SaaSrooms LLC
8 The Green #5702, Dover, DE 19901, USA
Data Processing Agreement
SaaSrooms
Updated November 2025
SaaSrooms LLC
8 The Green #5702, Dover, DE 19901, USA
This Data Processing Agreement (“DPA”) forms part of the Terms of Use (or other similarly titled written or electronic agreement addressing the same subject matter) (“Agreement”) between Customer (as defined in the Agreement) and Saasrooms under which the Processor provides the Controller with the software and services (the “Services”). The Controller and the Processor are individually referred to as a “Party” and collectively as the “Parties”.
The Parties seek to implement this DPA to comply with the requirements of EU GDPR (defined hereunder) in relation to Processor’s processing of Personal Data (as defined under the EU GDPR) as part of its obligations under the Agreement. This DPA shall apply to Processor’s processing of Personal Data, provided by the Controller as part of Processor’s obligations under the Agreement. Except as modified below, the terms of the Agreement shall remain in full force and effect.
Definitions
Terms not otherwise defined herein shall have the meaning given to them in the EU GDPR or the Agreement. The following terms shall have the corresponding meanings assigned to them below:
“Data Transfer” means a transfer of the Personal Data from the Controller to the Processor, or between two establishments of the Processor, or with a Sub-processor by the Processor.
“EU GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
“Standard Contractual Clauses” means the contractual clauses attached hereto as Schedule 1 pursuant to the European Commission’s Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of Personal Data to processors established in third countries which do not ensure an adequate level of data protection.
“Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
“Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
“Sub-processor” means a processor/ sub-contractor appointed by the Processor for the provision of all or parts of the Services and Processes the Personal Data as provided by the Controller.
“Aggregated Data” means data or information resulting from the processing and/or combining of Personal Data such that the result does not relate to an identified or identifiable natural person and cannot reasonably be used to identify a natural person, organization, or user, including when combined with other data held by SaaSrooms or third parties, consistent with the standards described in SaaSrooms’ Privacy Policy.
“Anonymized Data” or “De-Identified Data” means data originally derived from Personal Data that has been subject to technical and organizational measures (including removal of direct identifiers, aggregation thresholds, generalization, and other safeguards) so that it can no longer reasonably be linked to an identified or identifiable natural person by SaaSrooms or any third party likely to have access to such data, taking into account available technology and costs of re-identification, as further described in SaaSrooms’ Privacy Policy.
For the avoidance of doubt, Aggregated Data and Anonymized/De-Identified Data are not considered Personal Data under this DPA, provided that they cannot reasonably be re-identified.
Purpose of this Agreement
This DPA sets out various obligations of the Processor in relation to the Processing of Personal Data and shall be limited to the Processor’s obligations under the Agreement. If there is a conflict between the provisions of the Agreement and this DPA, the provisions of this DPA shall prevail.
Categories of Personal Data and Data Subjects
The Controller authorizes permission to the Processor to process the Personal Data to the extent of which is determined and regulated by the Controller. The current nature of the Personal Data is specified in Annex I to Schedule 1 to this DPA.
Purpose of Processing
The objective of Processing of Personal Data by the Processor shall be limited to the Processor’s provision of the Services to the Controller and/or its Client, pursuant to the Agreement. In addition, the Controller expressly acknowledges and agrees that the Processor may create and process Aggregated Data and Anonymized/De-Identified Data derived from Personal Data for the following purposes, to the extent such purposes are described in the SaaSrooms Privacy Policy:
Such processing of Aggregated Data and Anonymized/De-Identified Data is carried out on the basis of SaaSrooms’ legitimate interests under Article 6(1)(f) GDPR and any other applicable lawful bases identified in the Privacy Policy, and SaaSrooms shall maintain an internal Legitimate Interests Assessment to support such processing where required by applicable law.
Duration of Processing
The Processor will Process Personal Data for the duration of the Agreement, unless otherwise agreed upon in writing by the Controller. Aggregated Data and Anonymized/De-Identified Data created during the term may be retained by the Processor after the end of the Agreement, as described in the “Return and Deletion of Personal Data” section below and in the Privacy Policy, and shall not be subject to return or deletion obligations under this DPA.
Data Controller’s Obligations
The Data Controller shall warrant that it has all necessary rights to provide the Personal Data to the Data Processor for the Processing to be performed in relation to the agreed services. To the extent required by Data Privacy Laws, Data Controller is responsible for ensuring that it provides such Personal Data to Data Processor based on an appropriate legal basis allowing lawful processing activities, including any necessary Data Subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such consent be revoked by the Data Subject, the Data Controller is responsible for communicating the fact of such revocation to the Data Processor.
The Data Controller shall provide all natural persons from whom it collects Personal Data with the relevant privacy notice. Such notice shall include, where required by applicable law, information about the potential creation and use of Aggregated Data and Anonymized/De-Identified Data as described in the Privacy Policy.
The Data Controller shall request the Data Processor to purge Personal Data when required by the Data Controller or any Data Subject whom it collects Personal Data unless the Data Processor is otherwise required to retain the Personal Data by applicable law. The Data Controller acknowledges that such purge or deletion requests do not apply to Aggregated Data or Anonymized/De-Identified Data that no longer constitutes Personal Data.
