Compliance

GDPR

• The town hall is the data controller; Enantena is the processor under a standard DPA (art. 28 GDPR).
• Data processed: newsletter subscriber emails (consent with verifiable double opt-in) and staff accounts.
• Application servers in the EU (Frankfurt); sub-processors listed in the DPA; an unsubscribe link in every email; the list is handed over on the town’s request.
• Public pages carry no tracking cookies.
• Bot check: the public subscription form and the staff access pages (sign-in, password recovery, trial sign-up once it opens) use Cloudflare Turnstile (Cloudflare, Inc.) to tell people from bots and prevent automated submissions. It processes the IP address and technical data about the browser and device (such as the user agent and TLS fingerprint), sets no cookies on our domains (pre-clearance off) and is a security measure necessary to provide the service (art. 32 GDPR). Cloudflare acts as a sub-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

Citizen-facing pages are built to meet WCAG 2.1 AA / EN 301 549. Current status: partially compliant, by self-assessment, until a full audit is done (accessibility statement). The embedded widget inherits the official site’s fonts and colours (final contrast depends on that site). Radio audio and printable posters complement the digital channel.

AI transparency (AI Act)

All AI-generated content shows a visible indicator (“AI-generated”, “automatic translation”, “AI voice”) which clears once a human reviews it. Nothing is published without human approval. Translations carry a permanent notice: the original is the only legally valid text.

Records and proof

Delivery log per post and channel; individual email log; daily backups with documented recovery.

Screens (TV)

• The screen page is a public surface with no cookies, no external services and no analytics; only aggregate connectivity (that the TV is online) is counted. Nobody is identified.
• Each screen’s link is a device key: it can be regenerated at any time and is redacted from server logs.
• Accessibility: any key or tap pauses the rotation (WCAG 2.1 SC 2.2.2); static-board mode has no motion; the same content is accessible on the town’s public pages. AA contrast on every slide.

Documents available on request

Signed DPA, accessibility statement, technical description and security measures (Spanish ENS basic level), justification report for procurement.