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Disclose the signup form's Cloudflare Turnstile check in the legal pages - #4

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foobacca merged 3 commits into
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890-turnstile-legal-docs
Sep 28, 2026
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foobacca merged 3 commits into
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890-turnstile-legal-docs

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sortitionfoundation/opendlp#316 adds a Cloudflare Turnstile bot check to the account signup form (/auth/register). The widget runs in non-pre-clearance mode, so it sets no cookies — the no-consent-banner position still holds and the cookie table on the cookies page stays correct as is. But the signup page now loads a script and challenge iframe from challenges.cloudflare.com, and the visitor's IP address and browser characteristics reach Cloudflare, a US company. Two public pages claimed neither of those things happens; this PR brings them in line with the analysis in opendlp's backend/docs/personal-data.md.

Cookies page

  • New section "Bot protection when you create an account": the check sets no cookies and stores nothing on the device; what is sent to Cloudflare (IP address, browser characteristics) and why; signup page only; not used for advertising or cross-site tracking.
  • "Cookies from other companies" now also discloses the privacy-enhanced YouTube embeds allowed on registration pages (opendlp issue #769). These predate the Turnstile change, but the blanket "no embeds" wording was already ahead of reality, so this fixes both in one pass.
  • Bumped the last-reviewed date.

User data agreement

  • 4.4 Legal basis: the bot check is placed under the same legitimate-interest basis as the existing IP-address bullet (lawful operation, preventing misuse).
  • 4.5 Data processors: names Cloudflare, Inc. and scopes exactly what it processes and what it does not do with the data.
  • 6 Data transfer: the flat "no transfers outside the EEA" claim now carries the one exception, relying on Cloudflare's certification under the EU–US Data Privacy Framework.

⚠️ One decision to confirm before merging: section 6 cites the EU–US Data Privacy Framework as the transfer safeguard. Cloudflare, Inc. is DPF-certified, but if the Foundation would rather rely on standard contractual clauses (or word it more generically), that bullet is the place to change.

🤖 Generated with Claude Code

https://claude.ai/code/session_01CV1KJkfe2FGmDg6dJkCnou

opendlp PR #316 adds a Cloudflare Turnstile bot check to the account
signup form. The widget runs in non-pre-clearance mode, so it sets no
cookies and the no-cookie-banner position still holds - but the signup
page now loads a script and challenge iframe from Cloudflare, and the
visitor's IP address and browser characteristics reach a US company.
Two public pages claimed neither of those things happens.

The cookies page gets a section describing the check (no cookies,
what is sent to Cloudflare, signup page only) and its "Cookies from
other companies" section now also covers the privacy-enhanced YouTube
embeds on registration pages, which predate this change but were
likewise undisclosed.

The user data agreement names Cloudflare as a processor in section 4.5,
extends the legitimate-interest basis in 4.4 to the bot check, and
qualifies the section 6 claim that no data leaves the EEA, citing
Cloudflare's EU-US Data Privacy Framework certification.

Co-Authored-By: Claude Fable 5 <noreply@anthropic.com>
Claude-Session: https://claude.ai/code/session_01CV1KJkfe2FGmDg6dJkCnou
@foobacca
foobacca requested a review from nickpgill September 25, 2026 08:06
Changed references to "signup page" to "assembly manager's signup page".
Changed "account signup form" to "assembly manager's account signup form".
@foobacca
foobacca merged commit 02191d2 into main Sep 28, 2026
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@foobacca
foobacca deleted the 890-turnstile-legal-docs branch September 28, 2026 15:38
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3 participants