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Legal basis analysis for data processing

QR Branding API — GDPR Art. 6

FieldValue
ControllerQR Branding (Quartzon)
Date2026-03-08
Version1.0

1. Principle of lawfulness (Art. 6)

All processing of personal data must rely on at least one of the legal bases in Art. 6(1) GDPR. Each QR Branding processing activity and its corresponding legal basis is analyzed below.


2. Analysis by processing activity

2.1 Generating QR codes containing personal data

AspectAnalysis
ActivityThe user submits QR content that may include personal data (a vCard with name, email, phone and address; geolocation; email addresses)
Legal basisArt. 6(1)(b) — Performance of a contract
JustificationThe processing is necessary to perform the service the user has contracted through RapidAPI. Without processing the content, the requested QR code cannot be generated
ProportionalityMinimal: only the strictly necessary content is processed, in memory, with no storage
Less intrusive alternativeNone: the QR content IS the data to be encoded

2.2 AI-generated QR codes

AI generation works in two modes:

  • QR Branding's own accounts (the AI designer on qr-branding.com and the managed endpoint POST /api/qr/ai/generate-managed): QR Branding sends the design prompt to an LLM provider of its internal fallback chain (Groq, Google Gemini, OpenAI) with its own API keys. These providers act as QR Branding's processors and are listed on the subprocessors page.
  • BYOK (Bring Your Own Key) (the endpoint POST /api/qr/ai/generate): the customer supplies their own API key and chooses the provider; QR Branding does not use its own accounts for these requests.
AspectAnalysis
ActivityThe user submits a design prompt. QR Branding forwards the prompt to an LLM provider: with its own keys (site and managed endpoint) or with the customer's key (llmApiKey, BYOK endpoint)
ModelQR Branding's own accounts with Groq, Google (Gemini) and OpenAI, or BYOK (Bring Your Own Key) with the provider chosen by the customer
Legal basisArt. 6(1)(b) — Performance of a contract
JustificationThe user explicitly requests an AI-generated design: on the site and the managed endpoint by triggering an AI generation; on the BYOK endpoint also by selecting the provider and supplying their own API key. The processing is necessary to carry out that specific request
ProportionalityOnly the design prompt and the generation parameters are sent to the LLM. QR content, IP addresses and identification data are NEVER transmitted. On the BYOK endpoint, the customer's API key is neither stored nor logged
NoteThe user actively chooses to use AI generation and the prompt they send. On the BYOK endpoint they also choose the LLM provider and supply their own API key, and the relationship with the LLM provider is a direct one between the customer and the provider

2.3 Rate limiting

AspectAnalysis
ActivityCounting requests per identifier (RapidAPI user, subscription ID, anonymized IP) to limit the rate of use
Legal basisArt. 6(1)(f) — Legitimate interest
Legitimate interestProtecting the availability of the service for all users and preventing abuse and excessive costs
Balancing test
— Controller's interestHigh: without rate limiting, a single user could exhaust resources or generate prohibitive costs
— Impact on the data subjectMinimal: only a pseudonymous identifier is used to count requests, data is held in volatile memory (2 min), and IP addresses are anonymized
— Reasonable expectationYes: API users expect rate limiting as standard industry practice
— SafeguardsEphemeral data (2 min), IP anonymization, tracking cap (50K IPs), no logging of identifiers
OutcomeThe legitimate interest clearly prevails given the minimal impact on the data subject

2.4 Telemetry and diagnostics (Application Insights)

AspectAnalysis
ActivityCollecting performance metrics, errors and request metadata (no PII)
Legal basisArt. 6(1)(f) — Legitimate interest
Legitimate interestKeeping the service reliable and available, and diagnosing problems quickly
Balancing test
— Controller's interestHigh: without telemetry, incidents cannot be detected or resolved
— Impact on the data subjectMinimal: PII removed from error messages, API keys redacted, IP addresses anonymized
— Reasonable expectationYes: monitoring is standard practice for cloud services
— Safeguards90-day retention, PII-free logging, IP anonymization, API key redaction
OutcomeThe legitimate interest clearly prevails

2.5 RapidAPI authentication

AspectAnalysis
ActivityVerifying the X-RapidAPI-Proxy-Secret header on every request
Legal basisArt. 6(1)(f) — Legitimate interest
JustificationProtecting the service against unauthorized access
NoteThe secret is server data, not user data. No personal data at all is processed in this step

Legal basisArt.Why is it not used?
ConsentArt. 6(1)(a)No explicit consent is collected. It is not needed: the processing relies on contract and legitimate interest. Relying on consent would create additional obligations (withdrawability) with no benefit
Legal obligationArt. 6(1)(c)No legal obligation requires the processing of this data
Vital interestsArt. 6(1)(d)Not applicable: the service does not process data to protect vital interests
Public interestArt. 6(1)(e)Not applicable: this is a private commercial service

4. Special categories of data (Art. 9)

QR Branding neither requests nor requires special categories of personal data (ethnic origin, health, sexual orientation, etc.).

However, the user could include such data in QR content (e.g. a QR code containing medical data). In that case:

  • QR Branding acts as a technical processor that encodes data without interpreting it.
  • Responsibility for processing the special categories lies with the user who decides to include them.
  • The legal basis in this scenario would be the explicit consent of the data subject, which the user must obtain before encoding the data.
  • QR Branding does not store this data and discards it immediately after generation.

5. Children's data (Art. 8)

  • QR Branding is a B2B/B2C API service aimed at developers and businesses.
  • It is not directed at children under 16.
  • No age data is collected and no age verification is performed.
  • If a user includes children's data in QR content, responsibility for obtaining parental consent lies with the user.

6. International transfers (Art. 44-49)

DestinationLegal basis for the transferProvider
EU/USA (Azure)Online Services Terms + SCCsMicrosoft Azure
USAPlatform termsRapidAPI
USAEach provider's data processing terms (see the subprocessors page)Groq, Google (Gemini), OpenAI: AI generation with QR Branding's accounts

Note on LLM providers: with QR Branding's own accounts (the site and the managed endpoint), design prompts are transferred to Groq, Google (Gemini) or OpenAI, which act as QR Branding's processors. On the BYOK endpoint, prompts are transferred to the provider the customer chooses (OpenAI, Anthropic, Google, Mistral, Cohere, Groq, xAI, DeepSeek or Qwen, or their own OpenAI-compatible endpoint) using the customer's own API key. Responsibility for that transfer lies with the customer, who maintains a direct contractual relationship with the provider; QR Branding acts as a technical intermediary.

Using the standard QR generation endpoint involves no transfer to LLM providers (processing takes place exclusively on Azure).


7. Review

This legal basis analysis must be reviewed:

  • When new processing activities are added
  • When the data processed by existing activities changes
  • When LLM provider policies change
  • At least once a year

Document generated on 2026-03-08.