Privacy policy
Draft version — not yet legally reviewed. This text may change.
This privacy policy describes how Bayana processes personal data within the platform. It is a draft version, based on how the product actually works; the final text will be legally reviewed before it becomes binding.
Who is responsible for which data
Your organisation (the association, club or foundation using Bayana) is the data controller for its members' data. Bayana acts as a data processor: we process data solely on behalf of, and according to the instructions of, your organisation, as set out in the data processing agreement.
What data Bayana processes
Depending on your organisation's settings, this can include: name, address, contact details, membership details, contribution amounts and payment status, and (where applicable) SEPA direct debit mandate details. Bayana never asks for a national ID number. Optional dossier functionality for sensitive data (such as medical or behavioural information) is disabled by default and requires an explicitly recorded legal basis and purpose before an organisation can use it.
Security and separation between organisations
Every organisation gets its own, technically separated database schema (schema-per-tenant); data from one organisation is never visible to another. Access is based on passwords hashed with Argon2 and tokens (JWT) with a limited lifetime. Roles and permissions are restrictive by default (deny-default): a user only sees what matches their role.
Masking of bank details
The counterparty IBAN on a bank transaction is shown masked in logs, exports and overviews (for example NL12…4300). Full IBANs are never unnecessarily exposed outside direct payment processing.
Retention periods
Retention periods are set per data type and, where applicable, configurable by the organisation. Data that exceeds its retention period is removed through an automated process.
Subprocessors
To operate the platform, Bayana uses the following subprocessors: PostgreSQL (database hosting), MinIO or an S3-compatible storage service (storage of bank statements and exports), Cloudflare (network, security and access control), an email provider (Resend or SMTP, defaulting to Mailpit in development environments) for transactional email, and a payment provider (Mollie or Stripe) for iDEAL payment links and subscription payments. An up-to-date list of subprocessors is available on request.
Data subject rights
Members with questions about accessing, correcting or deleting their data should first contact their own association (the data controller). For questions about processing by Bayana itself, please use the contact form.
Changes
This is a draft version that may change, including after legal review. Changes will be published on this page.