier, no cookie and nothing stored on the device to count themNone — no consent-based analytics is in use
E-mail correspondence & preview requestsAnswer e-mail; send one preview invitation to a person who asked for it; optional product updates only on requestE-mail address, any name given, message content and time, whether updates were requestedPeople who e-mail usLegitimate interest (6(1)(f)); steps at the person's request (6(1)(b)); consent for updates (6(1)(a))Zoho Mail (mailbox)Until answered, at most 12 months after the conversation; a preview or updates request until five years after the last e-mail sent on that basis; after "stop" only the address on a do-not-contact listNone — Zoho EU data centre

Sub-processors & independent recipients

Sub-processors we instruct (Art 28): Vercel, Clerk, Neon, Resend, Zoho Mail, each under an Art 28 data-processing agreement that is in place. Paddle acts as Merchant of Record and is an independent controller of buyer payment data. Technical & organisational measures include TLS in transit, access controls, least-privilege secrets, and API rate limiting.

Independent recipients (not processors): service.pdok.nl, data.3dbag.nl, api.pdok.nl, service.pdok.nl, service.omgevingswet.overheid.nl, ec.europa.eu. Some map services are contacted directly by the visitor’s browser and receive the visitor IP; search, VAT and zoning services are called by our servers and receive only the relevant query. The Privacy Policy table identifies which path applies to each recipient — see the Privacy Policy §6.

This record is maintained internally and summarised here for transparency. Data processing agreements with the processors listed above are in place. A feature showing owner or price data would get its own data protection impact assessment before it is built.
Records of Processing (RoPA) — Zonavra