Data Processing Agreement (Orestia)

This Data Processing Agreement consists of the standard contractual clauses between controllers and processors adopted by the European Commission in Commission Implementing Decision (EU) 2021/915 of 4 June 2021 under Article 28(7) of Regulation (EU) 2016/679 (OJ L 199, 7.6.2021, p. 18).

• The Clauses are reproduced below without modification. The options are selected as shown in the table, and the Annexes are completed, as Clause 2(a) allows.
• The Supplementary terms after the Clauses are added under Clause 2(b). They do not contradict the Clauses.
• This Agreement forms part of the Orestia Terms of Service. The sub-processor list is kept on the Sub-processors page.

Options selected

Standard contractual clauses

SECTION I

Clause 1: Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of 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).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2: Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 (Optional): Docking clause

(a) Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.

(b) Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.

(c) The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.

SECTION II: OBLIGATIONS OF THE PARTIES

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7: Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor's opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller's request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) OPTION 2: GENERAL WRITTEN AUTHORISATION: The processor has the controller's general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller's request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor's obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8: Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects' requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller's instructions

(c) In addition to the processor's obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a 'data protection impact assessment') where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9: Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller's notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller's obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III: FINAL PROVISIONS

Clause 10: Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Supplementary terms (Clause 2(b))

These terms add detail and do not contradict the Clauses.

S1. Documented instructions. The controller's documented instructions are these Clauses, the Orestia Terms of Service, and the settings and approvals the controller makes in Orestia: which channels it connects, how much history it imports, what it approves, exports or deletes. They also include the set-up support the controller asks for, such as importing for an event the files the controller sends to the processor's staff.

S2. No other purposes. The processor does not use the personal data for its own purposes, does not sell it, and does not use it to train or improve AI models.

S3. Breach notification. Within the "without undue delay" duty of Clause 9.2, the processor aims to notify the controller within 48 hours of becoming aware of a personal data breach, at the controller's contact in Annex I.

S4. Audits. The processor first answers audit requests with documentation and its sub-processors' certifications. Inspections under Clause 7.6(d) take place with 30 days notice, during business hours, under confidentiality, at the controller's cost unless the audit finds a material breach.

S5. Deletion at the end. Under Clause 10(d), the processor deletes the personal data within 30 days of termination, unless the controller asks for its return first. Backups are replaced within 7 days . The processor certifies deletion on request.

S6. Liability. Liability between the Parties follows the Orestia Terms of Service, section 14, without prejudice to Article 82 GDPR.

S7. Governing law and courts. As in the Orestia Terms of Service, section 17.

S8. Personal data subject to the UK GDPR. Where the UK GDPR and the Data Protection Act 2018 apply to the processing, these Clauses also serve as the contract required by Article 28 of the UK GDPR. For that processing, references to Regulation (EU) 2016/679 are read as references to the UK GDPR, references to a supervisory authority as references to the UK Information Commission, and references to Union or Member State law as references to the law of the United Kingdom. Transfers to sub-processors outside the United Kingdom and the European Economic Area use a transfer tool that UK law recognises, such as the UK International Data Transfer Addendum.

S9. US state privacy laws. Where the controller is a "business" under the California Consumer Privacy Act, or a "controller" under another US state privacy law, the processor acts as its "service provider" or "processor" and:

• does not sell or share the personal information;
• processes it only for the business purposes in Annex II, which the controller discloses it for, and for no other purpose;
• does not retain, use or disclose it outside the direct business relationship with the controller, and does not combine it with personal information from other sources, except as those laws permit;
• complies with those laws and gives the personal information the level of privacy protection they require;
• lets the controller take reasonable and appropriate steps to ensure that the processor uses it consistently with the controller's obligations, including the audits in Clause 7.6;
• tells the controller if it can no longer meet its obligations under those laws, and lets the controller, on notice, take reasonable and appropriate steps to stop and remediate unauthorised use;
• helps the controller answer consumer requests;
• binds each sub-processor to the same obligations by written contract.

S10. Canada. Where PIPEDA or Québec's Act respecting the protection of personal information in the private sector applies, the processor uses the personal information only for the purposes in Annex II, protects it with the measures in Annex III, tells the controller of any breach of security safeguards under Supplementary term S3, and gives the controller the information it needs to assess the communication of personal information outside Québec.

