Data processing agreement (DPA) pursuant to Art. 28 (7) gdpr

Standard contractual clauses

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SECTION I

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Clause 1
Purpose and scope

1. The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
2. The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.
3. These Clauses apply to the processing of personal data as specified in Annex II.
4. Annexes I to IV are an integral part of the Clauses.
5. These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
6. These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2
Invariability of the Clauses

1. The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.
2. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3
Interpretation

1. Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.
2. These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.
3. These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4
Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5
Docking clause

1. Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.
2. Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.
3. The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

SECTION II OBLIGATIONS OF THE PARTIES

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Clause 6
Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7
Obligations of the Parties

7.1. Instructions

1. The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

2. The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

1. The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.
2. The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

 7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

1. The Parties shall be able to demonstrate compliance with these Clauses.
2. The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.
3. The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.
4. The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.
5. The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

1. The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.
2. Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
3. At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.
4. The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.
5. The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8.   International transfers

1. Any transfer of data to a third country or an international organization by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.
2. The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8
Assistance to the controller

1. The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.
2. The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions.
3. In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

1. the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
2. the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
3. the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
4. the obligations in  Article 32 of Regulation (EU) 2016/679

4. The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9
Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1. Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

1. in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);
2. in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679 shall be stated in the controller’s notification, and must at least include:

1. the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
2. the likely consequences of the personal data breach;
3. the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

3. in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay. 

9.2. Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

1. a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);
2. the details of a contact point where more information concerning the personal data breach can be obtained;
3. its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III FINAL PROVISIONS

Clause 10
Non-compliance with the Clauses and termination

1. Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.
2. The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

1. the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
2. the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
3. the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

1. The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.
2. Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.  

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ANNEX I
List of parties

Controller(s):

[Identity and contact details of the controller(s), and, where applicable, of the controller’s data protection officer]

Name: 

Address: 

Contact person’s name, position and contact details: 

Signature and accession date: 

Processor(s):

Name: Get Media GmbH

Address: Stormsweg 6a, 22085 Hamburg, Germany

ANNEX II
Description of the processing

Categories of data subjects whose personal data is processed

1. Creators: This category includes individuals who create and share digital content on the app, such as influencers, artists, musicians, and celebrities.
2. Fans/Followers/Customers: This category includes individuals who follow or subscribe to creators' content on the app and pay to access certain paywalled content. This category may also include customers of small businesses that use the app to promote their products or services.

Categories of personal data processed

1. User account information: This includes personal data such as the user's name, email address, and password (encrypted and hashed).
2. Payment information: This includes payment details such as credit card information, transaction history, and bank account details.
3. Social media metrics: This includes data about the user's engagement on social media platforms such as Facebook, Instagram, TikTok, YouTube, and Twitter, which may include the number of followers, likes, comments, and other engagement metrics.
4. Location data: This includes the user's location as provided by the device or through geolocation services.
5. User-generated content: This includes any digital content created by the user and uploaded to the app, such as links, files, images, videos, and other types of digital content.
6. Other data provided by the user: This includes any additional personal data provided by the user during the use of the app, such as demographic information or other personal preferences.

Sensitive data processed

We are usually not processing sensitive data. However, if sensitive personal data were to be processed by the app or by the controller providing sensitive information to the processor appropriate restrictions and safeguards are implemented to protect the data and comply with GDPR requirements.

Restrictions and Safeguards

1. Strict purpose limitation: Sensitive personal data will only be processed for the specific purposes for which it is collected and not for any other unrelated purposes.
2. Access restrictions: Access to sensitive personal data will be restricted to only those employees or contractors who have a legitimate need to access the data and have received specialized training in handling sensitive data.
3. Record-keeping: A record of access to sensitive personal data will be maintained to keep track of who has accessed the data and for what purpose.
4. Restrictions on onward transfers: Sensitive personal data will only be transferred to third-party processors if they provide appropriate safeguards to protect the data and comply with GDPR requirements.
5. Additional security measures: Additional security measures, such as encryption or pseudonymization, will be implemented to further protect sensitive personal data.

Nature of the processing

The nature of the processing carried out by Get Media GmbH through the get.me app includes the collection, storage, and processing of personal data provided by users during the registration process and through the use of the app's features.

The personal data collected and processed includes, but is not limited to, user account information, payment information, social media metrics, location data, user-generated content, and any other data provided by the user during the use of the app.

The processing of personal data is necessary for the provision of the app's functionality, including the ability for users to create a page, feed, and paywall digital content. The processing is also necessary for the handling of payment information and the provision of financial services through the app.

Get Media GmbH will process personal data in accordance with GDPR requirements, taking appropriate technical and organizational measures to ensure the security and protection of personal data processed through the app.

Purpose(s) for which the personal data is processed on behalf of the controller

The purpose for which personal data is processed by Get Media GmbH on behalf of the controller, as defined in the DPA, is to provide the functionality of the get.me app to users. This includes the creation of a user account, the ability to create a page and feed, and the option to paywall digital content. The processing of personal data is also necessary for the handling of payment information and the provision of financial services through the app.