The Data Controller shall immediately advise the Data Processor in writing if it receives or learns of any:
Where a Data Subject exercises the right to object to processing for analytics, product improvement, or similar “secondary” purposes, the Controller shall promptly notify the Processor, and the Parties shall cooperate in implementing any opt-out or objection handling in accordance with the Privacy Policy and applicable data protection laws, provided that such opt-out will apply on a go-forward basis and will not require deletion or modification of Aggregated Data or Anonymized/De-Identified Data already created.
Data Processor’s Obligations
The Processor will follow written and documented instructions received, including email, from the Controller, its affiliate, agents, or personnel, with respect to the Processing of Personal Data (each, an “Instruction”).
The Processing described in the Agreement and the relating documentation shall be considered as Instruction from the Controller. This includes the creation and use of Aggregated Data and Anonymized/De-Identified Data as described in this DPA and in the Privacy Policy, which the Parties agree falls within the scope of the Services and the Processor’s legitimate interests, provided that such processing does not identify any individual or Customer.
At the Data Controller’s request, the Data Processor will provide reasonable assistance to the Data Controller in responding to/ complying with requests/ directions by Data Subjects in exercising their rights or of the applicable regulatory authorities regarding Data Processor’s Processing of Personal Data. For clarity, Data Subject rights under GDPR do not apply to Aggregated Data or Anonymized/De-Identified Data that is no longer Personal Data, except to the extent required by local law.
In relation to the Personal Data, Data Processor shall obtain consent (where necessary) and/or provide notice to the Data Subject in accordance with Data Protection Laws to enable shared Personal Data to be provided to, and used by, the other Party as contemplated by this Agreement.
Where shared Personal Data is transferred outside the Data Processor’s territorial boundaries, the transferor shall ensure that the recipient of such data is under contractual obligations to protect such Personal Data to the same or higher standards as those imposed under this Addendum and the Data Protection Laws.
The Processor shall inform the Controller if, in its opinion, a processing instruction infringes applicable legislation or regulation.
As a Data Processor, taking into account the nature of the processing and the information available to the Data Processor, the Data Processor shall assist the Data Controller in conducting any necessary Data Protection Impact Assessments (DPIAs), as required under GDPR, including, where relevant, in assessing the impact of any large-scale analytics that may involve Personal Data prior to anonymization or aggregation.
Data Secrecy
To Process the Personal Data, the Processor will use personnel who are:
The Processor will regularly train individuals having access to Personal Data in data security and data privacy in accordance with accepted industry practice and shall ensure that all the Personal Data is kept strictly confidential.
The Processor will maintain appropriate technical and organizational measures for protection of the security, confidentiality, and integrity of the Personal Data as per the specifications as per the standards mutually agreed in writing by the Parties. Such measures include safeguards designed to ensure that any processes used to generate Aggregated Data and Anonymized/De-Identified Data minimize the risk of re-identification and prevent unauthorized access to underlying Personal Data.
Audit Rights
Upon Controller’s reasonable request, the Processor will make available to the Controller, information as is reasonably necessary to demonstrate Processor’s compliance with its obligations under the EU GDPR or other applicable laws in respect of its Processing of the Personal Data, including its processes and controls relevant to the generation of Aggregated Data and Anonymized/De-Identified Data.
When the Controller wishes to conduct the audit (by itself or through a representative) at Processor’s site, it shall provide at least fifteen (15) days’ prior written notice to the Processor; the Processor will provide reasonable cooperation and assistance in relation to audits, including inspections, conducted by the Controller or its representative. The Controller shall bear the expense of such an audit.
Mechanism of Data Transfers
Any Data Transfer for the purpose of Processing by the Processor in a country outside the European Economic Area (the “EEA”) shall only take place in compliance as detailed in Schedule 1 to the DPA. Where such model clauses have not been executed at the same time as this DPA, the Processor shall not unduly withhold the execution of such template model clauses, where the transfer of Personal Data outside of the EEA is required for the performance of the Agreement.
Sub-processors
The Controller acknowledges and agrees that the Processor may engage a third-party Sub-processor(s) in connection with the performance of the Services, provided such Sub-processor(s) take technical and organizational measures to ensure confidentiality of Personal Data shared with them. The current Sub-processors engaged by the Processors and approved by the Controller are listed in Annex III of Schedule 1 hereto. The Processor shall notify the Controller at least thirty (30) calendar days in advance of any intended changes or additions to its Sub-processors listed in Annex III by emailing notice of the intended change to Customer. In accordance with Article 28(4) of the GDPR, the Processor shall remain liable to Controller for any failure on behalf of a Sub-processor to fulfil its data protection obligations under the DPA in connection with the performance of the Services.
If the Controller has a concern that the Sub-processor(s) Processing of Personal Data is reasonably likely to cause the Controller to breach its data protection obligations under the GDPR, the Controller may object to Processor’s use of such Sub-processor and the Processor and Controller shall confer in good faith to address such concern.
