Data Processing Agreement — Working Template

Unexecuted draft for GDPR Article 28 review — Last updated: July 2026

1. Subject and Duration

Processing of customer data for the provision of MOJAQ services. Duration: term of the service agreement.

2. Nature and Purpose

Hosting and processing of analytics data, document rendering, uptime monitoring data, and error tracking events.

3. Categories of Data Subjects

End users of customer websites/applications, customer employees.

4. Types of Personal Data

IP addresses, user agents, page URLs, error stack traces, email addresses (for error notifications).

5. Sub-processors

NamePurposeLocation
Hetzner Online GmbHInfrastructure hosting and core service storageGermany / Finland (EU)
Cloudflare, Inc.TLS termination, CDN, DDoS and bot protectionGlobal edge / US entity; safeguards to be completed in executed DPA
ResendTransactional and account email deliveryUS entity; safeguards to be completed in executed DPA
Stripe, Inc.Payment processing when paid billing is enabledUS entity; safeguards to be completed in executed DPA
Customer-selected AI providerOptional inference through the AI gatewaySelected and instructed by Controller

6. Technical and Organizational Measures (TOMs)

7. Data Subject Rights

Controller may request access, rectification, or deletion of personal data. Processor will assist within 10 business days.

8. Data Breach Notification

Processor will notify Controller within 48 hours of becoming aware of a personal data breach.

9. Deletion

Following a confirmed deletion request, Processor will remove active service data through its cross-service deletion process unless retention is required by law. Encrypted off-site backup copies are not edited in place: copies older than 30 days are scheduled for pruning after a successful backup upload, and a failed or missed maintenance run can delay pruning. An executed DPA must state the agreed deletion timetable; this working template does not promise a hard 30-day expiry.

WORKING TEMPLATE — NOT EXECUTED. This page contains fields and transfer safeguards that must be completed for the parties and reviewed before signature. It is not a signed DPA and must not be represented as one. Contact [email protected] to prepare an execution copy.