The personal data processed by Get Media GmbH on behalf of the controller will be limited to what is necessary for the app's functionality and for the purposes set out in the DPA. Get Media GmbH will not process personal data for any other purposes without the prior written consent of the controller.
Purpose(s) for which the personal data is processed on behalf of the controller:

1. User account management: The personal data provided by the user during the registration process is processed to manage and administer their user account on the get.me app.
2. Provision of app functionality: The personal data is processed to provide the functionality of the get.me app to users, including the ability to create a page, feed, and paywall digital content.
3. Payment processing: The personal data is processed to handle payment information and provide financial services through the app.
4. Analytics and marketing: The personal data may be used for analytics and marketing purposes, such as improving the app's features and promoting the app to potential users. However, any such processing will be carried out in accordance with GDPR requirements and the controller's instructions.

Duration of the processing

The duration of the processing of personal data by Get Media GmbH on behalf of the controller is for the duration of the DPA or until the data subject requests deletion of their personal data, whichever occurs first.

Get Media GmbH will only process personal data on behalf of the controller for as long as necessary to fulfill the purposes set out in the DPA or as required by law. After the termination of the DPA or at the request of the controller, Get Media GmbH will delete or return all personal data processed on behalf of the controller.

However, it may not be possible to delete personal data immediately upon request due to technical constraints or legal requirements. In such cases, Get Media GmbH will restrict the processing of personal data to only what is necessary for legal compliance purposes and will take appropriate measures to ensure that personal data is not processed for any other purposes.

Processing by (sub-) processors 

Subject matter:

Sub-processors may be engaged by Get Media GmbH to assist with the processing of personal data on behalf of the controller. Such sub-processors may include, but are not limited to, payment processors, cloud service providers, and analytics providers.

Nature of the processing:

Sub-processors may process personal data on behalf of the controller for the same purposes set out in the DPA. This may include, but is not limited to, the processing of payment information, cloud hosting and storage, and analytics and marketing purposes.

Duration of the processing:

The duration of the processing by sub-processors may vary depending on the specific services provided. Sub-processors will only be engaged by Get Media GmbH for as long as necessary to fulfill the purposes set out in the DPA or as required by law.

Sub-processors will be required to comply with the same data protection obligations as set out in the DPA, including the implementation of appropriate technical and organizational measures to ensure the security and protection of personal data.

ANNEX III
Technical and organisational measures including technical and organisational measures to ensure the security of the data

Technical and organizational measures implemented by our company to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, as well as the risks for the rights and freedoms of natural persons, are as follows:

Access control:

• Physical security of the company's premises (e.g., lockable doors)
• Access control system for the company's premises (e.g., chip cards, transponder systems, security locks)
• Key policy (policy for key distribution & documentation)
• Access organization (e.g., logging / escorting of visitors / external personnel)
• Access authorization structure limited to the necessary (including server access)
• Additional security measures for servers (e.g., lockable server room, server/network cabinet, intrusion-proof windows)

Data carrier control:

• Directory of data carriers
• Encryption of data carriers
• Secure storage of data carriers (after business hours)

Storage control:

• Anonymization of personal data
• Pseudonymization of personal data

Access control:

• User authentication (e.g., username & password)
• Password policy or system requirements for password specifications
• Password complexity (minimum of 3 out of 4 criteria: capital letter, small letter, special character, and number)
• Password with a minimum length of 8 characters
• Two-factor authentication (2FA)
• System access lockout after a defined number of false logins
• Group-wide auto-logout after a defined period
• Role-based permission management or regular recertification of permissions

User control:

• Obligation to confidentiality or obligation of secrecy
• Written policy on the handling of electronic devices or BYOD policy
• Written policy on the handling of personal data (e.g., Clean Desk Policy)
• Need-to-know or Principle of Least Privilege implemented (permission structure limited to the necessary)
• Regular training on data protection

Transmission control:

• Encryption for critical data during data transmission
• Firewall

Recoverability:

• Data backup concept (backup concept) including regular backups
• Data backup concept - evaluation (regular testing and adaptation)
• Secure storage of data backups (e.g., other fire compartment, cloud)
• Disaster recovery plan (DRP) / emergency plan
• Disaster recovery plan - evaluation (regular testing and adaptation)

Reliability:

• Network monitoring / intrusion detection system (IDS / IPS)
• Change management
• Data protection management system
• Updates or patch and vulnerability management
• Procedures for regular review, assessment, and evaluation of the effectiveness of technical and organizational measures

Availability control:

• Resilience tests
• Ensuring operation in the event of a power supply failure (e.g., UPS, emergency power generator)
• Redundant design of all important systems
• RAID system
• Protection against fire in the server room (e.g., fire protection system)
• Protection against overheating of servers (e.g., air conditioning)
• Additional security measures (please specify)

Order control:

• Selection of contractors under due diligence criteria

Physical and Environmental Security:

• The physical access to data is restricted to authorized personnel only, and physical access to premises is controlled by appropriate means, such as security personnel or access control systems.
• The data center and servers are secured with security controls, such as surveillance cameras, motion detection, and 24/7 security monitoring.
• Servers are located in secure data centers with appropriate climate controls, backup power supply, and fire suppression systems.
• Server rooms are kept locked and require authorized personnel to access them.
• Adequate protection is in place to prevent unauthorized access to computer systems and data, including firewalls and intrusion detection/prevention systems.
• Access to data is granted on a need-to-know basis and is only available to authorized personnel.

