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ADPAL bot protection:
GDPR review for your DPO
This page gives privacy, legal, security and procurement teams the facts needed to assess ADPAL: what the protection layer evaluates, why request-level events are logged, where data resides, which decisions remain with the customer and which documents support the review.
It does not claim that one vendor makes an entire website GDPR compliant. It makes the ADPAL part of the data flow easier to understand, document and challenge.
Privacy at a glance
Cookieless | No cross-site tracking profiles | EU (Frankfurt) data residency
.Direct answer
What should a GDPR review of bot protection cover?
A GDPR review of bot protection should identify the processing purpose, data categories, legal roles, lawful basis, retention, rights handling, subprocessors, international-transfer path and security measures. ADPAL narrows that review with a cookieless architecture, no cross-site tracking profiles and Frankfurt residency, but the customer must still assess the real deployment and document its decisions.
.Why it matters
Why the architecture matters more than a compliance badge
Shorter fact-finding
Reviewers can see what request context is evaluated and why events are logged
Clearer decisions
The vendor states product facts. The customer documents purpose, lawful basis and transparency
Fewer contradictions
The public page, DPA, subprocessor list and privacy notices use the same language
A better audit trail
Roles, rights assistance, retention, transfers and deployment choices have an accountable owner
.Claim scope
Separate vendor facts
from customer decisions
A credible GDPR page should not turn legal conclusions into product features.
ADPAL can state how the service works and provide evidence.
The organisation operating the website or application decides why processing is needed, which lawful basis applies and how people are informed.
Review owner
ADPAL should provide
What must be clear
Service data flow, request context and logged-event categories, processing purposes and security measures
Review owner
ADPAL should document
What must be clear
Retention, deletion, Frankfurt residency, subprocessors, access controls, rights assistance and contractual terms
Review owner
The customer should decide
What must be clear
Purpose of deployment, lawful basis, legitimate-interest assessment where used, protected routes and user groups
Review owner
The customer should document
What must be clear
Transparency wording, DPIA need, rights-request intake, internal accountability and deployment decisions
Review owner
Both parties should align
What must be clear
Role allocation, documented instructions, incident handling, subprocessor changes and support access
Review owner
Both parties should close
What must be clear
Contract termination, exports and deletion, Adaptive CAPTCHA processing and material service changes
The practical rule
Review the data flow, contracts and operating choices. Do not rely on a “GDPR compliant” badge from any vendor.
.Architecture and data flow
Start with the request-to-dashboard data flow
ADPAL is a managed reverse proxy in front of the protected site, application or API routes. Requests reach the protection layer before the origin. Advanced detection evaluates request context, applies a decision and logs per-request security events that support enforcement, dashboard visibility and operational analysis.
01
Request arrives
The request reaches the managed reverse proxy before the protected origin
02
Evaluate context
Advanced detection evaluates behaviour, browser characteristics, network context, request sequence, endpoint activity and relevant application context. ADPAL does not use device fingerprinting or session tracking
03
Protection decision
The service applies the configured response. Most genuine users continue normally. Adaptive CAPTCHA appears only in rare, uncertain cases
04
Security event
A request-level event is logged so the customer can review activity and protection outcomes
05
Continue to origin
Permitted requests reach the existing origin. The website, CMS, application database, CRM and order records remain in the customer systems of record
06
Review and document
Events support dashboards, reporting, policy review and troubleshooting. Retention, access, deletion and material deployment choices should be documented consistently
.Processing and logging
What ADPAL processes
and why events are logged
Cookieless does not mean data-free. The protection layer sets no bot-detection cookie and builds no cross-site tracking profile.
Request context is still processed, and per-request security events are logged because the dashboard and operational review depend on them.
Processing area
Inbound request context
Review question
Which fields are needed to evaluate automation for each protected route?
Processing area
Protection outcome
Review question
Which action and reason categories are recorded?
Processing area
Security-event context
Review question
Which time, route, request and network categories support dashboards and investigation?
Processing area
Customer configuration
Review question
Which domains, policies and authorised automation settings are stored?
Processing area
Support, retention and deletion
Review question
What support material may be provided, who may access it, how long each data category remains and what happens at contract end?
Documentation boundary
The DPA, privacy record and public page must use the same data categories, purposes, roles, retention, deletion and access.
.Topic-specific review
How to structure the GDPR assessment
The legal review should follow the real processing activity.
The sections below are orientation points, not a compliance certificate.
GDPR review area
Question to answer
Practical review focus
Roles and purpose
Who determines why the protection service is used, and who processes data under instructions?
Define controller/processor allocation for the core service and map separate account, support or service-security activities
Lawful basis
Which Article 6 basis supports the real processing activity?
Document the chosen basis. Where legitimate interests are used, define the interest, necessity and balancing assessment
Transparency and minimisation
What data is necessary and what should people be told?
Align Articles 5, 13-14 and 25 with the actual request context, event logging, retention and cookieless architecture
Rights and retention
How can relevant events be found, retained, restricted, exported or deleted?
Define intake, verification, search scope, ADPAL assistance, identifiers and retention boundaries for Articles 15-22
Security and transfers
Which security measures and international-transfer questions remain?
Document Article 32 controls and review Frankfurt residency, subprocessors, support access and Chapter V before concluding that no transfer occurs
Practical conclusion
Follow the real processing activity: define roles, lawful basis, transparency, rights handling, security and transfer questions. Treat this page as an orientation tool, not a compliance certificate.
