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Privacy Policy

Effective date: 14 February 2026

01Data Controller

UAB TRANSERTA
Geliu g. 18
Klaipeda, LT-91211
Lithuania
Registration no. 141929931

UAB TRANSERTA ("we", "us") operates Distroboard, a content distribution platform. We are the data controller for any personal data processed through this service.

02Data We Collect

We process the following categories of personal data:

• Authentication identity — email address and name provided via Cloudflare Access single sign-on
• Content created — articles, images, and pins you generate or distribute through the platform
• Site credentials — WordPress API keys and site URLs you configure for content publishing
• Usage metrics — API costs associated with content generation (Gemini AI usage tracking)

03Legal Basis

We process your data under GDPR Article 6(1) on the following grounds:

• Contract performance (Art. 6(1)(b)) — processing necessary to provide you with the Distroboard service as agreed
• Legitimate interest (Art. 6(1)(f)) — service operation, security monitoring, and cost tracking to maintain and improve the platform

04How We Use Data

Your data is used exclusively for:

• Content generation and distribution — creating articles and images via AI, publishing to your configured WordPress sites, and managing Pinterest pins
• Cost tracking — recording API usage costs per post to help you monitor spending
• Service operation — authenticating your identity, storing your preferences, and maintaining platform functionality

05Data Processors

We use the following third-party processors:

• Cloudflare, Inc. — hosting (Cloudflare Pages), database (D1), object storage (R2), and zero-trust authentication (Access)
• Google LLC — AI content generation via the Gemini API

Each processor is bound by a data processing agreement and processes data only on our instructions.

06Data Retention

Your content, configuration, and usage data are retained for as long as your account is active. You may delete individual posts, sites, or pins at any time through the platform interface. Upon account deletion, all associated data is permanently removed from our systems.

WordPress site credentials are stored encrypted in Cloudflare D1 and are never exposed through the user interface after initial configuration.

07Your Rights (GDPR Art. 15–22)

Under the General Data Protection Regulation, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — correct inaccurate personal data
• Erasure — request deletion of your personal data ("right to be forgotten")
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interest
• Restriction — request that we limit processing of your data

To exercise any of these rights, contact us at hi@topreviewed.org. We will respond within 30 days.

08International Transfers

Your data may be transferred to and processed in countries outside the European Economic Area, specifically the United States, where Cloudflare and Google operate infrastructure.

These transfers are safeguarded by Standard Contractual Clauses (SCCs) approved by the European Commission, as incorporated into the data processing agreements with each processor.

09Cookies

Distroboard uses only strictly necessary cookies set by Cloudflare Access to maintain your authenticated session. These cookies are essential for the service to function and cannot be disabled.

We do not use analytics cookies, advertising cookies, or any third-party tracking technologies.

10Security

We protect your data through:

• Zero-trust authentication — all application access is gated by Cloudflare Access identity verification
• HTTPS encryption — all data in transit is encrypted via TLS
• Encrypted infrastructure — data at rest is encrypted by Cloudflare across all storage services (D1, R2)

11Policy Changes

We may update this privacy policy from time to time. Material changes will be communicated by updating the effective date at the top of this page. We encourage you to review this policy periodically.

12Contact & Supervisory Authority

For any privacy-related questions or to exercise your data rights:

hi@topreviewed.org

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI):

Valstybine duomenu apsaugos inspekcija
L. Sapiegos g. 17
Vilnius, LT-10312
Lithuania
vdai.lrv.lt