Status: draft, pending legal review (input I10). Not legal advice. Last updated 2026-11-13. This is the explicit residency declaration the RFP asks for.
Declaration
This declaration describes the production deployment defined inresources/plan.md (hosting choices in section 5) and built in phases 15 and
16. As of this draft no production deployment exists, so nothing below is
yet observed in a running system. Phase 15 must make the deployment match this
text, or this text must change before it is published.
All analytics data is hosted in Microsoft Azure, region Sweden Central (EU), spread
over the region’s three availability zones.
What leaves the EU
- Analytics data: nothing. Web events, sessions, aggregates and API metrics are processed and stored only in the locations above.
- Console sign-in. Console users authenticate with GitHub. GitHub sees that a user signs in to the service. The control plane stores the numeric GitHub id and login only (plan 4.8). This concerns tenant staff, not end users.
- Operator access. Operators read aggregates through the console and the
machine API. Aggregates are counts per site and day. Whether an operator
outside the EU reading them is a transfer of personal data depends on
whether they are anonymous (open question in
privacy-strategy.mdsection 1). Production access to raw data (shell, database) is limited to the people listed in the deployment’s secrets recipients (plan input I14); from which countries they work is recorded inrecords-of-processing.mdonce known. - EU to US transfers. None for analytics data. For reference, the EU-US Data Privacy Framework was upheld by the General Court in T-553/23 (3 September 2025) and the appeal C-703/25 P is pending (S9).
- Access from Turkey. If a person with production access works from Turkey, that access to EU-hosted personal data is a transfer to a country without an EU adequacy decision (S7, the Commission’s list does not include Turkey), and standard contractual clauses are needed on the EU side. On the Turkish side, Law 6698 Art. 9 as amended by Law 7499 and the Regulation of 10 July 2024 require a standard contract to be notified to the KVKK Authority within five business days of signature (S7). Which of these applies to the actual operators is for counsel.
Tracker script
Tenants loadsdk.js from in.<BASE_DOMAIN> (the EU edge) or self-host the
same file. Events always go from the browser to in.<BASE_DOMAIN>. No CDN
outside the edge serves the tracker in the planned deployment.