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Data processing agreement for websites

Version dpa-websites-2026-10-20, in force from 20 October 2026

This agreement is part of the contract for every Cyclop Studio website, together with the general terms of sale for websites and the accepted quote. It applies as soon as the quote is accepted, without a separate signature. Where it differs from the terms on personal data, this agreement prevails.

The controller is the client named on the quote ("the Client"). The processor is Cyclop Technologies OÜ, a private limited company registered in Estonia (registry code 17628116, Sepapaja tn 6, 15551 Tallinn), represented by Bilel Rahmouni, member of the management board ("Cyclop"). A copy signed by both parties is available on request.

This agreement goes with the general terms of sale for websites.

1. Subject

Cyclop designs, hosts, maintains and monitors the Client's website and the related services listed on the quote. To do so, Cyclop processes personal data on behalf of the Client, as described in annex 1.

2. Duration

The agreement runs for as long as Cyclop provides a service to the Client, then until the data is returned and deleted under article 11.

3. The Client's instructions

Cyclop processes the data only on the Client's documented instructions. The quote, the terms, this agreement and the requests made from the project page, by email or as a change request are instructions.

If an instruction seems to breach the GDPR or another data protection rule, Cyclop tells the Client without delay and may suspend it until it is confirmed or changed.

If Union or Member State law requires Cyclop to process data without an instruction, Cyclop tells the Client before doing so, unless that law forbids it.

4. Confidentiality

The people authorised to process the data at Cyclop are bound to confidentiality, by contract or by law. Today only the managing director has access; anyone new signs a confidentiality undertaking before getting access.

5. Security

Cyclop applies the measures of annex 2, keeps them in line with the state of the art and the risks, and does not lower them during the contract without telling the Client.

6. Sub-processors

The Client gives a general authorisation for the sub-processors listed in annex 3.

Cyclop tells the Client by email at least 30 days before adding or replacing one. Within that time the Client may object on reasonable data protection grounds; without agreement, either party may end the service concerned without penalty.

Cyclop binds each sub-processor to data protection obligations equivalent to this agreement and remains liable to the Client for them.

7. Transfers outside the EEA

The site's data (database, files, mailboxes, backups) stays in the European Union.

A transfer outside the EEA happens only to the sub-processors of annex 3 marked as such, and only on the basis of an adequacy decision (including the EU-US Data Privacy Framework, Commission Implementing Decision (EU) 2023/1795, for a certified recipient) or of the European Commission's standard contractual clauses (Decision (EU) 2021/914).

8. Helping the Client with people's rights

If someone contacts Cyclop to exercise a right over data of the Client's site, Cyclop forwards the request to the Client within 5 working days and does not answer it itself unless instructed.

Cyclop helps the Client answer (extraction, correction, deletion in the database, the mailboxes and the backups) within the one-month time limit of article 12(3) GDPR. Help beyond 2 hours a year may be billed at the quote's rate, after the Client agrees.

9. Personal data breaches

Cyclop notifies the Client of any personal data breach affecting the site without undue delay and at the latest 24 hours after becoming aware of it, by email and by phone to the Client's contact.

The notice gives what Cyclop knows at that point: nature of the breach, categories and approximate number of people and records, likely consequences, measures taken or proposed, contact. The rest follows as soon as it is known.

Cyclop helps the Client notify the supervisory authority within 72 hours (article 33 GDPR) and, where needed, the people concerned (article 34).

10. Impact assessments

Cyclop gives the Client the information it holds for a data protection impact assessment (article 35 GDPR) or a prior consultation (article 36).

11. End of the contract

When the service ends, at the Client's choice expressed within 30 days, Cyclop either returns a full copy (database dump in SQL, files, mailboxes in Maildir or mbox) and then deletes the data, or deletes it directly. Without an answer, the data is deleted at the end of those 30 days.

Backups are deleted at the end of their rotation cycle. Cyclop confirms the deletion in writing on request.

Cyclop keeps only what the law obliges it to keep (its own invoices, for example), which does not contain the data of the site's visitors.

12. Audits

Cyclop makes available the information needed to show compliance with article 28 GDPR and accepts an audit, by the Client or an auditor bound to secrecy, once a year, on 30 days' notice, at the Client's cost. An audit after a breach is not limited in number.

13. Liability and law

Each party is liable for its own breaches under article 82 GDPR. The liability cap of the terms of sale for websites applies, except for intentional breach or gross negligence. The governing law and the courts are those of the terms of sale for websites.

Annex 1. Description of the processing

ServicesThe site and the options listed on the quote (store, companion app, mailboxes, newsletter).
OperationsHosting, storage, backup, restore, maintenance, updates, monitoring, sending email on the Client's behalf, changes on request.
PurposesRunning the site and its services for the Client; security; continuity.
People concernedVisitors of the site; the Client's customers and prospects; newsletter subscribers; applicants (if the site has an application form); staff and mailbox users; users of the companion app. Only the categories the site actually uses.
DataIdentity and contact details; orders and payments (no card number, handled by Stripe); form messages; mailbox contents; applications and CVs; admin accounts; technical logs (IP address, browser); visit statistics without cookies (Pro and Store plans). Only what the site actually collects.
Special categories (article 9)None planned. The Client tells Cyclop if the site collects any (for example health data in an application).
LocationEuropean Union (see annex 3).
RetentionSet by the Client. Defaults proposed by Cyclop: form messages 3 years, applications 2 years, technical logs 6 months, orders as the Client's accounting obligations require.
ContactsThe Client: the contact on the quote. Cyclop: contact@cyclop-tech.com.

Annex 2. Security measures

Isolation: one virtual server per client, nothing shared between clients.

System: security updates applied; services in containers; a front web server with TLS certificates for every connection.

Administrator access: by SSH key only; the Cyclop team reaches servers through a private network; the Client's account passwords are kept in a password vault dedicated to the Client, never in a code repository.

Database: not exposed to the Internet, reachable only from the site's container.

Backups: every night Cyclop's backup server pulls a full copy (configuration, files, mailboxes, database dump) over SSH with a forced command that can do nothing else; an alert is raised if the latest copy is more than 36 hours old.

Monitoring: availability probe, hourly check of the site, the disk, and the domain's SPF, DKIM and DMARC records.

Changes: every change goes through the site's Git repository, is reviewed, then deployed. A change request is handed to an AI assistant only after Cyclop has approved it, and the assistant has no access to secrets, container files or database migrations.

Staff: access limited to the managing director; a confidentiality undertaking for anyone new.

Incidents: a written procedure, and notice to the Client within 24 hours.

Annex 3. Authorised sub-processors

Contabo GmbH (Germany)The site's virtual server and the backup server. Data in the European Union. No transfer outside the EEA.
Hetzner Online GmbH (Germany)Cyclop's internal servers (code repositories, request handling). Data in Germany. No transfer outside the EEA.
Brevo (Sendinblue SAS, France)Relay for the site's outgoing email, when the site uses it. Data in the European Union.
Stripe Payments Europe Ltd (Ireland)Online payments of the site's store, when it has one. Ireland and United States: Data Privacy Framework and standard contractual clauses.
Anthropic PBC (United States)AI assistant that helps Cyclop carry out an approved change request: it receives the request text and the site's code, never the database. United States: standard contractual clauses. The Client may refuse it in writing; Cyclop then makes changes without it.
Google (Gemini API)Machine translation of the site's public content, on request. United States: Data Privacy Framework and standard contractual clauses.
GitHub Inc. (United States)Hosting of the site's source code for deployment, when used (no visitor data). United States: Data Privacy Framework.