Scope and instructions
When incorporated into your service agreement, the identified operator is processor and the customer is controller, or an authorized processor appointing a subprocessor. This addendum applies to personal data we process on documented customer instructions in providing the service; it does not cover processing for which we independently determine purposes as controller.
Instructions consist of the agreement, configured service features, lawful support requests and subsequent documented directions agreed by the parties. We will inform you if we believe an instruction infringes applicable data-protection law, and may pause that instruction while it is resolved. If law requires other processing, we will inform you beforehand unless legally prohibited.
Processing description
Subject and duration: hosting, editing, domain routing, requested AI design, media storage and page analytics for the service term, followed by agreed deletion or return and necessary lawful retention. Nature: collection, storage, organization, retrieval, disclosure to authorized providers, analysis and deletion.
Data subjects: customers’ staff, creators, visitors and persons included in lawful customer content. Data: profile and contact text, photos and other media, link and design content, prompts, visitor preference references, event timestamps, approximate location, device/browser category, referrer and campaign data. Network metadata can be processed for delivery and security. Special-category data is not required; customers must not intentionally submit such data without a lawful basis and a separately agreed supported arrangement.
Confidentiality and security
Access is limited to authorized persons subject to confidentiality obligations. We implement appropriate technical and organizational measures considering risk, including authenticated account access, tenant ownership checks, database access controls, server-side provider credentials, transport encryption, quota controls, operational incident handling. The Security page describes implemented controls without claiming certification.
The customer secures its account and devices, provides lawful instructions and content, supplies required notices and establishes a lawful basis. Application controls assist but do not transfer the controller’s accountability to the processor.
Subprocessors and transfers
The customer gives general authorization for the relevant subprocessors identified in the customer provider register, available from the account before accepting the processing terms. Before adding or replacing a subprocessor for covered processing, we will provide notice with a reasonable opportunity to object on substantiated data-protection grounds. If an objection cannot be resolved, the parties will discuss a supported alternative or termination of the affected service.
We require appropriate written data-protection obligations from subprocessors and remain responsible for their covered processing as required by applicable law. Restricted transfers must use a valid legal mechanism and required supplementary measures. We assess the relevant providers and safeguards for covered processing and make applicable information available to customers on request.
Assistance, incidents and audit
Taking account of the processing and information available, we assist with data-subject requests, security obligations, breach assessment, impact assessments and regulator consultations. We notify the customer without undue delay after becoming aware of a personal-data breach affecting its covered data and provide available information, updates and reasonable cooperation.
We make information needed to demonstrate compliance available and allow lawful audits, including inspections, by the controller or its authorized auditor. Practical scheduling, confidentiality and security arrangements may be agreed without defeating statutory audit rights.
Return, deletion and priority
At the customer’s choice on termination, we return or delete covered personal data and delete copies unless law requires retention. Account exports and deletion requests support this process; legal obligations, domain orders and provider backup cycles must be addressed transparently. Retained data is protected and limited to the purpose requiring retention.
This addendum takes precedence over conflicting service terms for covered data processing. Statutory rights and obligations, including data-subject compensation rights, are not removed by commercial liability clauses.