S11. Australia. Where the Privacy Act 1988 (Cth) applies to the controller, the processor holds and handles the personal information only to provide the Service to the controller, under the controller's effective control and consistently with the Australian Privacy Principles as they apply to the controller. It does not use or disclose the personal information for its own purposes, binds its sub-processors to the same obligations, and gives the controller the information it needs under the notifiable data breaches scheme.

ANNEX I: List of parties

Controller(s): Identity and contact details of the controller(s), and, where applicable, of the controller's data protection officer

1. Name: Completed at signature
   Address: Completed at signature
   Contact person's name, position and contact details: Completed at signature, Completed at signature, Completed at signature
   Data protection officer (if any): Completed at signature
   Signature and accession date: Completed at signature, Completed at signature

Processor(s): Identity and contact details of the processor(s) and, where applicable, of the processor's data protection officer

1. Name: NORIA GROUP Ε.Ε., provider of the Orestia service (General Commercial Registry (ΓΕΜΗ) no. 186546103000, VAT no. EL802974340)
   Address: 71 Grammou Street, 151 24 Marousi, Greece
   Contact person's name, position and contact details: Dimitrios Poupouliadis, General partner, manager and legal representative, privacy@orestia.ai
   Data protection officer: none appointed
   Signature and accession date: Completed at signature, Completed at signature

ANNEX II: Description of the processing

Categories of data subjects whose personal data is processed

• The controller's staff and the Users of its Orestia workspace.
• The controller's clients: couples, hosts, families, companies and their contact people.
• Guests and attendees of the controller's events.
• Vendors and suppliers (for example venues, caterers, florists, photographers, musicians, transport and accommodation providers) and their staff.
• Other people who appear in the messages, files or voice notes in the channels the controller chooses to connect.

Categories of personal data processed

• Identification and contact data: names, phone numbers, email addresses, messaging identifiers (WhatsApp, Telegram, Instagram, Quo), company and role. Connected channels do not create a general contact book.
• Communications: selected Gmail and Outlook messages and attachments, forwarded emails, one-to-one WhatsApp messages (including shared history up to 180 days at connection), selected Telegram Chat Automation chats, Instagram professional-account DMs, selected-number Quo SMS and available call notes, exported chats, voice notes and available transcripts.
• Attachments and files: quotes, contracts, invoices (which may include bank details), proposals, images, spreadsheets and PDFs.
• Event data: dates, venues, schedules and run of show, tasks, budgets, quotes, payment schedules and status, decisions.
• Guest data: names, contact details, RSVP status, party, seating, travel and accommodation details, dietary requirements, allergies, accessibility needs and other notes the controller records.
• What the AI coordinator prepares about these people: facts with receipts, proposals, drafts, summaries and translations.

Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved

• Which data. Guests' dietary, allergy and accessibility notes may reveal data concerning health (for example allergies, medical conditions or disabilities) or religious beliefs (for example halal or kosher meals). Messages, files and voice notes may also contain other sensitive data incidentally. Guests may include children. The controller needs a legal basis for it under Article 9(2) GDPR, usually the guest's explicit consent.
• Restrictions and safeguards:
  • processed only for the controller's event purposes in Annex II;
  • visible only to Users with access to the event;
  • excluded from evaluation datasets, analytics and any training of AI models;
  • processed only by the sub-processors in Annex IV, in the EU where shown there;
  • encrypted in transit and at rest; changes and approvals recorded;
  • deleted with the event or on the controller's instruction;
  • the controller decides which of these notes to record.

