Data security: where is your data and who can access it?

Where is your data hosted?

Trackary’s database and servers are rented from netcup GmbH in Germany (Nuremberg), inside the European Union, with no transfer outside the EU. Files (documents, photos) and encrypted backups are stored with Cloudflare (R2 object storage); production files are kept in Europe.

All traffic with Trackary goes over HTTPS, an encrypted connection (TLS protocol). The server also enforces HSTS: your browser then only uses encrypted connections.

Every record carries the identifier of its organisation. The PostgreSQL database applies row-level security (RLS): one organisation cannot read another organisation’s data. Documents and photos are stored separately for each organisation and open through links valid for a few minutes.

Who can access your data?

In the app, rights depend on the role: owner, administrator or member. At The Level Code, access is restricted:

• production servers can only be reached with an SSH key (a secure login key), through an access point that is not publicly exposed;
• production secrets (technical keys and passwords) can only be read by the operations account; their backup copies are encrypted;
• the administration console and background jobs use a separate role; every access is logged with its reason;
• an audit log records sensitive actions; it is append-only: it cannot be edited or erased, except by deleting the organisation;
• to sign in: a password of at least 8 characters, stored in a form that cannot be read back, or a 6-digit code sent by e-mail, valid for 10 minutes, with at most 5 attempts;
• the API keys you create are stored in a form that cannot be read back.

Sub-processors and GDPR

The GDPR (General Data Protection Regulation, RGPD in French) distinguishes two roles. For the data your organisation enters (equipment, jobs, reports, time clocking…), your organisation is the data controller and The Level Code is its processor, within the meaning of Article 28. For your account data, The Level Code is the data controller. This framework is set out in the data processing agreement (in French), accepted when the organisation is created.

Here is the full list of sub-processors (the providers that process data for Trackary). Standard contractual clauses are a European Commission model contract that governs a transfer outside the EU. Any addition or replacement is announced by e-mail 30 days in advance; your organisation can object and, failing agreement, terminate without penalty.

Trackary AI: what goes to OpenAI

Trackary AI (the built-in AI assistant) uses OpenAI’s language models (United States). Apart from voice transcription, Trackary asks OpenAI not to store the responses. OpenAI may keep exchanges for up to 30 days to detect abuse, then deletes them.

• Neither The Level Code nor OpenAI uses your data to train models.
• Conversations are deleted automatically 12 months after their last message.
• Nothing is written to your fleet before you approve it.
• The administrator can switch the assistant off for the whole organisation or for certain roles. The analysis of documents uploaded in batches or received by e-mail, and the description of photos taken from the QR code, then remain active.

Backups, export and deletion

The database is backed up continuously with the pgBackRest tool, encrypted with AES-256 (a standard encryption algorithm) before being sent to storage separate from the server. The targeted maximum data loss is 5 minutes. Daily copies are also kept outside production: on an operations workstation in France, then, encrypted, in a second storage location in the EU. A restore test is scheduled every month.

The owner or an administrator can export the whole organisation at any time: a ZIP archive with one CSV file (spreadsheet) per category, documents, photos and closed reports as PDF, through a link valid for 7 days. Not yet in the archive, but supplied on request at contact@thelevelcode.com: meter readings, fault codes, e-mails received on the drop-off address, schedule assignments, timesheets and corrections, hourly rates.

At the end of the 30-day trial, the organisation moves to the free plan (5 active machines, 20 Trackary AI uses per month): you keep all your data, nothing is deleted.

Only the owner can delete the organisation, with a code received by e-mail; this can be cancelled for 30 days, then data, documents, photos, reports and exports are deleted. An organisation with no subscription and no activity for 24 months is deleted, after e-mails 60 and then 30 days before. Copies disappear from backups within 7 months at the latest. For your personal account, see delete your Trackary account.

In the event of a data breach, The Level Code informs your organisation without undue delay, at the latest 48 hours after becoming aware of it, and helps it notify the CNIL (the French data protection authority) within 72 hours.

What we do not promise: Trackary claims no security certification, and no online service is immune to incidents. To exercise your rights, write to contact@thelevelcode.com; you can also lodge a complaint with the CNIL (Commission nationale de l’informatique et des libertés), 3 place de Fontenoy, 75007 Paris, France.