LEGAL-006
TailorDrive Data Processing Agreement (DPA)
Status: Draft
Version: 0.1.0
Document ID: LEGAL-006
In short
This Data Processing Agreement sets out the responsibilities between CODINGTAILORS S.R.L., as Processor, and the organizations using TailorDrive, as Controllers.
When you use TailorDrive to manage data relating to your own customers, employees or collaborators, you remain responsible for the lawfulness of that processing.
1. Purpose of this document
This document supplements the Terms and Conditions and Privacy Policy and describes how personal data is processed on behalf of organizations using TailorDrive.
2. Roles of the parties
CODINGTAILORS S.R.L.
CODINGTAILORS S.R.L. provides TailorDrive and processes data entered into the platform only for providing the service.
In this situation, CODINGTAILORS S.R.L. acts as Processor.
User organization
The organization using TailorDrive determines the purposes and means of processing data entered into the application.
It acts as Controller and is responsible for complying with GDPR obligations toward data subjects.
3. Data processed
Depending on how the service is used, TailorDrive may process on behalf of the Controller:
- first and last names;
- e-mail addresses;
- phone numbers;
- addresses;
- documents;
- messages;
- appointments;
- tickets;
- contracts;
- invoices;
- other information entered by the Controller.
CODINGTAILORS S.R.L. does not determine the content of this data and does not use it for its own purposes.
4. Processor obligations
CODINGTAILORS S.R.L. undertakes to:
- process data only for providing the service;
- implement appropriate technical and organizational measures;
- ensure confidentiality of persons authorized to access data;
- reasonably assist the Controller in fulfilling GDPR obligations;
- notify the Controller when security incidents affecting processed data are identified.
5. Controller obligations
The Controller is responsible for:
- having a legal basis for processing data;
- informing data subjects;
- respecting data subject rights;
- the accuracy of data entered into TailorDrive;
- using the service in accordance with applicable law.
6. Confidentiality
CODINGTAILORS S.R.L. treats all data processed through TailorDrive as confidential and limits access to authorized persons only where necessary to operate and maintain the service.
7. Subprocessors
CODINGTAILORS S.R.L. uses carefully selected subprocessors to provide and operate TailorDrive.
Lumadoc
- Service: cloud infrastructure and VPS servers;
- Location: Romania (main server) and Germany (secondary server);
- Purpose: hosting the TailorDrive application, databases, uploaded files and ensuring service continuity.
Google LLC
- Service: e-mail services;
- Purpose: sending notifications and transactional messages generated by the application, including confirmations, operational notifications and access recovery messages.
Subprocessors are used under appropriate contractual obligations and must provide suitable guarantees regarding security and personal data protection.
Where processing involves international data transfers, those transfers will be carried out according to GDPR requirements and applicable legal mechanisms.
The updated subprocessor list is available on the TailorDrive Subprocessors page. The list may be updated as the service evolves.
8. Duration of processing
Data is processed during use of the service and afterward according to the Data Retention and Deletion Policy.
9. Termination of the agreement
When the contractual relationship ends, data will be deleted or returned to the Controller, as applicable, while respecting legal obligations and applicable retention policies.
10. Responsibility between the parties
Each party is responsible for its own compliance with applicable data-protection law. The Controller remains responsible for the lawfulness, accuracy, minimization and instructions relating to Customer Data. The Processor is responsible only for obligations that apply directly to it and for processing contrary to lawful documented instructions.
Nothing in this agreement restricts the rights of data subjects or supervisory authorities under mandatory law. As between the parties, and to the extent permitted by law, liability, recourse and allocation of loss are subject to the exclusions and aggregate cap in the Terms and Conditions, except where mandatory data-protection law requires otherwise.
11. Changes to this document
This agreement may be updated to reflect legal, technical or operational changes.
The updated version will be published on the website and in the TailorDrive application.