ProjoMania

Juridisch

Data Processing Agreement

Our standard Article 28 DPA for service delivery engagements.

Scope

This Data Processing Agreement (DPA) applies where ProjoMania acts as a processor on behalf of a client (controller) in the context of a service-delivery engagement. It supplements the Master Services Agreement or Statement of Work between us.

Subject matter & duration

Subject matter: processing of personal data as necessary to deliver the services described in the engagement. Duration: for the length of the engagement and for 30 days after completion for secure deletion.

Nature & purpose of processing

Technology-services delivery — migrations, implementations, custom development, support — as described in the engaging contract.

Types of personal data

Typically: customer, supplier, employee, and user records stored in the systems we operate on (contact details, identifiers, transactional records). Exact scope is defined per engagement.

Categories of data subjects

Client’s customers, suppliers, employees, and end-users as relevant to the engagement.

Controller rights & obligations

  • Client is the controller and remains responsible for lawful processing under GDPR or applicable law.
  • Client provides lawful instructions and ensures the legal basis for processing.
  • Client handles data-subject requests; ProjoMania assists as outlined below.

Processor obligations

  • Process personal data only on documented instructions from the controller.
  • Keep personal data confidential — our staff are under NDA, access is least-privilege.
  • Implement appropriate technical and organizational measures (see the Security page).
  • Assist the controller with data-subject access requests and regulatory enquiries.
  • Notify the controller of any personal data breach without undue delay and no later than 72 hours after becoming aware.
  • Delete or return personal data at the end of the engagement, per client’s election.
  • Submit to audits on reasonable notice.

Sub-processors

We use the following sub-processors for common service delivery; any additional sub-processors required for a specific engagement are listed in the SOW.

Sub-processorPurposeLocation
Vercel / Cloudflare PagesHostingGlobal edge
CloudflareCDN, DNS, DDoS protectionGlobal edge
ResendTransactional emailEU / US
SanityCMSEU
Cal.comSchedulingEU / US
AWS (as applicable)Backups, temporary storage during migrationsClient-chosen region

Sub-processor changes are notified with a 30-day objection window.

International transfers

Transfers outside the EU are covered by Standard Contractual Clauses or equivalent legal mechanism.

Liability

Subject to the limits set in the engagement contract.

Contact

[email protected]