Data Processing Agreement

Last updated: 2026-10-24

1. Purpose and precedence

This Data Processing Agreement (the "DPA") governs the processing of personal data that a business customer (the "Controller") submits to Probapedia (the "Processor") through the service. It supplements the Terms of Service. If this DPA conflicts with the Terms on a matter of data protection, this DPA prevails.

2. Roles of the parties

For individual consumer accounts, Probapedia acts as Controller for the data described in the Privacy Policy. For business accounts that submit end-user data through the service, the business is the Controller and Probapedia is the Processor.

3. Scope of processing

4. Processor obligations

  1. Process personal data only on documented instructions from the Controller, including for transfers to third countries, unless required by law.
  2. Ensure persons authorised to process the data are bound by confidentiality.
  3. Implement appropriate technical and organisational measures (Article 32 GDPR).
  4. Assist the Controller in responding to data-subject requests.
  5. Assist the Controller with security, breach notification, impact assessments, and prior consultations.
  6. Delete or return personal data at the end of the provision of services, subject to legal retention.
  7. Make available all information necessary to demonstrate compliance and allow audits.
  8. Notify the Controller promptly if an instruction appears to infringe data-protection law.

5. Sub-processors

The Controller authorises Probapedia to engage sub-processors that perform the functions listed below. Probapedia notifies the Controller of any material change to this list at least 14 days in advance and gives the Controller the right to object. Each sub-processor is bound by written terms that impose data-protection obligations at least as protective as this DPA.

FunctionData categories processedRegion
Cloud hosting and managed databaseAll data listed in section 3EU
AuthenticationEmail address, session identifiersEU
Security edge and abuse preventionIP address, request metadataGlobal edge
AI analytical processingPrompts, completions, uploaded imagesProvider regions under contractual safeguards
Payment processingBilling metadata, transaction referencesProvider regions under contractual safeguards
Transactional emailEmail address, one-time sign-in linksUS under Standard Contractual Clauses

The current sub-processor list is available to the Controller on request through the contact address in section 13.

6. International transfers

Primary storage is within the European Economic Area. Where a sub-processor processes data outside the EEA, the transfer relies on an adequacy decision of the European Commission or on Standard Contractual Clauses, together with supplementary technical measures such as encryption in transit, encryption at rest, and per-tenant isolation. The Controller may request the transfer mechanism that applies to any sub-processor by writing to the contact address in section 13.

7. Security measures

8. Breach notification

Probapedia notifies the Controller without undue delay, and in any event within 72 hours of becoming aware of a personal-data breach affecting the Controller's data. The notification includes the nature of the breach, the categories and approximate volume of data affected, the likely consequences, the measures taken or proposed, and a contact point for follow-up.

9. Audits

Once per year, or after a personal-data breach affecting the Controller, the Controller may request a written summary of the security controls in place. On-site audits require 30 days' notice, occur during business hours, are limited to the systems that process the Controller's data, and are subject to confidentiality. The Controller bears the cost of an on-site audit unless the audit reveals a material breach of this DPA.

10. Liability

Liability under this DPA is subject to the limitations in the Terms of Service. Nothing in this DPA limits liability that cannot be limited under applicable law.

11. Termination

On termination of the business account, Probapedia deletes or returns the Controller's data within 30 days, except where retention is required by law. The Controller may export data at any time through the Account page.

12. Changes to this DPA

Probapedia may update this DPA to reflect changes in law, in sub-processors, or in the service. Material changes are announced to the Controller at least 14 days before they take effect.

13. Contact

[email protected] — DPA questions and requests.
[email protected] — security disclosures.

Educational analytics only. Not financial advice.