Trooth now relies on the Article 27(2)(a) exemption instead of appointing an EU representative, with the events that would change that written down, and the Cloudflare connector names the two read permissions it needs.
What changed
Earlier on September 28 the security page said an EU representative would be appointed by November 30, because Trooth's processing of people in the European Union was regular. What Trooth can measure does not show that: two cookie choices from visitors in the European Economic Area, the United Kingdom or Switzerland have been recorded since receipts began on September 27. The security page and the GDPR Compliance Statement now say that no representative is appointed under the exemption in Article 27(2)(a) of the GDPR, which covers occasional processing that includes no special category data and is unlikely to put anyone's rights at risk. A representative is appointed within 30 days of the first customer established in the European Union, or sooner if that processing becomes regular, and the position is reassessed at every quarterly access review. The EU AI Act statement now points to that answer instead of calling it open. The Connector and Read-Only Access Disclosure now lists Cloudflare, with the two permissions its reads need: Zone: Zone: Read and Zone: Zone Settings: Read.
Why it changed
The EU representative decision earlier the same day rested on processing Trooth does not measure, and the Cloudflare connection form said its permissions were not listed.
Who is affected
- Affected: Anyone reading Trooth's security page or its General Data Protection Regulation (GDPR) statement, and anyone connecting Cloudflare. Nothing a developer calls changed.
- Availability: Public. No account needed.
- Release stage: Available.
- Areas: Legal, Platform.
What to do
No action required. Nothing to do. A Cloudflare connection made with a wider token keeps working.
Dates
- Announced: September 28, 2026, the day this entry was written. Entries are never backdated.
- Released: September 28, 2026.
What this does not fix
The exemption is a judgment on today's processing, not a permanent answer, and it has not been reviewed by counsel.