Data Access Controls:

• Access to personal data is restricted to authorized personnel who have received proper training on data protection and security.
• Access to personal data is granted only for the duration and scope necessary for the specific processing purpose.
• User access is granted and revoked based on role-based access control.
• Passwords are required to access data and are regularly changed, following specific password policies.
• The systems in place are designed to prevent unauthorized access, alteration, or destruction of data.

Data Transmission and Storage Controls:

• Encryption is used for data transmitted over public networks, such as the Internet.
• Encryption is used to store sensitive data at rest.
• Transmission and storage of data are logged and monitored, and these logs are reviewed regularly to identify any unauthorized access or use.
• Data backups are regularly created and stored securely off-site to ensure data availability in case of system failures or other disruptions.

Data Retention and Disposal Controls:

• Personal data is retained only for as long as necessary for the specific processing purpose.
• Once the data is no longer required, it is securely destroyed or deleted using appropriate methods.
• Appropriate policies and procedures are in place to ensure that personal data is properly disposed of.

Regular Testing, Assessing, and Evaluating of TOMs:

• Regular testing and assessments of technical and organizational measures are conducted to identify and address vulnerabilities and to ensure that the TOMs remain effective.
• The results of these tests and assessments are used to improve the TOMs.

Data Protection Impact Assessment:

• A Data Protection Impact Assessment (DPIA) is conducted regularly to evaluate the potential risks to the rights and freedoms of data subjects and to identify appropriate measures to address these risks.
• The DPIA includes an analysis of the risks posed by the processing operations, the measures in place to mitigate those risks, and the ongoing effectiveness of those measures.

Sub-Processor Management:

• Sub-processors are evaluated and selected based on their ability to provide appropriate technical and organizational measures to ensure the security of personal data.
• Contracts with sub-processors include appropriate provisions to ensure that they comply with data protection laws and regulations and implement appropriate security measures.
• The sub-processors are monitored to ensure ongoing compliance with data protection laws and regulations and to identify any potential risks to the rights and freedoms of data subjects.

Measures for ensuring data minimization:

• The app will only collect personal data that is necessary for the purposes of providing the services offered.
• Data minimization is achieved by limiting the amount of personal data collected from the user and by ensuring that personal data is not kept for longer than necessary.

Measures for ensuring data quality:

• The app will ensure that personal data is accurate, complete, and up-to-date.
• Appropriate measures will be taken to rectify or erase inaccurate or incomplete data.

Measures for ensuring limited data retention:

• Personal data will be kept for no longer than necessary for the purposes for which it is processed.
• The app will implement a data retention policy to ensure that personal data is deleted or anonymized when it is no longer needed for its original purpose.

Measures for ensuring accountability:

• The app will ensure that all staff members who have access to personal data are trained on data protection and the company's data protection policies and procedures.
• The app will implement measures to ensure that any data breaches are reported and investigated in a timely and appropriate manner.
• The app will maintain records of processing activities and will conduct regular reviews to ensure that personal data is being processed in compliance with data protection regulations.

Measures for allowing data portability and ensuring erasure:

• The app will enable users to obtain a copy of their personal data in a commonly used electronic format and to transmit this data to another controller.
• The app will enable users to request the erasure of their personal data, subject to any legal obligations to retain certain data for a specified period.

Additionally, we have implemented measures for ensuring data minimization, data quality, limited data retention, and accountability. We have also put in place measures for allowing data portability and ensuring erasure.

For transfers to sub-processors, we require the sub-processor to adhere to the same technical and organizational measures as described above. We ensure this by including a specific section in our sub-processor contracts that outlines the measures the sub-processor must take to provide assistance to the controller.

Overall, we regularly test, assess, and evaluate the effectiveness of our technical and organizational measures to ensure the security of the processing. We have also implemented internal IT and IT security governance and management processes to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.

As part of our commitment to data security, we continuously review and update our technical and organizational measures to ensure that they remain appropriate and effective against the evolving risks to the rights and freedoms of natural persons.

We do not currently hold any relevant certifications for our TOMs, but we are willing to obtain any certifications that may be required by law or that would provide additional assurance to our customers.       

ANNEX IV
List of sub-processors

The controller has authorised the use of the following sub-processors: