Legal

Data Processing Addendum

Effective · GDPR Article 28

⚠️ Draft pending legal review.

Working draft, not yet reviewed by counsel. Business and Enterprise customers requiring an executed DPA should email legal@veirox.com.

1. Parties & roles

This Addendum supplements the Terms of Service. The Customer is the data Controller; Veirox is the data Processor. Where Customer collects data on behalf of an end-user (e.g. their own customers), Customer remains the Controller.

2. Scope of processing

Categories of data subjects

Categories of data

Purposes of processing

Duration

For the term of the Customer's subscription, plus the deletion grace period documented in §9 of the Terms (default 30 days).

3. Processor obligations

Veirox will:

4. Security measures

We maintain measures including (non-exhaustive):

5. Subprocessors

The current subprocessor list is the canonical, current source: /legal/subprocessors.html. Material entries:

Customer may object to a new subprocessor within 14 days of notification by emailing legal@veirox.com. We'll work in good faith to resolve; if unresolvable, Customer may terminate without further obligation.

6. Data Subject Requests

Customer is responsible for handling DSRs received from data subjects. Veirox provides tooling to assist:

Veirox responds to direct data-subject requests by routing them to the relevant Customer.

7. International transfers

Veirox is hosted in the EU/US region (current: DigitalOcean ams3, may change with subprocessor list updates). Transfers outside the EEA rely on Standard Contractual Clauses (SCCs) where applicable.

8. Audits

Veirox will make available all information necessary to demonstrate compliance. Customer may request an audit, conducted at Customer's expense and reasonable notice (≥30 days), no more than once per year, subject to confidentiality.

Where SOC 2 Type II / ISO 27001 reports are available (see Security page for status), Customer may rely on them in lieu of an audit.

9. Liability

The liability cap in §11 of the Terms applies, except liability arising from breach of GDPR obligations cannot be capped below the relevant GDPR thresholds.

10. Changes

Material changes are announced 30 days in advance via email to org owners.

11. Contact

DPO / privacy contact: legal@veirox.com.