.Benefits and limitations
What ADPAL can simplify
and what remains
with the customer
ADPAL can simplify
A clear request-to-dashboard data flow
The customer still decides or maintains
Purpose, lawful basis and transparency wording
ADPAL can simplify
Cookieless protection with no cross-site tracking profiles
The customer still decides or maintains
The consent and ePrivacy position of the complete website stack
ADPAL can simplify
Frankfurt residency for the stated protection path
The customer still decides or maintains
The complete transfer assessment across subprocessors, support and other vendors
ADPAL can simplify
A DPA and documented assistance process
The customer still decides or maintains
Rights-request intake, identity verification and legal conclusions
ADPAL can simplify
A monitored perimeter deployment with advanced automated-traffic detection
The customer still decides or maintains
DPIA need, security risk acceptance, MFA, passkeys, server-side validation, PSP controls, backups and incident response
.Traffic outcomes
How protection decisions affect
visitors and existing controls
Privacy and security meet in the way traffic is handled. The response depends on confidence, endpoint risk and customer policy.
ADPAL is one layer. Keep identity controls, server-side validation, business rules, payment controls, resilience, recovery and manual review where the application needs them. The compliance pack should describe any separate processing introduced by Adaptive CAPTCHA.
.Deployment and monitoring
Deploy, observe and document
before enforcement
The monitoring period matters to both security and privacy.
It gives the team time to identify authorised automation,
review endpoint policies, confirm dashboard events
and document the actual deployment before blocking decisions are enforced.
01
Stage
Scope
GDPR and operational focus
Document domains, routes, APIs, purposes, users, authorised automation and data categories
02
Stage
Route
GDPR and operational focus
Make the planned DNS change and confirm origins, certificates and support responsibilities
03
Stage
Monitor
GDPR and operational focus
Review events, legitimate traffic, uncertainty, false positives and actual processing
04
Stage
Tune
GDPR and operational focus
Align policies, exceptions, retention choices and transparency with the real deployment
05
Stage
Enforce
GDPR and operational focus
Enable protection in a controlled sequence and maintain records of material changes
.Compliance pack
Document or page
What it should answer
Roles, instructions, purposes, data categories, confidentiality, security, retention, deletion or return, rights assistance, incidents, audits and transfer terms
Document or page
What it should answer
Current providers, service role, locations and change process
Document or page
What it should answer
ADPAL’s own controller activities, public transparency information and marketing-site cookies versus the cookieless protection layer
Document or page
What it should answer
Frankfurt service path, location scope and transfer boundaries
Document or page
What it should answer
Why the protection layer sets no bot-detection cookies or cross-site profiles
Document or page
What it should answer
Deployment-specific access, controls, incidents, continuity, testing and customer-specific architecture
.Related routes
Complete your ADPAL compliance review
Review cookies, client-side tracking and cross-site profiling
Review the Frankfurt path and transfer boundaries
Explore capabilities, detection logic and dashboard value
.FAQ
Questions privacy and legal teams ask first
Is ADPAL GDPR compliant?
A vendor cannot make the customer’s full deployment compliant by itself. ADPAL provides a cookieless protection architecture, no cross-site tracking profiles, EU (Frankfurt) data residency and documentation for the customer assessment. Compliance still depends on the actual data flow, legal basis, configuration, transparency, contracts and wider stack
Is ADPAL a processor or a controller?
Roles follow the activity. For the core protection service, the intended model is that the customer determines why and where protection is used, while ADPAL processes data to provide the service under documented instructions. Separate account, support or service-security activities must be mapped independently
What personal data does ADPAL process?
ADPAL evaluates behaviour, browser characteristics, network context, request sequence, endpoint activity and relevant application context. Per-request security events are logged for detection, dashboard visibility and operational analysis. The DPA should list exact fields, purposes, retention, access and deletion rules
Can bot protection rely on legitimate interests?
It may be an available legal basis for network and information security in some deployments, but it is not automatic. The controller must define the interest, show necessity, balance it against rights and expectations, provide transparency and document the assessment
Do we need consent or a new cookie-banner category?
ADPAL’s protection layer is cookieless and does not build cross-site tracking profiles. That does not decide the consent position for the full website. Review other analytics, advertising, personalisation and security technologies, plus applicable ePrivacy rules and transparency requirements
How are data-subject requests handled?
The customer receives the request and ADPAL assists under the DPA. Searches may require available identifiers, the protected host or endpoint and a relevant time window. The result depends on event fields and retention. Do not promise that no record exists merely because no visitor profile is built
Does ADPAL transfer data outside the EU?
The stated core protection path has EU (Frankfurt) data residency. A complete answer also reviews subprocessors, remote support access, backups, telemetry and separate service activities. Use the DPA and current subprocessor list for the deployment-specific conclusion
What changes during deployment?
Point your DNS at the managed reverse proxy – live in hours, then a short monitoring period before enforcing. CMS-integrated deployment is available through hosting partners. Most genuine users continue normally; Adaptive CAPTCHA appears only in rare, uncertain cases
Send the data flow,
not a compliance slogan
Share this page with the DPO, privacy counsel, security reviewer or procurement lead. Then use the DPA, subprocessor list and deployment-specific answers to close the remaining questions.