Nature of the processing

• Collection from the channels the controller chooses to connect, within the selection and permissions in the Privacy Policy, section 4: Gmail, Outlook, forwarding addresses, WhatsApp Business app Coexistence, selected Telegram Chat Automation chats after explicit AI consent, Instagram DMs and selected Quo numbers. Selected Google Drive and Sheets files, Dropbox snapshots, uploads, exports and mobile share content are imported for the controller's chosen event. OneDrive is not offered in the current web interface.
• Storage in the EU.
• Structuring by the AI coordinator: classifying messages, extracting facts with receipts, linking them to events and people, detecting contradictions.
• Preparing proposals and outbound messages. Every outbound message is presented to the controller as "a draft for your approval"; the controller sends it from their own app. No sending through connected channels, mailbox draft creation or file changes. Telegram has only two fixed private setup notices to the controller, never free-form messages to clients or vendors.
• Publishing only the approved schedule items and explicit display fields the controller selects through a private calendar subscription link. No amounts, contact details, source messages or receipts are included. No calendar reading or invitations. The controller can revoke or replace the link; already downloaded copies remain with the chosen calendar service.
• Translation.
• Set-up support at the controller's request: the processor's staff import, check and structure the files the controller sends for an event.
• Search, display, export and deletion.

Purpose(s) for which the personal data is processed on behalf of the controller

To provide the Orestia service to the controller: keeping the ledger of the controller's events up to date, helping the controller coordinate clients, vendors and guests through proposals and drafts that the controller approves, and supporting and securing the service for the controller. No other purposes.

Duration of the processing

For the term of the agreement between the Parties. Items the controller deletes are removed from the live system at once and from backups within 7 days . At the end, Clause 10(d) and Supplementary term S5 apply.

Connected conversation content that cannot be linked to an event is dropped without storage as an inbox. Retained event-linked message text expires at event end + 90 days; after that only approved facts and their exact receipt excerpts remain. Raw forwarded email is deleted after import, or within 7 days if quarantined. Drive row and snapshot sources follow event-data deletion; Sheet checkpoints contain versions and row fingerprints rather than full file copies. Calendar feeds contain only the selected projection, with approved cancellations included for 30 days. Disconnect stops further reads; deletion of existing event data is a separate instruction.

For processing by (sub-) processors, also specify subject matter, nature and duration of the processing

As listed in Annex IV and on the Sub-processors page, for the duration of this Agreement.

ANNEX III: Technical and organisational measures including technical and organisational measures to ensure the security of the data

Status on Completed at signature:

Assistance to the controller (Clauses 8 and 9):

• We forward any request from a data subject to the controller within 5 business days and do not answer it ourselves.
• Search, export and deletion tools let the controller answer requests.
• Breach notices include the information in Clause 9.2 and follow Supplementary term S3.
• On request, we give the information the controller needs for a data protection impact assessment.

Measures of sub-processors: each sub-processor in Annex IV is bound by a contract with data protection obligations (Clause 7.7(b)); their security measures are described in their DPAs, linked on the Sub-processors page.

ANNEX IV: List of sub-processors

The controller has authorised the use of the following sub-processors (the agreed list under Clause 7.7(a), Option 2). Addresses and contacts are those stated in each provider's agreement and data processing terms, linked on the Sub-processors page.

1. Name: Supabase Pte. Ltd.
   Address: as stated in the Supabase DPA
   Contact person's name, position and contact details: the privacy contact in the Supabase DPA
   Description of the processing: hosting of the database, authentication and file storage for Orestia in the Central EU (Frankfurt) region; storage of all event data.

2. Name: Google Cloud (as named in our Google Cloud agreement), Vertex AI with Claude models through the European Union multi-region endpoint
   Address: as stated in the Google Cloud agreement
   Contact person's name, position and contact details: the privacy contact in the Google Cloud Data Processing Addendum
   Description of the processing: AI processing of the content in each request, to extract facts with receipts and prepare proposals, drafts, summaries and translations.

3. Name: Amazon Web Services (as named in our AWS agreement), Amazon SES and Amazon S3 in Europe (Frankfurt)
   Address: as stated in the AWS agreement
   Contact person's name, position and contact details: the privacy contact in the AWS Data Processing Addendum
   Description of the processing: receiving emails forwarded to Orestia addresses, storing them, and sending notifications.

4. Name: Vercel Inc.
   Address: as stated in the Vercel DPA
   Contact person's name, position and contact details: privacy@vercel.com (as stated in the Vercel DPA)
   Description of the processing: hosting of the web application and its server functions, configured in Frankfurt (fra1); processing of requests in transit. Vercel's primary processing facilities are in the United States.

5. Name: Google Workspace
   Address: as stated in the provider's agreement
   Contact person's name, position and contact details: the privacy contact in the provider's DPA
   Description of the processing: team email, used only when the controller sends event data to our support.