Where Sub-processors receive or process Aggregated Data or Anonymized/De-Identified Data, the Processor shall ensure that such Sub-processors are contractually prohibited from attempting to re-identify any individual or Customer, must maintain appropriate security safeguards, and may only use such data for the limited purposes specified by the Processor.
Personal Data Breach Notification
The Processor shall maintain defined procedures in case of a Personal Data Breach (as defined under the GDPR) and shall without undue delay notify Controller if it becomes aware of any Personal Data Breach unless such Data Breach is unlikely to result in a risk to the rights and freedoms of natural persons.
The Processor shall provide the Controller with all reasonable assistance to comply with the notification of Personal Data Breach to Supervisory Authority and/or the Data Subject, to identify the cause of such Data Breach and take such commercially reasonable steps as reasonably required to mitigate and remedy such Data Breach.
No Acknowledgement of Fault by Processor. Processor’s notification of or response to a Personal Data Breach under this DPA will not be construed as an acknowledgement by Processor of any fault or liability with respect to the data incident.
Return and Deletion of Personal Data
The Processor shall at least thirty (30) days from the end of the Agreement or cessation of the Processor’s Services under the Agreement, whichever occurs earlier, return to the Controller all the Personal Data, or if the Controller so instructs, the Processor shall have the Personal Data deleted. The Processor shall return such Personal Data in a commonly used format or in the current format in which it was stored at discretion of the Controller, as soon as reasonably practicable following receipt of Controller’s notification.
In any case, the Processor shall delete Personal Data including all the copies of it as soon as reasonably practicicable following the end of the Agreement, unless retention is required by applicable law. For the avoidance of doubt, the Processor may retain and continue to use Aggregated Data and Anonymized/De-Identified Data created prior to such return or deletion for the purposes set out in this DPA and the Privacy Policy, and such data will not be returned to the Controller.
Technical and Organizational Measures
Having regard to the state of technological development and the cost of implementing any measures, the Processor will take appropriate technical and organizational measures against the unauthorized or unlawful processing of Personal Data and against the accidental loss or destruction of, or damage to, Personal Data to ensure a level of security appropriate to: (a) the harm that might result from unauthorized or unlawful processing or accidental loss, destruction or damage; and (b) the nature of the data to be protected, including the measures stated in Annex II of Schedule 1. Such measures will also be designed to support secure pseudonymization, aggregation, and anonymization processes, to reduce the likelihood that datasets used to create Aggregated Data and Anonymized/De-Identified Data can be re-identified.
SCHEDULE 1
ANNEX I
Data exporter(s):
Name: Customer (As set forth in the relevant Order Form).
Address: As set forth in the relevant Order Form.
Contact person’s name, position, and contact details: As set forth in the relevant Order Form.
Activities relevant to the data transferred under these Clauses: Recipient of the Services provided by Saasrooms in accordance with the Agreement.
Signature and date: Signature and date are set out in the Agreement.
Role (Controller/ Processor): Controller.
Data importer(s):
Activities relevant to the data transferred under these Clauses: Provision of the Services to the Customer in accordance with the Agreement.
Signature and date: Signature and date are set out in the Agreement.
Role (controller/processor): Processor.
Categories of data subjects whose personal data is transferred
Customer’s authorized users of the Services.
Categories of personal data transferred
Name, Address, Date of Birth, Age, Education, Email, Gender, Image, Job, Language, Phone, Related person, Related URL, User ID, Username.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialized training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
No sensitive data collected.
The frequency of the transfer (e.g., whether the data is transferred on a one-off or continuous basis).
Continuous basis.
Nature of the processing
Processing necessary to provide, maintain, support, secure, and improve the Services, including hosting, storage, backup, user management, analytics, error detection, and the creation of Aggregated Data and Anonymized/De-Identified Data as described in the Agreement, this DPA, and the Privacy Policy.
Purpose(s) of the data transfer and further processing
The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms, including related security, support, analytics, and lawful creation and use of Aggregated Data and Anonymized/De-Identified Data.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
The period for which the Customer Personal Data will be retained is more fully described in the Agreement, this DPA, and accompanying order forms. Aggregated Data and Anonymized/De-Identified Data may be retained for as long as necessary to fulfil the purposes set out in this DPA and the Privacy Policy.
For transfers to (sub-) processors, also specify subject matter, nature, and duration of the processing
The subject matter, nature, and duration of the Processing are more fully described in the Agreement, this DPA, and accompanying order forms. Sub-processors may also handle Aggregated Data and Anonymized/De-Identified Data strictly for the purposes and duration specified by SaaSrooms and subject to re-identification prohibitions.
Data exporter is established in an EEA country.
The competent supervisory authority is as determined by application of Clause 13 of the EU SCCs.
ANNEX II
TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
[Existing detailed security text remains unchanged, with the understanding that these controls also support secure aggregation and anonymization processes as referenced above.]
ANNEX III
LIST OF SUB-PROCESSORS
The controller has authorized the use of the following sub-processors:
Name of Sub-Processor: Amazon Web Services
Description of Processing: Hosting the Production Environment
Location of Other Processor: US-EAST-1
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